ML20065B949
| ML20065B949 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 02/16/1983 |
| From: | William Jones OMAHA PUBLIC POWER DISTRICT |
| To: | Clark R Office of Nuclear Reactor Regulation |
| References | |
| LIC-83-044, LIC-83-44, NUDOCS 8302230576 | |
| Download: ML20065B949 (4) | |
Text
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9-Omaha Public Power District 1623 HARNEY a OMAHA, NEBRASKA 68102 m TELEPHONE S36 4000 AREA CODE 402 February 16, 1983 LIC-83-044 Mr. Rebe; t A. Clark, Chief
- 3. S. Nuclear Regulatory Comission Of fice of Nuclear Reactor Regulation Division of Licensing Operating Reactors Branch ho. 3 Washington, D.C.
20555 e
Reference:
D9cket No. 50-285
Dear Mr. Clark:
Safety Evaluation Report (SER) for Environmental Qualification of
$dfety-Related Electrical Equipment The Commission's letter dated January 11, 1983 transmitted the subject SER and its attached Technical Evaluation Report (TER) to the Omaha Public Power District.
The SER requested the District reaffirm justifi-cation for continued cperation and submit information on items in the TER which no justification has been previously submitted.
The District has reviewed the TER and has concluded that continued oper-ation of the Fort Calhoun Station does not present undue risk to the public health and safety. The District hereby reaffirms justification
' for the continued operation of TER Items 1 through 114.
As requested by the Commission's letter, items in NRC categories 1A, 2A, and 28 of the TER for which previous justification for continued oper-ation has not been submitted were identified. Ten such items were noted by the Franklin Research Center in the TER.
The following is a list of l
the TER numbers of the ten items:
TER Item No.
Category 8
2A 9
2A 10 2A 11 2A 12 2A 13 2A 14 2A ph l
20 2A i
91 2A L
97 2A 8302230576 830216 PDR ADOCK 05000285 p
e-Mr. Robert A.' Clark LIC-83-044 Page Two In accordance with the request of the SER, additional information regarding these items has been prepared for submittal. This submittal constitutes the District's response to this request and is attached.
Si,nce W. C. Jc le;;
Divistor J Manager Production Operations WCJ/TLP:jmm Attach ient i
cc: LeBoeuf, Lamb, Lef by & 1/acRae 1333 New Hampshire Avenue, N.W.
Nashington, D.C.
20036 Mr. L. A. Yandell, Senior Resident Inspector i.
e ATTACHMENT Position #1 Continued operation of Fisher Model 304 limit switches (TER Items 8-13) is justified.
Resoonse The Fisher Model 304 limit switches involved in TER Items 8 through 13 function to provide valve position indication or.ly. Fa.ilure of the Model 304 ocses no safety hazard since failure will not jeopardize operebility, control, or the fail-safe function of the associated valve.
This valva position can also be determired by checking other parameters.
In the past, a cetailed safety analysis of Model 304 limit switches in containment was performed and submitted to the hRC..which demonstrated continued operatien was justified even if the switches failed.
The switches involved in TER Itaas 8 through 13 are located in rooms of the auxiliary building subjected to a less' severe accident environment than the containment. The effects of radiation and temperature on the au<i-liary building limit switches are spread over a longer daration and are much less severe thar, the rapid, high-intensity parameters experienced by the containment switches; they are not expected to fail under LOCA ccnditions.
The Fisher Model 304 limit switches are scheduled to be tested for qualification purposes. Should they not qualify, they will be replaced.
However, in the interim, based upon the less severe environment, alter-natives available to the operator, and the fact that failures do not present a safety hazard, it is the District's position that continued operation is justified.
Position #2 1
Lack of justification for TER Item 14 has been resolved.
Response
TER Item 14 concerned Fisher Model 304 limit switches located in Room
- 81. The ten switches in question were all replaced by fully qualified NAMC0 EA-180 limit switches.
SCEWS 6-5, 6-95, and 6-102 included with the District's letter dated November 5,1982 (revision to the 79-01B submittal) incorporated information on the existing equipment.
Position #3 Lack of justification for the continued use of TER Item 20 has been resolved.
Response
TER Item 20 concerned NAMC0 Hodel D2400X limit switches located in Room
- 21. The two switches in question were replaced by fully qualified NAMC0 EA-180 limit switches.
SCEW 6-65 included in the District's November 5, 1982 revision to the 79-01B submittal incorporates the existing equip-ment.
. Position #4 i
Continued operation of TER Item 91 is justified.
f
' Response-l TER Item 91 concerns Amp Catalog No. 321280 cable splices located in containment. Wyle Laboratories performed the Environmental Qualifi-cation Evaluation of these splices. Due to a lack of accident test data,14yle Laboratories concluded that these cable splices do not fully i -
qualify in accordance with D0R Guidelines of IE Bulletin 79-013.
Tne District concurs with Wyle Laboratories' opinion (Wyle Report No. 26333-
.26) that from an engineering and analysis ooint of yiew, the splices are capable of safe operation'before, during, and after a LOCA for toe time period required to operate. Based upon this opinion, the Disttict's judgment is that continued operation _ is justified.
l Position #5 Justification exists for the continued operatiors of States terminal blocks (TER Ite'n 97).
Response
i Qualification of these blocks was deemed lacking by the Franklin Re-search Center because similarity between tt.e test specimen and the i
actual equipment in use was not demonstrated. This problem arose from the District's submittal of qualification documentation which identified the terminal blocks as States Madels M25014, M25016, M25018, and M25112.
However, the District feels this concern is urwarranted because _the i
States terminal-blocks in use are, in fact, Type NT.
(Verification of this' fact can be found by referring to the vendor's catalog.)
States Type NT terminal blocks were subjected to LOCA conditions and performed satisfactorily (Plant-Specific Reference #10 of the TER). A j
materials analysis was performed to determine radiation and chemical spray qualification. This was submitted as Enclosure 10 of the November 5, 1982 submittal.
Results of this analysis showed spray and radiation effects would not prevent the terminal blocks from performing their l
design function. Aging analysis was also performed for the District by Wyle Laboratories. The Wyle Laboratories Report #26333-29 demonstrates that the qualified life of the equipment exceeds 40 years.
In addition to these qualifications, the Type NT terminal blocks installed are enclosed in junction boxes of NEMA 12 rating and are covered with Dow Corning 3144 or 3145 RTV.
i It is the District's judgment that the qualification documentation plus the additional conservatism supplied by the junction box and RTV make i-States Type NT terminal blocks capable of safe operation. Their con-tinued use is therefore justified.
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