ML20069F100

Forwards Rev 1 to Chapter 7 to Response Re Environ Qualification of Electrical Equipment.Rev Justifies Continued Operation W/Equipment W/O Complete Documentation Qualification,Per NRC

ML20069F100
Person / Time
Site:	Oyster Creek
Issue date:	03/16/1983
From:	Fiedler P GENERAL PUBLIC UTILITIES CORP.
To:	Crutchfield D Office of Nuclear Reactor Regulation
References
NUDOCS 8303220313
Download: ML20069F100 (24)

Text

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,, .. 9 GPU Nuclear NQQIQf P.O. Box 388 Forked River, New Jersey 08731 609-693-6000 Writer's Direct Dial Number:

March 16. 1983 Mr. Dennis M. Crutchfield, Chief Operating Reactors Branch #5 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 205'i5

Dear Mr. Crutchfield:

Subj ect: Oyster Creek Nuclear Generating Station Do eke t No. 50-219 Safety Evaluation Report for Environmental Qualification of Safety-Related Electrical Equipment Your letter dated November 30, 1982 to P.B. Fiedler transmitted the Safety Evaluation Report (SER) and Technical Evaluation Report (TER) for Environmental Qualification of Safety-Related Electrical Equipment at Oyster Creek Nuclear Generating Station.

Your letter requested that GPU Nuclear Corporation (GPUNC) reat firm the previously submitted justification for continued operation (JFCO) and within thirty (30) days of our receipt of your letter, submit information for items in NRC categories 1B, 2A, and 2B for which JFC0 was not previoulsy submitted to the NRC. In our recent phone conversation with your staf f, we requested an extension of our response to the SER by approximately one month. Our revised JFCO is attached to this letter as Revision 1 to Chapter 7 of our December 28, 1980 submittal on environmental qualification. Also, in Section 3 of Appendix D to the TER it is stated that there are no additional items requiring JFCO.

Based upon the above consideration, GPU reaf firms the JFCO.

Your letter also requested that GPUNC inform the NRC, as indicated in the proprietary section of the Safety Evaluation Report, whether any portions of the identified pages still require proprietary protection. Review of our previously submitted information indicates that none is classified as propri e tary. However, Franklin Research Center (FRC) has attempted to obtain some information f rom secondary sources (vendors, etc.) which is indicated as proprietary and used in the subject SER for the Oyster Creek Nuclear Generating Station. It is our position that the burden of responsibility for the proprietary nature of this material rests eith the NRC and its contractor, FRC.

/od r303220313 830316 PDR ADOCK 05000219 P pop GPU Nuclear is a part of the General Public Utihties System

< 1

,, 'a The subject SER requested verification that the containment spray system is not subjected to a disabling single component failure (Section 4.3.3.2 of the FRC TER). Our investigation shows that redundancy (both physical installation and power supply) is provided for the containment spray system to avoid a single component failure that would prevent remote-manual initiation of containment spray.

GPUNC plans to complete replacement or qualification of unqualified equipment or subcomponents as described in the previously submitted System Component Evaluation Work Sheet (Rev 1) by the end of the Cycle 11 refueling outage (which is the second refueling outage after March 31, 1982).

Installation of the environmentally qualified equipment , as required by NUREG 0737 (TMI Action Plan), will also be completed by the end of the Cycle 11 outage.

In our telephone conversation with your staf f on January 31,1983, we requested clarification concerning steam exposure, applicability of qualification report, etc., as indicated in TER. We were told by the NRC staf f that a meeting will be arranged in the near future to clarify these issues.

Very truly yours,

~

Y- -

Peter B. Fiedler Vice President and Director Oyster Creek PBF:jal Attachment-cc: Ronald C. Haynes, Administrator Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 NRC Resident Inspector Oyster Creek Nuclear Generating Station Forked River, NJ 08731

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12/30/82 CHAPTER 7 OYSTER CREEK NUCLEAR GENERATINC STATION )

ENVIRONMENTAL QUALIFICATION OF ELECTRICAL EQUIPMENT JUSTIFICATION FOR CONTINUED OPERATION WITH EQUTPMENT THAT DOES NOT llAVE COMPLETE QUALIFICATION DOCUMKNTATION As indicated on the System Component Evaluation Work Sheets (Chapter 6), the equipment that lacks adequate qualification documentation will be qualified through further document searches, replaced with qualified or to -

be qualified equipment, or qualified through test, analysis, etc. This chapter provides the justification of the interim use of existing equipment until it is either qualified or replaced with qualified equipment.

