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ACCESSION NBR:8211040152 DOC,DATE: 82/10/30 NOTARIZED: YES DOCKETFACIL 50 389 Sts Lucie Plant/ Uni't 2E Florida Power 8t Light Co ~ 05000389

AUTH,NAME . AUTHOR Af FILIATIONUHRIG<R,E, F loriaa Power 8 Light Co ~

'REC IP ~ NAME RECIPIENT AFFILIATIONEI SENHUTg D ~ G ~ D i v i s i on of L i censing

SUBJECT: Forwards Revsion 4 to "Environ Qualification ReptGuidebooki" Vpls 2~4Efor safety related electricalequipment. Responses to NRC comments identified during NRCsite audit ecci, g i</

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. Office of Nuclear Reactor RegulationAttention: Mr. Darrell G. Eisenhut, Director

Division of LicensingU. S. Nuclear Regulatory Commission'jlashington, D.C. 20555

Dear Mr. Eisenhut:

FLORIDA POWER 5 LIGHT COMPANY

October 30, 1982L-82-454

Re: St. Lucie Unit 2Docket No. 50-389Environmental uglification Pro ram

This letter transmi ts Revision 4 of the Environmental gualification Report andGuidebook for safety related electrical equipment for St. Lucie Unit 2.

Attachment 1 to this letter is Florida Power 5 Light's responses to informationrequested by the NRC, as understood by Florida Power 8 Light. The information was

requested as a result of the successful NRC and NRC contractor (EGKG) site audit.

In addition to responding to the information requested the following additionalchanges have been made to the previous submittals:

a) Updating of the various Component Evaluation Sheets to reflect the latestdata.

b) Inclusion of a subject index to Volume 1 to enhance readability.c) Volume 1 update to reflect latest generic industry information.

Revision 4 of the Environmental gualification Report and Guidebook addresses all ofthe above items.

Three copies of this revision are being sent under separate cover to the NRC

Licensing Project Manager for St. Lucie Unit 2 and the NRC staff Equipmentgualification reviewers. Two copies of this revision are also being sent underseparate cover to EGKG Idaho, Inc.

The St. Lucie Unit 2 Eg Report 8 Guidebook will be revised as appropriate by commer-

cial operation to update the status of equipment qualification.

Very tr ours,

04< ~.~L>i e~g",.X

PEOPLE... SERVING PEOPLE

Robert E. UhrigVice PresidentAdvanced Systems 8 Technolr~»

REU/RJS/cab PDR ADOCK 05000389PDR

Enclosure

cc: J. P. O'Reilly, Regional Administratqr, Region II (w/o enclosure)Harold F. Reis, Esquire (w/o enclosure)

~'

STATE OF FLORIDA ))

COUNTY OF DADE )

Robert E hri being first duly sworn, deposes and says:

That he is Vice PresidLight Company, the L>censee herein;

of Florida Power 6

That he has executed the foregoing document; that, the state-ments made in this said document're true and correct to thebest of his knowledge, information, and belief, and that he isauthorized to execute the document on behalf of said

Robert E. Uhrig

Subscribed and sworn to before me this

28 day of OCTOBER 19 82

NO ARY PUBLIC, in and for the County of Dade,State of Florida ~ Qm eF @ebb a ~

My ~~ Exp'pe 20, 1CGS

My commission expires: s,~~ ~

c / ~/~,e

jJ

Att~ent 1 to L-82-454Page~of 6

Table1'pplicantResponses to

NRC Comments as IdentifiedDuring The NRC Site Audit

1) NRC Comment

The applicant is therfore requested to identify those items notemploying type testing in the sequence described in Section 6 ofIEEE Standard 323-1974 and to commit to retesting to the CategoryI requirements.

2)

Ag~~licant Resolution:

The applicant has compiled a list of equipment which does not em-ploy type testing in the literal sense of IEEE 323-1974 as approp-riate for the limiting LOCA/MSLB qualifications (Table 2 attached).The .applicant's position on this issue is in Appendix M, completewith equipment listings.NRC Comment

Although the applicant has described a general procedure for qual-ification of equipment exposed to low level radiation doses, ad-ditional details concerning threshold doses and qualification an-alyses for materials and equipment with solid state componentsshould be provided to the staff for review.

A licant Resolution:

The additional information requested by the USNRC has been provid-ed in Section 8.2 "Qualification Methods" of the Guidebook.

