ML19261D555
| ML19261D555 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 06/13/1979 |
| From: | Short T OMAHA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| NUDOCS 7906190491 | |
| Download: ML19261D555 (22) | |
Text
.
4 Omaha Public Power District
~
1623 HARNEY s Q M A H A, NEBRASKA 68102 s TELEPHONE S36 4000 AREA CODE 402 June 13, 1979 Director Division of Reactor Operations Inspection Office of Inspection and Enforcement U. S. :Tuclear Regulatory Cc==ission Washington, D. C.
20555
Reference:
Docket :To. 50-235 Gentlemen:
The Cmaha Public Power District received IE Bulletin 79-01, dated February 8, 1979, requesting that certain actions be taken to assess environmental qualification of safety related electrical equipment in-side containment at the Fort Calhoun Station.
The enclosure to this letter provides a comprehersive response to the bulletin, Sincerely, T. E. Short Assistant General Manager TES/KJM/BJH:j==
Enclosure cc:
Mr. K. V. Seyfrit, Director U. S. :fuelear Regulatory Oc==ission Office of Inspection and Enforcement Region IV 611 Ryan Plaza Drive, Suite 1000 2309 230 Arlington, Texas 76011 LeBoeuf, Lamb, Leiby & MacRae 1333 :Iew Hampshire Avenue, Suite 1100 Washington, D. C.
20036 pol 5 il 7906190y7j,.
ENCLOSURE #1 Environmental Desien Conditions When considering the Design Basis Events of a LOCA and high energy pipe breaks, the following adverse environ =ents are postulated:
Environment No. 1 - Containment Te=perature:
- Figure 1 - 2880F Fressure:
- Figure 2 - 60 psig Humidity:
1005 R.H.
Chemical Spray: Chemical spray of boric acid solution of at least 1700 pp boron (minimum concentration specified per Technical Specification 2.3)
Radiation:
- 3 x 106 rad 3
- From "Contain=ent Fressure Analysis", Section 14.16 of FSAR and from
" Design Evaluatien", Section 6.2.5 of FSAR. The temperature transient is based on a large pri=ary coolant syste= pipe break. As can be seen from Figures 1 and 2 (attached), "the maximum centainment pressure is 57 psig at a temperature of 235CF.
If it is assumed that hydrogen does not burn as it is produced but accu =ulates and reacts at the containment peak pressure, the effect is to increase the peak pressure by approxi-mately 2.h psi."
- Section 6.1 3, pa;e 6.1-3, of the FSAR states " Engineered safeguards system control electrical equiptent located within containment is specified at a ga==a level of 1R/Er for h0 years."
This is approri-
=ately.h17 x 105 rads.
The k0 year integrated dose plus LOCA dose (3 x 10 rads), as specified for the Franklin Institute Cable Tests, is used for conservatism.
2309 231
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ENCLOSURE #2 Document References Reference 1 - A) For environ = ental qualification, refer to Joy Manu-facturing Test Report X-377A, dated Septe=ber 3, 1970.
B) See also FSAR Section 1.4.811, pages 1.4-9 through 1.4-14.
Reference 2 - A) Environ = ental qualification per Franklin Institute Re-search Laboratory Test (see Test Report F-C2232-1, dated November, 1968).
B) Radiation qualification per Limitorque Test (see Test Report 30003 of L1=itorque Project No. 600h61. Test perfor ed Nove=ber 13,197k, to January 23, 1975).
Reference 3 - A) Environ = ental qualification per Foxboro Tests of si=ilar transmitters (i.e., tests were performed on standard Ell and E13 :odels). For test results, refer to Fox-boro Test Report Q9-6005, dated April, 1971.
P) Radiation qualification per Foxboro Test Report T2-1075, dated August, 1973, and T3-1097, dated Nove=ber,1973 C) See also FSAR Section 1.k.8.5 and Section 6.1 3 Reference 4 - A) For environ = ental qualification, refer to Franklin In-stitute Research Laboratory Test Report F-C3050, dated May, 1971.
- 3) See also FSAR Sections 1.k,8.2 and 8.5 Reference 5 - A) For environ = ental qualification, refer to Conax Corpora-tion Test Report IPS-37, Revisica A, dated March 8,1971.
- 3) Conax Corporation Test Report IPS h35, approved Nhy 31, 1979 Reference 6 - A) For enviren= ental qualificatica, refer to Franklin In-stitute Research Laboratory Final Report F-C33h8, dated April, 1972.
