ML20063M343

Further Supplemental Testimony of Jj Boseman on Behalf of Applicant Re Polymerization of Safety Relief Valve Lubricants.Supporting Documentation & Certificate of Svc Encl.Related Correspondence

ML20063M343
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	08/31/1982
From:	Boseman J GENERAL ELECTRIC CO., LONG ISLAND LIGHTING CO.
To:
References
ISSUANCES-OL, NUDOCS 8209100268
Download: ML20063M343 (16)

Text

r1 AmATED.@RRESPONDENCB DOCKETED

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USNRC

'82 SEP -7 40:42 0FFICE OF SECRETAhY DOCKETING & SERVICE BRANCH LILCO, August 31, 1982 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of

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LONG ISLAND LIGHTING COMPANY

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Docket No. 50-322 (OL)

)

(Shoreham Nuclear Power Station, )

Unit 1)

)

FURTHER SUPPLEMENTAL TESTIMONY OF JOHN J.

BOSEMAN ON BEHALP OF LONG ISLAND LIGHTING COMPANY CONCERNING POLYMERIZATION OF SRV LUBRICANTS 1.

O.

Please state your name and business add'ress.

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'4 A.

My name is John J.

Boseman.

I am employed by the i

General Electric Company.

My business address is

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175 Curtner Avenue, San Jose, California 95126.

My professional qualifications have already been entered into the record of this proceeding.

2.

Q.

Please state the purpose of this Further b

G Supplemental Testimony.

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8209100268 820031 PDRADOCK05000g s

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A.

The purpose of this testimony is to respond to two observations by Judge Morris on August 25, 1982 (Tr. 9507-08), concerning two statements in the answer to Question 4 on page 3 of my August 19, 1982 " Supplemental Testimony.

Concerning Polymerization of SRV Lubricants. "

The first of 1

these related to the statement that " Inspections performed by Wyle Lab of the Hatch SRVs have not disclosed the presence of any castor oil or any foreign substances in the labyrinth seal area Judge Morris' second observation con-cerned my statement that " evaluations performed to date suggest that [ castor oil] could not readily migrate to [the labyrinth seal] area, because of

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i both the length and complexity of the migration path through the valve, and the small amount of castor oil used on the 0-Ring initially."

Judge i

Morris noted, accurately, that the basis for these statements is not stated in my August 19 testimony.

The purpose of this Further Supplemental Testimony l

is to provide that basis.

3.

Q.

What is the basis for your conclusion that inspec-tions performed by Wyle Lab of the Hatch SRVs have not disclosed the presence of any castor oil or any l

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~3-foreign substances in the labyrinth seal area of those valves?

A.

The first basis for this observation is personal conversations with representatives from Wyle Lab and with the Target Rock Corporation field service technician who conducted the inspections of the flatch SRVs.

Those inspections took place during the period from July 5 through July 21, 1982, and involved both visual observation and manual han-dling of the surfaces of the disassembled valves..

Specific attention was devoted during those inspec-tions, at my personal instruction, to (1) the con-dition of the labyrinth seal area, and (2) the pos-sibility of the presence of any foreign materials in the labyrinth seal area and other areas of the SRVs.

If polymerized castor oil were present on a valve surface it would be very likely to be visi-i I

ble.

In addition, its presence would almost cer-i tainly be detected by touch, since polymerization 1

would turn castor oil from a slippery lubricant-into a viscous or tacky substance.

No such evi-donce was discovered during the inspection accord-h ing to the direct verbal and written reports I have received.

I should add that this type of C

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aC s inspection is the normal method of proceeding, and that only if visual or tactile observation dis-closes the apparent presence of some foreign mate-rial or substance are other types of analysis, e.g., chemical or metallurgical, undertaken.

In addition, I have examined photographs of the IIatch SRVs.

The surfaces of the valves in those photographs appeared clean and free of contami-nation from any foreign substance.

I regard the direct reports from other experts, corroborated by photographs, as being a reliable basis for my con-clusion.

4.

Q.

What is the basis for your conclusion that migra-tion of castor oil from the O-Ring area where'it is used to the labyrinth seal area is unlikely?

A.

At the outset, let me note two matters:

first, that the O-Ring in the valve actuator to which I referred in my previous testimony is the only area i

in which castor oil is used in the Target Rock two-stage SRV; and second, that the migration mechanism to which Dr. Morris has directed his inquiry should l

not occur it Shoreham because LILCO intends to implement SIL 196, Supplement #10, prior to plant b

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start-up.

Under Supplement #10, all castor oil will be removed from any parts on Target Rock two stage SRVs and replaced with DAG Dispersion #156.

That SIL Supplement is attached as Exhibit 1 to this testimony.

My conclusion relative to castor oil migration is based on my knowledge of the physical geometry of Target Rock two-stage SRVs and on discussions with other experts who have examined the general ques-tion of polymerization and migration from-thermal and radiation perspectives.

It is important to bear in mind the physical geome-try of the Target Rock two-stage SRV involved.

The O-Ring to which I referred in the answer to Question 4 of my previous " Supplemental Testimony.