NOTE: Equipments identified with an asterisks (*) indicate that equipment is not required to mitigate the consequences of an accident outside of containment or to achieve a safe shutdown for that accident. For a break inside containtent, asterisked items are needed to mitigate the accident, however, the environmental conditions for these asterisked items would be normal ambient conditions.

1. Automatic Depressurization System (ADS) Pressure Switches LA83A IA83B IA83C IA83D IA83E

Hevision 1 .

a f The pressure switches will open the electromatic relief valves in the Automatic Depress:arization 5ystem on an overpressure condition in the reac-tor pressure vessel. Each pressure switch is installed at a dif ferent loca-tion outside the Drywell and a single high energy line break in the vicinity the will not subject all five switches to a peak temperature and pressure at ..

same time. These switches are necessary only for over pressurization protection and their failure does not af fect the ability of the Control Roon operator to manually operate the ADS valves in order to achieve a controlled cooldown. Even without the relief valves, reacrer vessel overpressure protection is provided by sixteen (16) safety valves located inside containment and will be unaf fected by any HELB's outside containment.

2. Drywell Vent and Purge Valves V-26-16* .

V-26-18*

Qualified Equipment .

3. Containment Spray Valves V-21-5*

V-21-11*

Qualified Equipment I 4. Reactor Building Closed Cooling System Isolation Valves V-5-167*

l V-5-14 7

• l 1

Qualified Equipment l

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,y,,ma w,-- -w ,, , pny=,,ypr ,4.p y esm 4 ry_

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5. Containment Spray Valves V-21-13

• V-21-17

• V-21-3

• V-21-9

• V-21-1

• V-21-7

• Qualified Equipment

6. Drywell Hi-Pressure Scram Switch RE-04A

• RE-04B* .

. RE-04 C* .

RE-04D*

• These switches are installed just outside the drywell wall and monitor the pressure inside the Drywell. These switches are only used to detect a HELB or LOCA inside containment and will not be subjected to the harsh en-vironment tha t they are required to sense.

7. Raactor Vessel Pressure Transmitter ID-45 ID-46A ID-46 B

nevisie t

. r These transmitters provide reactor vessel pressure indication to the They do not provide a safety function and their Crntrol Room operator.

failure can not hinder the actuation of the Auto Depressurization System cnd/or the Core Spray System.

8. Isolation Condenser Level Transmitter IG-06A IG-06B These transmitters provide the Control Room operator with isolation I f these transmitters should f.2i1 the condenser sater 1cvel imlica t ion. for up to Isolation Condenser System can accommodate the reactor decay heat If only one condenser I hour and 40 minutes without need f or make-up water.

up to 45 minutes after a is available, it can accommodste reactor decay heat The reactor can

. scram from full power before make-up water is required.

d cooled also be depressurized by using the Auto Depressurization System an be adversely These two systems will not by using the Core Spray System.

af fected by the same HELB that IG-06A, B will be subjected to.

9.

Reactor Isolation Temperature Switches IB-10 (A thru P) i Qualified Equipment

10. Reactor Water Level Transmitter ID-13A ID-138

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Hevision I ,

These transmitters provide reactor water level indication to the Con-trol Room operator. They do not perform any safety functions and their failure will not hamper other water level indicators /alarns or SCRAM signal s.

11. Core Spray Pressure Switch

• RV-29A RV-29B RV-19C .

RV-29D These switches are used in the Auto Start circuits of the Core Spray pumps. If these switches should fail, the Control Room operator can man-ually start the pumps. -

12. Core Spray Pressure Switches RV-40A RV-408 RV-40C RV-40D i

These switches are used in the Auto Start circuits of the Core Spray pumps (booster pumps). If these switches should fail, the booster pumps can be started manually by the operator.

Flow Transmitters RV-26A RV-26B sua e #

.> {

RLvision 1

. e ese tranmitters only provide indication to the Control Room of flow in the Core Spray System for either tests or actual use. If they should fail, other reactor vessel instrumentation, e.g. reactor water level indication, could be used to determine if core spray is functioning.