2309 234
i t
i rm'r m uPr #2 (Page 1 or t )
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ENVIRONMINI (LOCAll0N)
QUAL.
00C.
ITEM EQUIPMENT DESCRIPil0N I4murac ture r PARMK1ER
- SPEC.
QUAL.
METH00*
REF**
REHARKS 1
Containment cooler & re-Environment I ci rculation fan motors I<eliance Kitor ICT- ( I)_
2880F
>2880F fy2graf stic Her. #1 _
fur _ rmil at t e quali-(VA-U R TP. 7D1Relians lhy.Tmr W no_
60 Dsig
]QJgig el. Hum.
Gyggfd g tj c,
ficut,1QJL Cl4t1 Cic a ___ _ _ _.,
motor fun-Joy axivane fan facturing) 100% H.H.
100% R.H.,
Syrjergistic,,
tion refer also to model 60-30-1200 Radiation 3 x 306 rads
>l x 108 rads Separate Anal) sia footnote 1.
For chem-Clem.
y $%t 1"es: t 1000 ppm boron S>nergistic ical analysis, refer ITDO~I@a solut1vu tu ruvuuuue o.
2 Hig.h pres ure_ginfaty in-Heliance H) tor f'
jection valve motor &
(purchased fron ICW' II gQQOE_,____
3%$0f_, _ _ _.
SyM filatic_ 8e f. R._ _
Test was_yerformed
[
operator combinations and Limitorque Corp press. (p514) 60 peig 90ys3 _ _ ___,
Syner6 stic.
on valve yith Fort
}
i low pressure safety in-Rel. llum.
100% H.H.
100% H.H.
Synergistic Calhoun type SMB jection valve motor and Radia tion 3 x 106 rads 2 x 107 ruds Separate Test:
operator.
)
operator combinations
- Chem, B6rvireIrlii-- I-' % s$ uEf5ii(bSSynergistic I
conc. of at Iran we ght 0f actai-1 e a i 1700 ppm Limi torq ue type SMB-0 10 4
and SMB-O-25 type operators
( tiCV-311, 312, 31b. 315.
m___
317. 318, 320, 321 327, 329, 331, 313)
-e 3
Steam generator ani pres-Voxboro n> del surizer pressure trans-EllGM (equipped ICDEL(_ I)
R@(.)F 318 F,
Synergistic de f,_O___ _,
For chem { cal aqal.y-mitteru (transmitters with WA modt-Press. (psia) 60 psig 90 psig Synergistic sia refer to foot-Pi-902 afb /C/DandPT-905 fication)
Rel. Hum.
100% H.H.
100% R.H.
Synergistic note #2.
A/B/C/D and PT-102A/B/C/D Radiation 3 x 106 rads 1 x 107 rada separate Test I
- Chem, conc. of at
, lea st__1_LO1 ppm A+EM_And gle Boric acid in Boric acid of at
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1 1
A east. Aluu ppm
- 19, separate effects, sequential, etc.
- See attached list of reference documents
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ENcInsuHF #2 (Page 2 of h)
ENVIRotetENT (10 Call 0N) tjuAL.
00C.
)
. ITEM EQUIPHENT DESCRIPTION __
HoauractufvJ___
___ PARNtEIER SPEC.
QUAL.
HE Til00
- REF**
REHARKS k
Safety injection flow Foxboro hedel transmitters (FT-313, E13DH leup. (UF) 288vy 3180F Synergistic Re f. # 3,__ For chemical analy-316, 319, 322)
Pless- (Psla) g
_100". H.11.
100% R.H.
Synergis tic note J2.
"NddI3EION 3x 106 rads 1x 107 rads Separate Test i
kNrN""NNtice t
_Htterial Analj ats t700 wm S
Cable leads to cont. cooler Cerro Wire &
_ _ _ _ _ _(UF) 2880F 286"F Synergetic Ref. #b _
For discussion of
& recirculating fan motors Cable Conipany Tenip.
(W10 - 1/C 300 MCH stranded Press. (psla) 60 psit 60 g g Synergistic cables tested refer i
power, 2/C #10 stranded Rel. Ilum.
100% R.H.
100% R.H.
Synergistic to footnote #3.
control, 2/C #12 stranded Radiation 3 x 106 rada 3 x 106 rads Sequential control)
Chem.
fh ht" hbkNo n
fyne rgLsM g.__
1 east 1700 ppm-MT 5T 9.0 l
6 Cable leads to all steam Cerro Wire &
generator, pressurizer, &
Cable Company Ienp. ( f 268 2
OF Synerg ic Hef. #4 or discussion of safety injection flow trans Press. (pSla) 60 psig 60 psig Synergistic cables tested refer mitters (W57 - 2/C #11 Rel. llum.