3) NRC Comment

The applicant should address the means by which it will be assuredthat mechanical equipment will function as required while exposed toits postulated service conditions, including design basis accidents.Where design verification cannot be assured before exceeding 5%power, the applicant should discuss the schedule for completion andprovide justification for operation until this effort is completeand full compliance with GDC 4 and Section III of Appendix B to 10CFR 50=is demonstrated.

A licants Resolution:

Additional information on this subject has been included in theForeward to Volume 1 of the guidebook. However, the applicant be-lieves that this is a generic issue where FPL's approach meets orexceeds that of the industry. For this reason, St Lucie Unit 2should not be singled out on this issue. The applicant is willingto meet for discussion with an owner's group of the USNRC to resolveproblems associated with the qualification of mechanical equipment.

/

E

1I

4) NRC Comment

After a detailed review of the applicant's written responses toquestions subsequent to the audit, the staff is concerned witha documentation plan the applicant has established for "commer-cial grade" replacement items. The applicant is required tojustify his classification of any harsh environment electricalequipment as "commercial grade" as compared with the definitionof 10 CFR Part 21. 3 (a) (4) (a-1) . In addition, the plans for thelocation of test reports and qualification analyses should beaddressed with respect to the Commission's requirement for aud-itabile qualification files. This area has been addressed inpart in the April 2, 1982 submittal but only for components suchas resistors, fuses, etc. In the response to a question, theapplicant indicated a complete "equipment" was to be purchasedas commercial grade.

A licant Resolution:

5)

The requested additional information has been provided in Appen-dix E of the Guidebook.

a

Per USNRC request, a correlation of systems presented in the EQReport and Guidebook with those in FSAR Table 3.2-1 was presentedin R'evision 3.

NRC Comment

The applicant must compare all systems in Table 3.2.1 of the FSARwith the systems whose components were included in the harsh elec-trical equipment list (CES sheets). Where there are omissions thereason should be provided (for example, not safety-related, con-tains no electrical equipment, etc.).A licant Resolution:

As requested, table 8 correlating the systems presented in the EQReport and Guidebook with those in FSAR Table 3.2-1 is updated.

6) NRC Comment

Also, complete environmental zone maps should be provided (thesemaps were not furnished in Revision 3). HELB temperature profilesas a function of location are the only missing items at this time.

A~licant Resolution:

Complete environmental zone maps are provided in Revision 4 ofthe EQ Report and Guidebook Appendixes B and C. It has been de-termined that no safety related electrical equipment is found inthose plant X'ocati'ons (pipe chase, hallway, etc) which experienceelevated temperatures due to High Energy Line Break in an adjac-ent area. Verification of this is included in Revision 4 of theGui'debook.

7) NRC Comment

The applicant verbally stated that. post-LOCA "aging" had notbeen used to demonstrate a 40-year qualified life, but shouldconfirm this for all equipment in the EQ program. Category Iequipment is required to be pre-aged for particular qualifiedlife prior to LOCA testing.A licant Resolution:

The applicant has given positive indication in Section 8.4C ofthe EQ Report and Guidebook. that, aging qualification of allequipment was conducted in accordance with the requirements ofNUERG-0588.

8) NRC Comment

Target Rock Solenoid Valve Thermal Lag Analysis: This analysisshould be furnished to the staff for review when completed andshould include the heat. transfer modelling, justification thatcritical surface (surface with highest calculated temperature)is limiting in both time and location, a comparison to the cal-culated ramp time with that achieved in testing (and the effectof any differences), margins in the analysis, and the effect ofa spectrum of break sizes on the calculated surface temperature.

A licant Resolution:

The requested information has been provided in Appendix A of theEQ Report and Guidebook.

9) NRC Comments

The staf f agrees that. the(charging pump) motor is qualified, butonly to the Category II provisions of NUREG-0588. Sequentialtype testing (i.e., thermal, radiation, and mechanical aging,followed by seismic testing) should be performed on an identicalor similar motor to meet the requirements of Category I.

A licant Resolution:

The applicant has provided information regarding their positionon this issue in Appendix M of the Guidebook, entitled "GenericOverview of Separate Effects Testing vs. 'Type'r

'Protype'estingof Motors".

10) NRC Comment

In addition, the qualification methods for equipment with sens-itive electronics exposed to small doses (less than 10 ) shouldbe discussed.

A licant Resolution:

A discussion of the qualification methods for equipment with

10)(cont'd)

sensitive electronics exposed to small radiation doses has beenprovided in Section 8.2 of the EQ Report and Guidebook.

11) NRC Comment

The staff reviewed documentation for mild environment equipmentand the maintenance/surveillance program plan and finds them tobe satisfactory. However, Section 3.10 of the staff SER requiresadditional information concerning the pre-aging of equipment priorto seismic testing.