13. Isolation Coudenser Area Temperature Detectors IB-06-A IB-06-B IB-06-C s IB-06-D The isolation condenser atea temperature monitors provide indication in the control room of steam leaks in the area. These temperature detectors do not provide any automatic safety functions, but are referred to in the station emergency procedures as one of the parameters that can be used to detect leaks in the isolation condenser system. Since the system is pri-marily there to detect leaks not breaks it is unlikely that the area temper-ature will reach those levels described in the worst case break analysis.

14. Containment Spray Flow Transmitter IP-03-A

• IP-03-B

• The Containment Spray flow transmitters are used by the control room operator to verify that the containment spray system is delivering its re-quired flow. The containment spray system would be used if there had been an inside containment IIELB or LOCA or the torus had to be utilized as a heat sink in order to achieve safe shutdown. Also, this system maybe used if the Drywell has reached its design temperature due to a loss of Drywell cooling.

l It should be noted that these instruments provide only indication and do not

-6" J

Revision 1 o '

perform any automatic safety functions. Even considering the loss of this indication, the operator has various other backup parameters that will verify _ adequate system flow. They are: containment spray motor amperes, pump discharge pressure, torus temperature and valve position.

15. Containment Pressure Switches IP15-A*

IP15-B*

IP15-C*

IP15-D*

These switches monitor the drywell pressure and provide one of two auto start signals required to actuate containment spray. These switches are lo-cated outside the drywell (containment) and are only used to mitigate loss of Drywell cooling, a HELB or LOCA inside containment, therefore they will not

, be subjected to the harsh environment that they are required to mitigate.

If these switches should fail, there are other indications of a HELB or LOCA

! in containment and the operator has the opportunity to manually actuate containment spray.

16. Drywell Pressure Transmitter IP-07*

This transmitter only provides drywell pressure indication to the con trol roor. It is located outside the dryr211, and therefore it will not be subjected to the HELB or LOCA in containment that it is sensing. If this transmitter should fail, the operator has other means of detecting a HELB or LOCA in the drywell, e.g. drywell sump level sensor and transmitter, drywell radio gas monitor, drywell radio particulate monitor, drywell and suppression pool pressure icdicators and recorder, drywell temperature recorders, suppression pool level indications and recorders.

1 REvicion 1

18. Drywell Pressure Switch RV-46-A*

RV-46-B*

RV-4 6-C*

RV-46-D*

These switches monitor the drywell pressure and provides an auto start signal required to actuate core spray. These switches cre located outside the drywell and are used to sense an accident inside containment. Therefore they will not be subjected to the harsh environment that they are required <

to mitigate. If these switches should fail, there are other signals to automatically or manually start core spray, e.g. reactor water level.

19 . MSL Low Pressure Switch RE 23-A RE 23-B RE 23-C RE 23-D Qualified Equipment

20. Main Steam Line High Flow Switch RE 22A RE 22B-RE 22C RE 22D RE 22E RE 22F RE 22G' RE 22H'

Revision 1 Thsco switches, which cra locatsd outside cantaminment, monitor the

~

main steam lines flow. They will remain in ambient conditions during any of the postulated accidents and the 40 year plus 1 year post accident radiation dosage is 6.1 x 10' R. It is unlikely that all of these switches will fail to perform their function in the event of en accident.

21. Isolation Condenser A P Switch IB-05Al IB-05A2 IB-05 B1 ,

IB-05B2 IB-11A1 IB-1LA2 IB-11B1 IB-11B2 These switches provide automatic valve closure on the isolation con-denser system given a detected pressure change (line break). If these switches fail before their time delay expires due to the postulated HELB, there are other means for the operator to determine an isolation condenser HELB and manually close all valves, e.g. reactor pressure, radiation monitor and reactor water level instruments.

22. Core Spray Pressure Switches RE-17-A EE-17-B RE-17-C RE-17-D

_9_

[-[~ .Revtalon 1-

.. i These pressure switches monitor reactor pressure and are interlocked with the core spray auto initiation legic to prevent core spray inject ion i

valves from opening until reactor pressure is 285 psig decreasing. If these switches should fail, the operator can manisally open the core spray injection' valves from the Control Room.

23. Reactor Pressure Switch RE-15-A RE-15-3 RE-15-c RE-15-D These switches automatically trip the recirculation pamps and initiate the isolation condenser system on high reactor vessel pressure. Switches RE-15A and B are located in RK-01 and RE-15C and D are located in RK-02.

Therefore, only two of these switches will be subjected to the harsh environ-ment of a HELB while the other two will see relative ambient conditions.

