ML17334B040

Informs That Valves 2-WMO-724 & 2-WMO-726 Will Not Be Removed from Environmentally Qualified Equipment List Contrary to 860530 Response to NRC Audit.Valves Meet Criteria for Environmentally Qualified Equipment

ML17334B040
Person / Time
Site:	Cook
Issue date:	01/21/1987
From:	Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17324B267	List: ML17324B266 ML17334B017 ML17334B040
References
AEP:NRC:0775AK, AEP:NRC:775AK, NUDOCS 8701280418
Download: ML17334B040 (5)

Text

'REGULATORY ~ORNATION DISTRIBUTION SY~N (R IDS>

ACCEHSiCAq NBR: 8701280418 DOC. DATE: 87/01/21 NOTARIZED: NO DOCKET ¹ FACIL: 50-315 Donald C. Cook Nuclear Power Planti Unit ii Indiana 0 05000315 50-316 Donald C. Cook Nuclear Potuer Planti Unit 2i Indiana 5 05000316 AUTH. NAl"fE AUTHOR AFFILIATION ALEXICH> N. P. Indiana Zc Nichigan Electric Co.

RECIP. NAME RECIPIENT AFFILIATION Record Services Branch (Document Control Desk>

SUBJECT:

Informs that Valves 2 MNO 724 8( 2 WNO 726 lllill not be removed Prom environmentally qualified equipment ) i st contrary to 860530 ltr. Valves meet criteria for environmental lg qualified equipment.

DISTRIBUTION CODE: A048D COPIES RECEIVED: LTR I ENCL ~ SIZE:

TITLE: OR/Licensing Submittal: Equipment Qualification NOTES:

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IN D IA N A 8 M IC H I G A N ELEC TR I C COM PA N Y P,O. BOX 16631 COLUMBUS, OHIO 43216 January 21, 1987 AEP:NRC:0775AK 10 CFR 50.49 Donald C. Cook Nuclear Plant Unit Nos. 1 and 2 Docket Nos. 50-315 and 50-316 License Nos. DPR-58 and DPR-74 ENVIRONMENTAL QUALIFICATION OF LIMITORQUE VALVES U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.

20555'ear Sirs:

In our letter of May 30, 1986 we responded to issues raised during the NRC audit of our Electrical Equipment Environmental Qualification program.

One of the issues concerned the results of our inspection of the internal wiring of Limitorque valve operator switches. This inspection was conducted because of reports that other utilities-had found undocumented wire (potentially unqualified) inside the Limitorque switches. At the time of the audit of our Environmental Qualification Program we had found three valves (D. C. Cook Tag Nos. 2-WM0-714, 2-WM0-724, and 2-WMO-726) that contained undocumented wiring. As part of our inspection plan, these wires were replaced with qualified wire.

Following the discovery of the undocumented wiring, an assessment was made regarding the reportability of the event under the provisions of 10 CFR 50.73. Our judgement,'ased on the material which was reviewed at that time, was that these valves were not in an area which would be subjected to a harsh environment, as defined in 10 CFR 50.49, following an accident. Thus, they were not required to be environmentally qualified and were to be removed from the Master Environmentally Qualified Equipment List. This judgement was included as Attachment 8 to our letter of May 30, 1986 and it documented as Potential Enforcement/Unresolved Item No. 6 in Inspection Report is also Nos. 50-315/86015 and 50-316/86015. A subsequent letter, AEP:NRC:0775AH (dated August 27, 1986), and Inspection Report 50-315/86033 and 50-315/86033 also address this issue.

Since the time of the audit, we have been reevaluating the environmental conditions which would exist in the areas which could potentially be exposed to a high energy line break. Of particular concern was the fact that a steam leak resulting from a critical size crack could go undetected for a considerable time period. As a result of this review, which includes a preliminary calculation for the area in which valves 2-WMO-724 and 2-WMO-726 are located, we must change our previous conclusion for these two valves.

(The conclusion remains valid for 2-WM0-714.)

8701280418 870121 PDR ADOCK 05000315 PDR

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8r."Harold R. Denton AEP:NRC:0775AK These two valves are located outside containment in the diesel generator pipe tunnel. This tunnel contains a four-inch steam line that supplies the turbine-driven auxiliary feedwater pump. Should a critical size crack develop in this piping section, it could go undetected for as long as eight hours because the area is patrolled only once per shift. During this time, the temperature would increase, and it is judged that the resulting conditions would meet the 10 CFR 50.49 definition of a harsh environment.

For this reason, these two valves will not be removed from the environmentally qualified equipment list. Since the replacement of the undocumented wires during March 1986, these valves have met the criteria for environmentally qualified equipment, and their qualification will be maintained following existing procedures.

staff.

This matter was discussed with both your staff and the NRC Region III During the course of the discussion, we stated that we believed that the jumper wires were not unqualified, but only lacked qualification documentation. To substantiate this belief we intend to subject the undocumented jumper cables to the appropriate testing. The test program is currently under development. We anticipate that our plans and schedules for such testing will be complete by February 28, 1987.

This document has been prepared following Corporate procedures which incorporate a reasonable set of controls to insure its accuracy and completeness prior to signature by the undersigned.

Very truly yours P. A exich )Q Vice President cc: John E. Dolan W. G. Smith, Jr. - Bridgman R. C. Callen G. Bruchmann G. Charnoff NRC Resident Inspector - Bridgman J. G. Keppler - Region III