." is Part 123 in Figure 1 to Exhibit 1 to this Testimony.

It is also identified as Part 123 in Figure 4 (sheet 1 of 2) and in Figure 6 of the Target Rock Safety / Relief Valve Model 7567F Technical Manual, Assembly 7567F-010 (October j

1980).

I understand that complete copies of this E

document have been made available already to the Board and parties in this proceeding.

Copies of 6

Figures 4 (sheet 1 of 2) and 6 are attached as f=

Exhibits 2 and 3 to this testimony. On Exhibit 2, the 0-Ring is shown as being near the top of the pneumatic actuator section of the valve, at the upper end of the valve.

This physical location is illustrated also in a schematic diagram attached to my January 1982 presentation to the NRC, which was appended to the July 26, 1982 Board Notification 82-79 already introduced into the record at Tr.

7968.

A copy of that schematic is reproduced as Exhibit 4 to this testimony for convenience.

The O-Ring of interest, as can be seen from Exhibit 2 and Exhibit 3 (right hand column), is both small

-- 0.8 inch 0.D.

by 0.6 inch I.D. by 0.1 inch cross-section diameter -- and and deeply buried within the several components of the air operator assembly at the top of the valve.

The components whose functioning the castor oil would have to dis-rupt in order to cause the SRV to malfunction are referred to as the pilot rod and guide liner in the labyrinth seal area (see Parts 53 and 79 of Exhibit 2).

The relative locations of both the pneumatic actuator and the labyrinth seal area are shown gen-l erally on Exhibit 4.

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j In order to reach the labyrinth seal area, any cas-tor oil must first escape from the air operator assembly in the pneumatic actuator area through the cavity in the O-Ring (Part 123).

It would then have to run down through one bushing (Part 74),

then further through an air operator stem (Part 97) past its interface with a large busaing (Part 73) and then continue down Part 97; and then, changing direction, spread along past the lower spring retainer (Part 89), migrate inward to the spherical collar (Part 75) and then drip down or splatter into the labyrinth seal area.

l This is neither a short nor a straight path, and there are many opportunities for material to coat or plate out en route.

It is my judgment, con-firmed by that of other knowledgeable valve person-nel and by inspections at Hatch and elsewhere, that i

such coating or plating out is what would be most likely to happen.

This judgment is confirmed by the total absence of reported contamination of the l

labyrinth seal area by foreign substances in the Hatch inspection.

In addition, I am not aware of any other reported instances of contamination by l

castor oil or other foreign substances of the

labyrinth scal area of other Target Rock two stage valves.

This conclusion is also reinforced by the fact that the amount of castor oil used on t'.1e 0-Ring itself is very small.

The O-Ring has a total surface area on the order of 0.69 square inch.

It is lubricated during the process of valve assembly by manual application of a light, uniform coat of castor oil, which has approximately the same viscosity as com-mon baby oil.

The amount of castor oil used in this process is very small, probably not more than half a dozen drops in all.

These facts, combined with the nature of the pathway required to reach the labyrinth seal area, 1

have led me, and others knowledgeable about Target Rock valves at GE, Target Rock Corporation and Wyle Lab with whom I have discussed this question, 1

to conclude that the likelihood of castor oil reaching the labyrinth seal area in quantities sufficient to have any effect on the valve is extremely low.

$"x 5.

Q.

Does this complete your further supplemental testi-many?

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A.

Yes, it does.

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, gg NUCLEAR FUEL AND SERvlCES olvlSION SAN JOSE. CALIFORNIA 95125 e

April 1981 File Tab B SIL No. 196 Supplement 10 Category 1 s

SRV FAILURES TO OPEN ON MANUAL DEMAND AND AIR OPERATOR SEAL FAILURES General Electric's investigation of recent incidents concerning two-stage Target Rock safety / relief valves (SRVs) failing to open in resoonse to a manual signal has resulted in recommendations to help avoid similar occur-In addition, during the investigation of one of the incidents, rences.

excessive leakage from one of the seals in the air operator assembly was encountered.

As a result, replacement of this seal with a seal having a more temperature resistant material is recommended.

_0ISCUSSION The incidents referred to above resulted in disassembly and inspection of the top-works of the valves.

The failure to open was determined to be due to the excessive use of Loc-tite during the assembly of the solenoid valves.

The procedure for the solenoid valve assembly requires the application of a light coat of Loc-tite 620 to the disc stem thread and to the face of the O

lock nut which contacts the plunger.

Excessive use of the Loc-tite resulted in migration of some of it ir. o the close clearance between the plunger and bonnet tube.

After a period of time it locked the plunger to the bonnet tube to an extent that a manual signal to open the valve would not move the plunger.

Correction of this problem required disassembly of the solenoid valve, clean-ing the outside diameter of the plunger and inside diameter of the bonnet tube with a fine abrasive, and reassembly of the valve in accordance with the SRV technical manual.

As part of the disassembly and inspection of the top works, all of the 0-rings were inspected.

The 0-ring at the air operator stem and bushing interface (see Figure 1) was found to be degraded and broke into segments during removal.