24. Reactor Pressure Switch RE-03-A RE-03-B RE-03-C RE-03-D

Revision 1 1

'These pressure switches'are the switches used to provid'c a scram sin-nal on reactor high prensure. This is not the-scram signal that would be utilized to shutdown the reactor in the event of a rupture of eit her the Emergency Condenser or the cleanup system (the HELB's that will effect theso switches).

25. Reactor Water Level Switch RE-05-A RE-O 's-li These water level switches along with RE-05/19A and RE-05/193 provide a scram signal on low water level. These switches are supplied with redundant power supply and physically separated. The areas where the switches are located are monitored by area temperature detectors. These detectors will warn the control room operator of leaks in those systems long before the pipes rupture. - This will enable the operator to isolate - the le ik before the harsh environment is established.

26. Reactor Water Level Switch RE-02-A RE-02-B RE-02-C RE-02-D These switches provide an auto start signal to core spray, provide a containment isolation signal, provide a reactor isolation signal and pro-vides one of the signals required for an automatic containment spray start.

Reviston 1 These switches are redundant and located in separate areas. These areas are. monitored by ared temperature detectors, which will warn the control room operator of leaks in the clean-up systems long before the pipes

-rupture. This will enable the operatur to isolate the leak before the harsh environment is established.

27. Purge Valves and Nitrogen Valves V-27-1*

V-27-2*

V-27-3*

V-27-4*

V-23-13*

V-23-14

• V 17

• V-2 3- 18

• These containment isolation valves are normally closed during plant operation and will not -change position given a failure of the solenoid valve. They will not see the environmental effects of the HELB/LOCA that they are required to mitigate.

28. Nitrogen System Valves V-23-15*

V 16

• V-23-19

• V-23-20*

l _19.

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Revision'l

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These containment isolation valves are norma'lly closed during plant operation and will not change position given a failure of tiie soleroid valve.

They. are in a non h'arsh temperature / pressure environment for the llELil/LOCA in containment which they are to mitigate.

29. Particulate Monitor System, 0 Analyzer 2

System and Torus Sample

. System Valves V-38-16*

V-38-17*

V-38-9*

V-38-10*

V-38-22*

-V-38-23*

These valves will remain in an ambient environment for the llEl.11/I,0CA inside containraent they are required to mitigate. If these valves sh ou lil fail, they will fail closed which is the desired position.

30. Ventilation Valves V-23-21*

V-23-22*

V-28-17*:

l V-28-18*

! V-2 8-4 7

• r i

L

Revision i

. . . s These are containment isolation valves that are normally closed during plant operation and will not change position given a failure of the notenoid valve. They will not see the harsh environment of the ilF.I,ll/l OCA that they are required to mitinate and it is unlikely that they will not he able I. o perform their required function.

1

31. Reactor Isolation Temperature Switches I 15 - 1 0 Qualified Equipment

'12 . Core Spray pumps NZ-01-A NZ-01-B NZ-01-C NZ-01-D Qualified Equipment

33. Containment Spray Pumps 1-1 1-2 1-3 1-4 The HELB that will adversely affect these pump motors is outside con-tainment. These pump motors are used to mitigate an accident inside con-tainment. Therefore, these motors will not see the harsh environment that they are required to mitigate.

i

Revision 1

..- m-

34. Containment Spray Dif ferential Pressure Transmitter IP-DSA*

11-053*

IP-05C*

I P-05 D

• The purpose of these-Differential Pressure transmitters is to detect tube leaks in the Coatainment Spray heat exchangers. These leaks might provide a potential leakage path to the environment of radi.> active ef flu-1 ent. This component does not provide any automatic function and only serves

, to provide an alarm in the control room. They will remain in an ambient 4

enviconment for the llKI.Il/ LOCA in containment in which this system will he-come of use. Also, it is not expected that the containment spray heat ex-changers tubes woulu leak, since they were retubed with titanium in the spring of 1980. This mater ial has proved to be highly resistant to cor-rosion in other similar opplications at Oyster Creek.