100% R.H.
100% R.H.
Synergistic to footnote #3.
shielded twisted pair)
Radiation 3 x 106 rads 3 x 106 rada Sequential Chem Iforic acid In--
ic acid o I bo50rpmboron synergistic conc. of at 19 i
Iggst TT00 rpm-7 Cable leads to HPSI & ITSI Cerro Wi re a valves / motors (W21 - 3/C Cable Company Tenp. ( F) 288 F 286 F Synergistic _ Ref. #b For discussion of
- 10 stranded power, W33 -
Press. (psla) 60 psig 60 psig Synergistic cables tested refer 2/C #10 stranded control, Rel. Hum.
100% R.H.
100% R.H.
Synergistic to footnote #3 Wh2 - 12/C #12 stranded Radiation 3 x 106 6
rads 3 x 10 rads Sequential Horic acid in Doric acid R -
~
control)
Chem.
cone. or at 1900 ppm boron Synerglaus_
tEsequential,etc.
)
- fe. separate eff
- Uee attached list of reference documents U
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I ENCIASURE #2 (Page 3 of 4)
INVIROfjMENT (LOCATION)
{
ijuAL.
00C.
ITEH
_ EQUIPMENT DESCRIPTION.
. _. QUAL.
14THOD*
REF" REHARKS 8
Containment electrical pen-Conax Corp.
etration assemblies low Tepp. (Uf) 288oy 3050F Synercistic 1e r. #5 _
For discussion of voltage power, control, &
Press. (psla) psig O ysig 1
instrumentation; medium Rel. Hum.
Syner6 stic test results, refer 1005 H.H.
100_%, H. H..,,
Syner61stic to footnote 5.
voltage power; therancouple Radiatlon 6 rads 1x 10I rads Separate Test I
_3 x 10 coaxial & triaxial
- Chem, ggegplat "
kNNE Th Nm" Synergi sti c least-'lT00 Tpnr-9 Cable splices for #10 AWO AMP So11 strand l
(W21), #12 AWG (Wk2), &
Butt Splices IBH43 I f) 2880F 2860f,, _, _ Q,gygrQ Q _ l h gg, _
A Q _ggble an11,qgg Der
, Press. (p5ta) 60 ps_ig 60_pe_1g Sequentia.1 CHDR Splicing Proce _ _
i
- 1b AWG (W59 thru W63) #18 Penntube PlagM g
i dure XA-545-E k50 &
AWG uninsulated drain wiren Co. Neoprene peg, gum.
100% H.H.
100% H.H.
Se_qwntial _
g_$y_g_gh, 6
j only those cables (above)
Tubing Radiation 3 x 10 cada 3 x 106 rada Material Analpis (These splices are
"?
d N I "10 V
t are required under DHA envi onwn t Chem.
C a
Sequential a[U&
r leasF liOO-ppm-19f r-term MiRTe&Is'~)
l 10 Solenoid valves - ASCO Automatic solenoid valves located on Switch Co.
Teap. (Of) 288 F Not qualirled N/A_
Herer to attached containment isolation Press. (psla) 60 psi 6 solenoid valve dis-valves Rel, llum.
100% H.H.
cussion ( ENCLOSURE 6
Radiation 3 x 10 r da
- 3).
a Chem.
1GH,. M iioratSea L
con.
17D& rpm 11 Limit switches - limit NAMCO D2h00X j
switches located on con-NAMCO D1200d-2 Tenp. (Of) 2880F Not,_qualtried
. 14/A Herer to attached
]
tainment isolation & IDCA Fisher Type 304 Press. (psla) 60 psig limit switch dis-required valves Rel. Hum.
100% H.ll.
e salon (lGC10SUNE. %
m, 6
Radiation 3 x 10 rads
- 4).
Chem.
Boric acid or cone, or at lea t
j -
Aguu ppm
- le separate effects, sequential, etc.
4:
- See attached list of reference documents j
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ENCLOSURE #2 Footuotes 1.
The radiation qualification data cited in these sections is the re-sult of vendor contact or purchase specification requirements. In no case is it evident that the equip =ent was actually tested to failure.
Thus, it is felt that in all cases the radiation levels cited are the =inimum levels with unspecffied =argin to failure.
2.
The pressure transmitters listed were described as having cast aluminum top covers.