Substantial information on the issue of aging of equipment priorto seismic testing is provided in Appendix R of the EQ Reportand Guidebook. However, as noted, this is pertinent to section3.10, not Section 3.11.

12) NRC Comment

The applicant's systems list for the environmental qualificationprogram was compared to Table 3.2.1 of the FSAR, the systems listpreviously reviewed by the staff and found to be acceptable. Inorder for the staff to complete this review, tha,applicant should,for each system in Table 3.2.1, indicate its name in the EQ pro-gram (Table 7) or justify its exclusion from the program. Anyomitted systems which are not satisfactorily justified must beincluded in the program prior to fuel load. Appendix D lists thesystems identified to date by the applicant.A licant Resolution:

See Item 5.

13) NRC Comment

The applicant indicated in his program that equipment required byNUERG-0737, "Clarification of TMI Action Plan Requirements, " andRegulateory Guide 1.97Rev 2 would be addressed in additional up-dates to the environmental qualification program. The staff willreview this information after it is furnished and before fuel load.

A~ licant Resolution:

Equipment required by NUREG-0737 and Regulatory Guide 1.97 Rev 2will be addressed in full prior to the implementation date of thisequipment. As much of this equipment is undergoing generic testing(for NSSS or Owner s groups), there can be evolving data which mayeffect qualification data previously supplied.

14) NRC Comment

The applicant is conducting a field verification program to ensurethat equipment is installed as required (i.e., above the flood lev-el). Until tQis,effort is complete and all essential equipmentfound to be subject to submergence is identified, this will remainan open item.

14)(cont'd)

In Paragraph 7.6 of the EQ Guidebook, "Submerged or PotentiallySubmerged Equipment", the applicant has provided information thatcloses out-the EQ Staff review on this issue by outlining a pro-cedure for retaining this feature of the qualification programthroughout the life of the plant.

15) NRC Comment

In addition to the above, a maintenance/surveillance programshould be implemented to identify and prevent significant age-related degradation in equipment., Regulatory Guide 1.33,"Qual-ity Assurance Program Requirements (Operation)," and the ANSI/ANS standard is endorses, state that a preventive maintenanceprogram for safety-related equipment shall be established whichprescribes the frequency and type of maintenance to be perform-ed. A preliminary program based on service conditions and ex-perience with comparable equipment should be developed prior tofuel loading and updated as experience is gained with the equip-ment.

The applicant has described a maintenance/surveillance programplan which conforms with the above guidelines with the exceptionof the implementation date, which is by the plant commercial op-erations date. The preliminary program should be implemented byfuel loading.

A~licant Resolution:

The issue of maintenance/surveillance is addressed in both theForeword and Appendix 0 of the EQ Report and Guidebook. Thereis no applicant dependence on a maintenance/surveillance programas the primary basis for qualification, as all equipment, whetherin harsh of mild environment, will be qualified. A maintenance/surveillance program incorporating repair, operating history,andgeneral housekeeping tasks and schedules, consistent with previoussuccess in both fossil and nuclear plants, will be implemented inorder to maintain high reliability and efficiency of the plant.This maintenance/surveillance plan will be implemented prior tocommercial operation.

16) NRC Comment

Where complete qualification documentaiton will not be abailableby fuel load, the applicant must provide for staff review priorto fuel load justificaitons for interim operation to provide as-surance that required safety functions can be 'accomplished duringaccidents.

A licant Resolution:

Justification for interim operation for each item where completequalification documentaion will not be available by fuel load, aswell as a schedule for completing all outstanding qualification doc-umentaiton, is provided in Volume 4, Tab 5 of the EQ Report andGuidebood, Rev 4. The justification takes into account, theschedules for completing qualification documentation (current asof 10-12-82).

'll

At~ment 1 to L-2-82-454Pag~ of 6

TABLE 2

DOC. PKG. 0

4.2

4 '

4.4

4.5

MANUFACTURER

SIEMENS-ALLIS

GENERAL ELECTRIC

GENERAL ELECTRIC

WESTINGHOUSE

TAG NO.

CSP 2ACSP 2B

AUX FWP 2AAUX FWP 2B

HPSI P 2AHPSI P 2B

'PSI P 2ALPSI P 2B

4.6

4.7

WESTINGHOUSE

WESTINGHOUSE

CHGG P 2ACHGG P 2BCHGG P 2C

2HVE-6A2HVE-6B

4.8 WESTINGHOUSE 2HVE-9A2HVE-9B2HVS-4A2HVS-4B