35. MSLV Solenoid Valves NS-04A-LL, L2, L3 NS-043-L1, L2, L3 Qualified Equipment MSIV Position Indicators j NS-04A-1 & 2 Outside NS-03A-1 & 2 Inside NS-04B-1 & 2 Containment NS-03 B-1 & 2 containment Position Indicators The MSIV position indication switches are utilized to proviile a scram signal when the MSIV's are less than 90% open. In the event the outside containment MSLV position switch did not provide a scram signal, two scram signals would still be available to ensure the reactor was shutdown Revision I

. ,e immediately for a main steam line break. One is the MSIV position switch signal from the inside valves and the other is the reactor high pressure and/or reactor low water level signal, both of which would not he af fected by the HELB that af fects the outside containment MSIV position switches.

36. Cleanup Valves V-16-2 V 14 V- 16-61 Qualified Equipment

37. Reactor Water Sample Valves V-24-30*

This valve is the outside containment isolation valve for the reactor coolant sample line. It is located in the area monitored by area temperature detectors. These detectors will warn the centrol room operator of leaks in the cleanup systems long before the pipes rupture. This will enable the operator to isolate the leak before the harsh environment is established. The redundant valve inside containment is environmentally qualified valve.

38. Shutdown Cooling Valves V-17-1*

V-17-2*

V-17-3*

V-17-55*

V-17-56*

V-17-57*

Qualified Equipment 4

R vision 1

39. Drywell Sump Discharge Valves V-22-l* .

V-22-2*

V-22-25*

V-22-29*

These valves are the containment isolation valves for the drywell equipment drain tank and sump. These valves do not see a harsh tempera-ture/ pressure environment for any postulated llELB's. A 1 Wb , it should be noted that these valves are not needed for isolation purposes for breaks outside containment. And if these valves should fail, they will fail closed which is the desired position.

40. Core Spray Valves V-20-15

- V-20-40 Qualified Equipment f e

41. PS-153. Deleted.

1 Disconnected in conjunction with plant modification #528-80-3 (SROC No. 81-16.1).

1

42. Core Spray Booster Pumps NZ-03 -A NZ-03-B NZ-03-C NZ-03-D i

,- , - - _ _ ~ _. - -. 4- m m---e '-

-er

Revision 1

. *=

Only two of these pump motors will be affected by a HELB. Even if one

' of these pumps should fail, the core spray system can still funct ion.

43. Core Spray Valves V-20-21 V-20-41 Qualified Equipment

44. Emergency Condenser Valves V-14-30 V-14-31 V-14-32 V-14-33 V-14-34 V-14-35 Qualified Equipment i

45. Emergency Condenser Makeup Valves V-11-34 V-11-36 These valves provide make up to the isolation condensers. With the minimum water level permitted by technical specifications the emergency 1

! condensers will be available to remove heat at their design capacity without uncovering the heat exchanger tubes for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 40 minutet with both conden-i sers available and 45 minutes if only one condenser is available.

i . -- -- - - -

Revision 1

. .=

The Emergency Condenser System is one of the methods available to control reactor pressure and cooldown the plant following a llELB. Since the emergency condenser line break is the break that causes the harsh environ-ment it is likely that one of the alternate cooldown methods would be util-ized.

In the area of the emergency condensers there are area temperature detectors that will detect Icaks in the emergency condenser system and an-nunciate this in the control room. By procedure the control room operator would isolate the af fected system before a rupture developed. There fore ,

the actual temperature / pressure environment would not reach the levels indi-cated in the worst case analysis. And these valves will most likely be usable if the isolation condenser system is available for use.

46. Reactor Water Level Switches and Reactor Water Level Switches / Transmitters RE-18-A RE-18-B l

RE-18-C RE-18-D l

l l

RE-05/19-A RE-05/19-B The RE-18 switches provide a low-low-low (triple low) signal to the automatic depressurization circuic. This signal could be necessary if there was a small break that required a rapid depressurization in order to permit core spray injection. The breaks that cause the harsh environment for i

1

Revision 1 these switches does not require the use of the Automatic Depressurization System. It should be noted that regardless of the condition of the RE-18 switches the electromatic relief valves can be manually operated by the control room operator if he desires to use them for blowdowm.

The RE-05 switches along with the RE-05/19 switches / transmitters pro-vide a reactor high pressure scram signal and control room water level in-dication. They are redundant and physically separated and adversely af-fected by two different HELB's. These HELB areas are monitored by area temperature detectors. These detectors will warn the control operator of leaks in those systems long before the pipes rupture. This will enable the operator to isolate the leak before the harsh environment is established.