Corrosion of aluminum in a slightly caustic and boric acid spray environ =ent vill occur and has been addressed in the FSAR under hydrogen generation in contain=ent (Section 1k.17).
The loca-tion af these transmitters provides them with shielding from the spray, by the 10k5' elevation and the 1013' elevation floor slabs.
For similarly located aluminu=, i.e., ductwork, mounting brackets,
etc., the FSAR assumed negligible corrosion for hydrogen generation.
Those transmitters needed for post-LOCA =enitoring which =ay be sub-
=erged are the H.P. Safety Injection Flow Trans=itters, FT-313, FT-316, FT-319, and F"-322.
Even though this type of transmitter was not subjected to a boric acid spray during the environ = ental type tests done prior to installation, later tests done on similar trans-mitters (see test report Foxboro T3-1013) proved the transmitters capability to withstand a boric acid spray with a 100% air / steam MCA atmosphere for r least a 2h hour duration.
It is OPPD's en-gineering judg=ent tnat these transmitters vill then also be capable of withstanding submergence for at least 2h hours with no adverse effects.
3 As previously stated in the FSAR, the only cables which are required to be operable during and after the design basis accident were =anu-factured by Cerro Wire & Cable Company.
These cables which must be operable during and after the design basis accident are:
a.
the containment cooler motor leads b.
the safety injection =otor leads c.
the safety injection flow transmitters' cables d.
the pressurizer pressure transmitters' cables e.
t.he steam generator pressure transmitters' cables The qualification testing performed by Cerro covers all cables =en-tioned above by testing the largest and the smallest gauge of wire for each type used at the Fort Calhoun Station. Refer to the Franklin Institute Research Laboratories Final Test Report F-C3050.
For the cables listed in EUCLOSURE #2, the known exterior (Jacket)
=aterials are Cross-Linked Polyethylene. A search was made in Perry's Chemical Engineers Handbook for an indication of the relative cor-rosion or che=ical resistance of polyethylene in slightly alkaline solutions and dilute boric acid.
This reference described polyethylene as being resistant to dilute alkali and mineral acid solutions.
Therefore, it is inferred that this =aterial vould not undergo che=1-cal attack by the boric acid spray water.
2309 239
\\
ENCLOSURE #2 Footnotes (Continued) 3 (Continued)
Some additional cables, purchased frca Anaconda and Boston Insulated Wire & Cable Co=pany, which are not requfred to operate under and subsequent to a design basis accident, were also type tested in a fashion si=ilar to that of the Cerro cable.
This was the case for all reactor protective system and engineered safeguard system cables inside and outside the contain=ent not mentioned previously in ENCLOSURE #2.
For copies of these test reports, refer to the Franklin Institute Research Laboratory Final Test Report F-C2525 (Anaconda) and 3oston Insulated Wire & Cable Test Report 3901.
h.
The protective casings for the contain=ent cooler and recirculation fan motors are cade of painted steel.
Considering these steel pro-tective casings in conjunction with the location of these fan =otors (i.e., under ductvork), it is believed that these motors vill not be subjected to adverse chemical spray conditions of a LOCA.
These fan motors were tested prior to installation (per Joy Manufacturing Test, see Report X-377A) to withstand a che=ical enviren=ent of approxi-mately 1000 ppa baron, i.e., 2.5 lbs of boric acid dissolved in 50 gallcas of water.
1000 ppa boren is belev the 1700 ppm bcron =ini-mun specified by the Fort Calhoun Technical Specifications. How-ever, it appears that this difference is negligible due to the afore-centioned facts.
Refer also to Consumers Power Cc=pany sub=1ttal concerning environ-
= ental qualificatien of electrical equip =ent, dated February 2h, 1978, Docket No. 50-255 5
The Conax electrical penetration modules were tested under a chemical /
steam enviren=ent consisting of a boric acid solution of 1900 ppa.
This is underneath the =ini=u= boron concentration of the SIRWT tank, which is 1700 ppm boren or approximately 10,000 ppm boric acid solu-tion. However, the portions of the penetrations which eculd be ex-posed to the adverse chemical spray are =ade of painted carbon steel or FEP teflon. A search through Perry & Chilton's Chemical Engineers' Handbcok has revealed these =aterials to have strong resistance to dilute boric acid solutions.
It is therefore concluded that the boren concentration difference between the solution used in the electri-cal penetration enviren= ental tests and the Fort Calhoun SIRWT tank is insignificant as far as the Cenax electrical penetrations are con-cerned.