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The E

degradation was determined to be due to a combination of temperature and the use of castor oil to facilitate assembly. The castor oil tends to cause a softening "y

and swelling of silicone rubber and accelerated the degradation of the seal.

Sub-sequent inspections and tests on the same 0-ring from other two-stage Target Rock SRVs has confirmed the need for a different seal material and lubricant for N p

l this application, i

RECOMMENDED ACTION General Electric recommends that the inspections and disassemblies required by J

IE Bulletin No. 80-25, Operating Problems with Target Rock Safety-Relief Valves at BWRs, Items 1 and 2, be done directly by or under supervision of Target Rock l

Field Service Representatives.

Solenoid valves that are disassembled should be reassembled with new 0-rings of the same material; however, use Dag Dispersion

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156 (GE-D50YP2) instead of castor oil for those 0-rings that require a lubricant.

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G EN ER A L () E LECTRIC 5

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SIL No 196 Supplement 10 -

During reassembly of solenoid valves the requirements of the SRV technical manual should be strictly followed, and special care should be taken concern-ing the ", caution" note 'to remove all excess Loc-tite from the plunger, nut l

and stem.

Air operators that are disassembled should be reassembled with a new 0-ring at the stem and bushing interface (see Figure 1).

The 0-ring material should i

be Fluorocarbon V747-75 (Viton V60-C)instead of silicone rubber.

Use Dag Dis-persion 156 (GE-D50YP2) instead of castor oil as a lubricant.

For additional information contact your local General Electric service repre-sentative.

Prepared by:

C.T. Nieh/D.R.Heising Approved by:

[dd JI Issued by D.K. Willett, Manager D.L. Allred, tianager BWR Product Service Utility Support Services '

Product

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SIL Ns. 196 Supplement 10 NOTER ITEM NUM8ERS REFLECT ITEMS AS LISTED IN VALVE ASSEM8LY PARTS LIST 98 109 110 146

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LILCO, August 31, 1982 CERTIFICATE OF SERVICE In the Matter of LONG ISLAND LIGHTING COMPANY (SHOREHAM NUCLEAR POWER STATION, UNIT 1)

DOCKET NO. 50-322 (OL)

I certify that on August 31, 1982, the FURTHER SUPPLEMENTAL TESTIMONY OF JOHN J.

BOSEMAN ON BEHALF OF LONG ISLAND LIGHTING COMPANY CONCERNING POLYMERIZATION OF SRV LUBRICANTS was served by deposit in the U.S. mail, first-class, postage prepaid, on the following:

Lawrence Brenner, Esq.

Atomic Safety and Licensing Administrative Judge Appeal Board Panel Atomic Safety and Licensing U.S.

Nuclear Regulatory Board Panel Commission U.S. Nuclear Regulatory Washington, D.C.

20555 Commission Washington, D.C.

20555 Atomic Safety and Licensing Board Panel Dr. Peter A.

Morris U.S. Nuclear Re'gulatory Administrative Judge Commission Atomic Safety and' Licensing Washington, D.C.

20555 Board Panel U.S. Nuclear Regulatory Bernard M.

Bordenick, Esq.

Commission David A.

Repka, Esq.

Washington, D.C.

20555 U.S.

Nuclear Regulatory Commission Dr. James H. Carpenter Washington, D.C.

20555 l

Administrative Judge Atomic Safety and Licensing David J. Gilmartin, Esq.

Board Panel Attn:

Patricia A.

Dempsey, Esq.

U.S.

Nuclear Regulatory County Attorney Commission Suffolk County Department of Law Washington, D.C.

20555 Veterans Memorial Highway Hauppauge, New York 11787 l

P

. Secretary of the Commission St'ephen B. Latham, Esq.

U.S. Nuclear Regulatory Commission' Twomey, Latham & Shea 33 West Second Street Washington, D.C.

20555 P. O. Box 398 Riverhead, New York 11901 Herbert H. Brown, Esq.

Ralph Shapiro, Esq.

Lawrence Coe Lanpher, Esq.

Cammer and Shapiro, P.C.

Karla J. Letsche, Esq.

9 East 40th Street Kirkpatrick, Lockhart, Hill, New York, New York 11901 Christopher & Phillips 8th Floor 1900 M Street, N.W.

Howard L. Blau, Esq.

Washington, D.C.

20036 217 Newbridge Road Mr. Mark W. Goldsmith Hicksville, New York 11801 4

Energy Research Group Matthew J. Kelly, Esq.

400-1 Totten Pond Road State of New York Waltham, Massachusetts 02154 Department of Public Service MIIB Technical Associates Three Empire State Plaza 1723 Hamilton Avenue Albany, New York 12223 Suite K Mr. Jay Dunkleberger San Jose, California 95125 i

New York State Energy Office Agency Building 2 Empire State Plaza l

Albany, New York 12223 I

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-N Donald P.

Irwin i

l' llunton & Williams i

707 East Main Street i

P.O. Box 1535 k

Richmond, Virginia 23212

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DATED:

August 31, 1982 l

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