47. Deleted

48. Limitorque Valve Actuators Inside Containment V-14-36, 37 V-17-19, 54 V-16-1 Qualified Equipment l

i l

49. Head Cooling System Isolation Valve l

V-31-2 The purpose of this valve is to provide reactor coolant boundary isol-ation. This valve is used if the head cooling system was needed to ensure that the Technical Specification limit of vessel flange to head temperature l

1 l

Revision 1 o en of 200 degrees F was not violated during normal plant cooldown. This valve is normally closed and fails closed of loss of air or power. Therefore, this valve should function properly in the event of an accident.

-50. Scram Discharge Valve Level Switches RD-08-A RD-08-B RD-08-C RD-08-D RD-08-E RD-08-F These switches provide for alarm, rod block and a reactor scram on a sensed high water level in the instrument scram discharge volume. These components are located in an area.that does not see a harsh temperature and pressure environment. Also the switches do not provide a primary safety function in the event of a HELB inside or outside ccntainment. They do serve to back up the signal which provides the reactor scram (hi drywell pressure or low water level). The only possible adverse ef fect that the failure of this switch might create is to allow a ' scram reset with a signi f-icant level of water in the instrument volume. This would require a delib-crate action by the Control Room operator in violation of station emergency procedures.

t *

. Revision 1 a

i REFERENCES

1. " Activation Energy for Fish Paper"

• Spaulding Fisher Company - Wyle Lab File No. 167-78

2. " Radiation Ef fect on Vulcanized Fiber" Spaulding Fi'oer Company - Wyle Lab File No. 200-79

3. " Radiation Effect on Engineering Material" IEIC Report, Bartell Memorial Institute, Manual No. 173

4. REIC Report No. 21. Table 1 Page 12 (for Nitrille Rubber)

5. " Activation Energy for Buna-N" by Trimble, L.E. and Cosgarea, A. Jr.

Wyle Lab File No. 169-78

6. Parker Seal Company Publication 12A on Buna-N dated November 26, 1975

7. Gilbert Associates, Inc, letter of June 4, 1980 Proposed 25% radiation damage does for various radiation sensitive materials.

8. NRC letter docket #50-320 with enclosed IE Bulletin #79-01B

9. Radiation Ef fects llandbook, Sponsored by the Radiation Technology Subcommittee of the IEEE Nucleonics Committee June 1963.

10. Radiation Effects on Organic Materials by Robert Bolt and James Carroll, Academic Press 1963

11. Study of the ef fects of Nuclear Research on the Mechanical Properties of Aceto 1, Resins, Delsin and Celcon.

by USAF Nuclear Aerospace Research Facility, March 31, 1964.

12. The Ef fect of Nucle'r Radiation on Elastomeric and Plastic Components and Materials.

Radiation Effects Information Center Report #21.

13. Engineering and Design 17 (1971) 247-280 Chapter Entitled "Use of Plastics and Elastomers in Nuclear Radiation" by W.W. Parkinson and O. Sisman, North Holland Publishing Company.

14. Letter for E. A. Lomatsch (ITT Barton Instrument) to Y. Nagai (JCP&L) dated September 10, 1980.

15. Letter from L. L. Blake, Jr. (ITT Barton Instrument) to Y. Nagai (JCP&L) dated August 19, 1980.

16. Letter from R. Farrell (ASCO) to Y. Nagai (JCP&L) dated October 22, 1980.

Revision 1, e *-

17. Letter from R. Matthews (ASCO) Y. Nagai (JCP&L) dated August 26, 1980.

18. Letter from R. King (Transamerica Delsval-Berksdale) to R. K.

Pruthi (GPU) dated August 21, 1980.

19. Letter from R. King (Transamerica Delaval-Berksdale) to R. K.

Pruthi (GPU) dated September 16, 1980.

20. Letter from M. Kosciak (Fenwall Inc.) to R. K. Pruthi (GPU) dated August 19 , 1980.

21. Letter from H. P. Hartman (Static-0-Ring) to R. K. Pruthi (GPU) dated September 2,1980.

22. Letter from C. W. Spear (Atkomatic Valve Co.) to R. K. Pruthi (GPU) dated September 23, 1980.

23. Letter from A. L. Gawrych (Mercoid Corp.) to R. K. Prothi dated August 20, 1980.

24. Letter from J. Woods (Magnetrol International) to E. T. Banua (JCP&L) dated September 16, 1980.

__ . . . _ - ,---