2309 240
ENCLOSURE #3 Solenoid Valves ASCO solenoid valves were previously reported to the Nuclear Regula-tory Coc: mission as being environmentally unqualified in LIR 79-014 and by letters dated May 15, 1979, and ahy 29, 197'.
This enclosure contains 9
a safety analysis justifying continued operation as well as a proposed solenoid valve replacement schedule.
Listed below are the solenoid valves which function to operate safety-related equipment within the Fort Calhoun reactor containment.
Also listed is pertinent information relating to the function of each of the valves.
NOTE: Those valves 1 through 19 (below) were previously listed in LER 79-014, since these valves contain plastic internals which =ay degrade due to radiatica and high te=perature, possibly result-ing in repositioning of safety-related valves without a signal for repositioning, provided an air source is available for the valves. ASCO solenoid valves 20 through kh were not listed in LER 79-014, since these solenoid valves did not contain plastic or degradable internals and in the manufacturer's cpinion vould be capable of initially attaining its fail-safe /de-energized position and remaining in this position throughout the duration of a LOCA.
Solenoid Nor=al Energize Accident Fail-Safe Solenoid Valve No.
Drawing State to:
Position Positien Model 1)
PCV-742A GHDR ND Open Closed Closed L3-8316315 11kO5-M-1 2)
PCV-Th2C GHDR ND Open Closed Closed L3-8316B15 11405-M-1 3)
HCV-250hA GHDR ND Open Closed Closed 8320A26 11h05-M-12 h)
HCV-2506A GHDR ND Open Closed Closed 8320A26 11h05-M-12 5)
HCV-2507A GHDR ND Open Closea Closed 8320A26 11kO5-M-12 6)
PCV-2909 CE ND Open Closed Closed 8320A7 23866-210-130 7)
PCV-2929 CE ND Open Closed Closed 8320A7 23866-210-130 8)
PCV-29h9 CE ND Open Closed Closed 8320A7 23866-210-130 9)
PCV-2969 CE ND Open Closed Closed 832 CAT 23866-210-130
- 10) HCV-72hA GHDR ND Close Closed Open 8320A42 11405-M-1
- 11) HCV-72hB GHDR ND Open Open Closed 8320Ah2 11405-M-1
- 12) HCV-725A GHDR ND Close Closed Open 8320Ah2 11405-M-1 2309 241
Solenoid Valves (Continued)
Solenoid Normal Energi::e Accident Fail-Safe Solenoid Valve No.
Drawing State to:
Dsi; ion Position Model
- 13) HCV-7253 GHDR ND Open Open Closed 8320Ah2 11405-N-1 1h) HCV-1107A GHDR NE Close Open Open 8320A8 11h05-M-253
- 15) HCV-1108A GHDR NE Close Open Open 8320A8 11h05-M-253
- 16) HCV-881 GHER NE Close Closed Open 8320A102 11405-M-1
- 17) HCV-882 GHDR NE Close Closed Open 8320A102 11h05-M-1
- 18) HCV-883A GHDR NE Close Closed Open 8320A86V 11405-M-1
- 19) HCV-88hA GHER NE Close Closed Open 8320V86V 11h05-M-1
- 20) HCV-1387A GHDR NE Open Closed Closed 11h05-M-253
- 21) HCV-1388A GEDR NE Open Closed Closed 11405-M-253
- 22) HCV-26033 GEDR NE Cpen Closed Closed 11h05-M h2
- 23) HCV-260hA GEDR NE Open Closed Closed 11405-M h2 2h) ECV 438A GEDR ND Close Closed Open 11kO5-M ho
- 25) ECV h38C GEDR ND Close Closed Open 11h05-M-40
- 26) HCV h67A GEDR NE Open Closed Closed 11h05-M-40
- 28) PCV-Th2E GHDR NE Open Closed Closed 11h05-M-1
- 29) PCV-742G GHER NE Open Closed Closed 11405-M-1
- 30) HCV-Th6A GHDR ND Open Closed Closed 11h05-M-1
- 31) TCV-202 CE NE Open Closed Closed 23866-210-120
- 32) HCV-2h1 CE NE Open Closed Closed 23866-210-120
- 33) HCV-Sh5 CE ND Open Closed Closed 23866-210-130 3h) HCV-2916 CE ND Open Closed Closed 23866-210-130
- 35) HCV-2936 CE ND Open Closed Closed 23866-210-130
- 36) HCV-2956 CE ND Open Closed Closed 23866-210-130 2309 242 4
Solenoid Valves (Continued)
Solenoid Nor=al Energize Accident Fail-Safe Solenoid Valve No.
Drawing State to:
Position Position Model
- 37) HCV-2976 CE ND Open Closed Closed 23866-210-130
- 38) HCV-238 CE ND Close Open 23866-210-120
- 39) HCV-239 CE ND Close Open 23866-210-120
- 42) HCV 425C GHDR NE Open Closed Closed 11405-M 40 h3) HCV-204 CE NE Open Closed Closed 23866-210-120 kh) HCV-208 CE '
ND Close Open 23866-210-120
" Indicates ASCO Model '4P-HT-831h29 for: "F" solenoid valve.
---Indicates the valve has no auto =atically initiated accident position.
As =entioned previously in LIR 79-01k, the Fort Calhoun plant opera-tors have been instructed to fail instrument air to contain=ent during post-LOCA conditions, if solenoid failure is detected, which could poten-tially cause solenoid failures.
Failure of instrument air vill ensure that these safety-related valves are maintained in their safety position.
It is emphasized that failure of instrument air to containment vill not jeopardi e the ability to safely shutdown the plant and =aintain it in a safe shutdown condition.
New environmentally qualified solenoid valves will be ordered, and replacement of these valves vill begin upon receipt and be ec=pleted during the 1980 refueling outage.
A test progra= will be initiated if necessary to determine qualification of these new valves.
For all those valves (1 through hk) listed above, with the ex-ception of the Containnent Recirculating Fan da=per valves, HCV-72hA/B and HCV-725A/3, redundant isolation valves outside of containment have been provided.
Certification of enviren= ental qualification for the new solenoid valves to be installed vill be forwarded to the Conmission as soon as it is received by the District.
2309 243
ENCLOSURE #4 Limit Switches Stem-=ounted li=it switches (NAMCO D2400X SNAP-LCCK li=it switches) were reported to the Nuclear Regulatory Conmission as being enviren=entally unqualified for an adverse LOCA environ =ent by letters dated March 16, 1979, and March 29, 1979, and by_ LER 79-007 At the time these limit switches were reported, their function was considered as non-safety related due to the fact that they did not function to provide the lock-in/ loc'-out feature of the a
valve control circuitry mentioned as the subject of IE Bulletin 78-Ch.
Rather, all limit switches reported in response to IE Bulletin 73-Oh func-tion solely to provide contacts in external position indicator light cir-c uitry. For convenience, listed below are the valves in which the limit switches (N/J4C0 D2h00X limit switches) were installed:
1.
HCV-h26C 10.
PCV-103-1 2.
HCV h27C 11.
LCV-101-1 3.
HCV 428C 12.
LCV-101-2 h.
Hr.' h29C 13.
HC7-2500 5.
Pci -2909 14.
HCV-2501 6.
PCV-2929 15.
HCV-2502 7
PCV-2949 16.
HCV-2503 8.
PCV-2969 17.
HCV-250hA 9
PCV-103-1 18.
HCV-2506A 19 HCV-2507A NOTE: Each valve listed above has two limit switches.
A follow-up inspection was performed by the NRC/ Region IV.
During this inspection, the inspector 'nfor=ed OPPD representatives of the NRC position that such limit switche s should be qualified for operatica under LOCA conditions if they provide position indication of valves which are used for primary containment isolation.
The following valves using NAMCO D2400X SNAP-LOCK limit switches perform a containment isolation function:
1.
PCV-2909 h.
PCV-2969 2.
PCV-2929 5.
HCV-250hA 3.
PCV-2949 6.
HCV-2506A 7
ECV-2507A
.'everal = ore limit switches were identified in the Fort Calhoun Stati n reactor containment as being unqualified for service in a LOCA environ =ent, in response to II Bulletin 79-01.
These limit switches were reported as such to the Nuclear Regulatory Conmission. The foi-loving safety analysis justifies continued operation.
Also contained within this enclosure is a schedule for replacing unqualified limit switches with qualified limit switches.
For convenience, a list is provided (below) indicating all limit switch / licit switch models contained on safety-related valves which could possibly be subjected to adverse LOCA conditions. It should again be 2309 244
Limit Switches (Continued) pointed out that these limit switches function to provide valve position indication only.
Valve No.
Limit Switch PCV-2909 NAMCO D2400X PCV-2929 NAMCO D2h00X Pcy-2949 NAMCO D2h00X PCV-2969 NAMCO D2400X HCV-250hA NAMCO D2h00X HCV-2506A NAMCO D2h00X HCV-2507A NM4C0 D2400X HCV-881 NAMCO D1200G-2 HCV-882 NAMCO D1200G-2 HCV-883A NAMCO D1200G-2 HCV-88hA NAMCO D1200G-2 HCV-438A NAMCO D1200G-2 HCV h38C NAMCO D1200G-2 HCV h67A NAMCO D1200G-2 HCV-h67C NAMCO D1200G-2 HCV-h25A NAMCO D1200G-2 HCV 425C NAMCO D1200G-2 TCV-202 NAMCO D1200G-2 HCV-238 NAMCO D1200G-2 HCV-239 NAMCO D1200G-2 HCV-2hD NAMCO D1200G-2 HCV-2h1 NAMCO D120CG-2 HCV-1387A FISER TY?E 30h HCV-1388A FISHER TYPE 30h HCV-26033 FISHER TYPE 30h HCV-260hA FISER TYPE 30h HCV-1107A FISHER TYPE 30h HCV-1108A FISER TYPE 30h PCV-Th25 FISER TYPE 30k PCV-Th2G FISHER TYPE 30h HCV-Th6A FISER TYPE 30h HCV-Sh5 FISHER TYPE 30h HCV-2916 FISER TYPE 30h HCV-2936 FISHER TYPE 30h HCV-2956 FISHER TYPE 30h HCV-2976 FISHER TYPE 30h As previously discussed in 123 79-007, fcur pcssible modes of limit switch failure were postulated.
These modes of limit switch failure are listed below, along with the postulated consequences cor-responding to each of the failure modes:
2309 245
Limit Switches (Continued)
Mode 1) Limit Switch Short Circuits - this vould result in possible indication of both "open" and " closed" position of the valve, i.e.,
both lights could possibly be lit.
If such is the case, the Fort Calhoun operators have been instructed to rely upon related process instrumentation for indication of true valve position.
Mode 2) Limit Switch Open Circuits - this would result in a com-plete loss of position indication.
Again, operators have been in-structed to be aware of this condition and if necessary rely upon the appropriate process instru=entation for valve indicaticn.
Mode 3) Grounding of the power supply through limit switch failure -
again, as stated in the previous sub=ittal, the Fort Calhoun instru-ment buses are designed to operate with a ground. The circuit de-sign is suhh that only one line-to-ground fault would occur, i.e.,
the negative bus vould be grounded and the other line is held above ground by the resistance of the light indication circuitry, (refer to Figure 1 attached). It was previously stated that in the event both lines, positive and negative, were grounded, the control fuses located in the individual containment isolation valve circuit would
" blow" and the valve would assume its fail-safe position. This state =ent should be clarified by saying that it is unlikely that the grounding of the positive and negative leads of the li=it switch would cause the fuse to " blow" since the resistance of the light indicator circuitry would tend to hold the voltage of the circuit above ground, (refer to Figure 1).
It is our belief that since the light bulb resistance =akes up the =ajor portien of the total cir-cult resistance, it would be extre=ely unlikely that the grounding of the limit switches would cause the control fuses to " blow".
However, if the fuses were to blev, the valve vould go to its fail-safe position. In the extre=ely unlikely event that the fuses to a particular valve were to blev, the li=it switch leads may be dis-connected, thus eli=inating the= from the circuit.
Upon doing so, the fuses vill then be changed and operability of the valve vill be restored.
It is pointed out as a reminder that in certain cir-cu= stances, if a centrol circuits' fuses were blevn causing the valve to go to its fail-safe position, the desired or accident position =ay not be attainable.
In such circumstances redundant (outside contain=ent) valves provide the necessary isolaticn.
For exa ple, ECV-881 - this valve's accident position is closed but its fail-safe position is open.
If the control circuit fuses to this valve were blown i==ediately following a LOCA, the valve vou'.d go to its fail-safe (open) position until operability to the valve
~
could be restored.
During the interim, however, isolation =ay still be provided by valves located outside the containment.
Mode h) Tracking to the solenoid valve - as discussed per pre-vious submittal, it was concluded that the occurrence of " tracking" will not cause any malfunction or loss of valve operability and vill not inhibit any valve from carrying out its intended design function.
In addition, tracking would not cause the malfunction of any other safety-related equipment.
2309 246
Limit Switches (Continued)
Lastly, all unqualified limit switches vill be replaced with en-vironmentally qualified limit switches during the next two refuel-ing outages.
t 2309 247 e
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FIGURE NO. 1 TO ENCLOSURE #4 T.'.
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ENCLOSURE #5 Terminal Blocks The terminal blocks provided for the Fort Calhoun Station reactor contain=ent are States Company NT-type terminal blocks. Specifically, the States =odel nu=bers M-25104, M-25106, M-35108, and M-25112 tersinal blocks are prevalent in the Fort Calhoun reactor containment. As mentioned previously in response to IE Bulletin 78-02, none of the terminal blocks located inside the containment have been left unprotected. Rather, all terminal blocks have been covered with Dow Corning 31hh RTV adhesive / sealant and installed in protective junction boxes.
The District is presently in negotiations with the General Electric Co=pany and the Alabama Power Co=pany in an effort to attain environ = ental qualification documentation corresponding to the States NT-type block.
It is our engineering judg=ent that upon co=pletion of these negotiations, OPPD vill have attained applicable data which vill qualify our States NT-type terminal blocks for operation in a post-LOCA envircnnent.
The Nuclear Regulatory Co==ission vill be forwarded docu=entation verifying environ = ental qualification of these States NT-type terminal blocks by August 15, 1979 If negotiations or docu=entation provided in the future do not provide adequate environ = ental qualification data, as intended, the Co==ission vill be notified i==ediately.
2309 249 O
ENCLOSURE #6 Containment Fan Cooler Motor Solices The containment cooler fan motor lead splices (VA-3A, 33, TC, and TD motor lead splices) are, in OPPD's engineering judgment, environmentally qualified for the adverse conditions of a LOCA. Reasons for this judgment stem from the following:
1)
First, eight half-laps of Scotch Brand #70 tape are applied to the bare joint / splice. Second, eight half-laps of Bishop Brand #3 high voltage tape are applied over the splice sur-face. Third, the joint / splice area is then covered with eight half-laps of Scotch 3 rand #88 tape.
Fourth, an additional two half-laps of Scotch 3 rand #70 tape is then applied over the general splice / joint area. Lastly, the entire splice / joint area is covered with Dow Corning RTV #314h compound at least 1/8" thick and at least 1" beyond all applied tape.
The RTV is sacothed to completely seal the splice / joint and then the RTV is allowed to cure in accordance with instructions.
2)
Recent conversaticas with the manufacturer of Scotch 3 rand #70 and #88 tapes have revealed satisfactory test results were ob-tained for sa=ples of the two aforementioned tapes when sub-jected to radiat' ion fields in the neighborhood of 50-100 x 106 rads.
Due to the RTV sealant, this tape vill not be subjected to the pressure, =oisture (1005 R.H. ), boric acid conditiens present in a LOCA.
In addition, both tapes mentioned above are capable of operating in te=peratures in excess of 3500F vith no subse-quent damage.
3)
The entire splice / joint is covered with a layer of RTV #31hh adhesive / sealant.
Conversations with the manufacturer of the RTV, Dow Corning, revealed that several laboratory tests were run on the afore=entioned RTV.
Results of these testa revealed that the Dov Corning RTV #31kh was capable of operating in en-viron=ents greater than 102 x 10D rads (total integrated dose) with no appreciable deficiencies.
In addition, the #31hk RTV reacts with water vapor in the air to cure. Upon curing, the adhesive / sealant becomes resistant to hu.idity and temperatures up to h820F over long periods of.tice.
The RTV #31hh sealent will effectively seal off ell environ =ents from the underlying Scotch Brand tapes and the splice except for radiatien.
The
- 31hh BTV is also not adverrely affected by boric acid solutions in excess of 5%.
Further evidence of Dov Corning #31hh RTV sealant / adhesive's ability to stand up to the adverse conditions of a LOCA is documented by the Fisher Controls Co=pany valve actuator tests.
In these tests, Dov Corning #314h adhesive / sealant was used to cover all bara terminations. Results of the tests provided evidence that throughout the simulated LOCA environment no ter=ination covered with #314h RTV vas found to be shorted or damaged.
Test parameters included temperatures in excess of 2880F, pressure in excess of 60 psig, and a 100% saturated steam environment.
No credit is taken for the Bishop #3 high voltage tape.
---me----
C 1
ENCLOSURE #7 ADDITIONAL AREAS OF CONCERN Connectors Several different types of connectors were found in " safety circuits" (i.e., RPS, nuclear instrunentation channels as well as certain triaxial /
coaxial containnent feedthroughs and rod drive units). However, as pointed out previously in OPPD's response to IE Bulletins 77-05 and 77-05A, none of the connectors found were located in circuits that need to be qualified
.or post-IDCA conditions.
I I
2309 251
_