ML20070T323
| ML20070T323 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 02/01/1983 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Varga S Office of Nuclear Reactor Regulation |
| References | |
| TAC-42459, NUDOCS 8302080302 | |
| Download: ML20070T323 (23) | |
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Telephone (412) 393-6000 Nuclear Division P.O. Box 4 Shippingport, PA 15077-0004 February 1, 1983 Director of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Attn:
Mr. Steven A. Varga, Chief Operating Reactors Branch No.1 Division of Licensing Washington, DC 20555
Reference:
Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Response to 12/82 SER for Environmental Qualification of Safety-Related Electrical Equipment.
Centlemen:
We have reviewed the NRC's December 1982 Safety Evaluation Report (SER) for the Environmental Qualification of Safety-Related Electric Equipment. The SER examined safety-related electrical equipment that are potentially exposed to a harsh environment.
Based upon our review of each identified deficiency which could have an adverse impact on safety, we have determined that none of the identified deficiencies will impair the continued safe operation of the Station.
As directed by the SER, we are currently reviewing those elec-l trical equipment items that have been categorized I.B, II.A, or II.B by the NRC and will provide plans for any additional corrective actions that may be necessary within the next 60 days, as directed. Our review I
of the equipment identified by the NRC in these categories has in-j dicated that safe plant operation is not impaired. The justifications i
for continued operation that have been previously sent to the NRC remain I
valid, and additional justifications are provided (See Attachment A) l for equipment in Categories I.B, II.A, or II.B.
We are currently reviewing with our equipment supplier, the current status of their proprietary positions regarding certain man-ufacturer's documentations that apply to qualification. At this time, final conclusion of their positions has not been completed, however, we are continuing to seek reclassification of the manufac-turers information whenever possible.
J 8302080302 830201 e
PDR ADOCK 05000334 P
Braver Valley Power Station, Unit No.1 -
Docket No. 50-334, Licenze No. DPR-66 Response to 12/82 SER for Environmental Qualification of Safety-Related Electrical Page 2 If you have any questions concerning this response, please contact my office.
Very tru y yours,
. Carey Vice-President, Nuclear Attachment A:
Additional Justifications _ for Continued Operation ec:
Mr. W. M. Troskoski, Resident Inspector U. S. Nuclear Regulatory Commission Beaver Valley Power Station Shippingport, PA 15077 U. S. Regulatory Commission c/o Document Management Branch Washington, DC 20555 United States Nuclear Regulatory Commission Of fice of Inspection and Enforcement Division of Reactor Inspections Operation Washington, DC 20555 United States Nuclear Regulatory Commission (3)
Offfice of Inspection and Enforcement Attn:
R. C. Haynes, Regional Director Region I 631 Park Avenue King of Prussia, PA 19406 I
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9 COMMONWEALTH OF PENNSYLVANIA)
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COUNTY OF BEAVER
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On this
[Jf day of MLu W
/ f 8 3, before me, 4L/6 /MJ/$Z:M_4, a Notary Public in 6hd for said Commonwealth and County, personally appeared J. J. Carey, who being duly sworn, deposed, and said that (1) he is Vice President of Duquesne Light, (2) he is duly authorized to execute and file the foregoing Submittal on behalf of said Company, and (3) the statements set forth in the Submittal are true and correct to the best of his kncwledge, information and belief.
SHEllAM.FATTett,NetARf P900C SMiPPHIGPORT 3000, BEAutt COGNTV NY C05Gl3510N EIPttES SEPT.16,1905 tha+er, Peglvanie Asseostien of IIsteries 9
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ATTACHMENT A
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l JUSTIFICATION FOR CONTINUED OPERATION l
This section contains justification - for continued operation for equipment in Categories I.B, II.A, or II.B that Duquesne Light-Company has not provided justification for continued operation in 4
their previous submittals.
Duquesne Light Company continues to believe that this equipment is qualifiable and is pursuing the appropriate action to substantiate qualification with the appropriate documentation.
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INDEX OF EQUIPMENT JUSTIFICATIONS i
EQUIPMENT TYPE SECTION 4
PUMP MOTORS ------------------------- 1 MOTOR OPERATED VALVES --------------- 2 1
i CABLE ------------------------------- 3 s
ELECTRICAL PENETRATIONS ------------- 4 TERMINAL BLOCKS --------------------- 5 1
RHR EQUIPMENT ----------------------- 6 4
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FRANKLIN TAB #56 79-01B TAB #26 RS-P-1A, Inside Recirculation Spray Pump Motors RS-P-1B, Inside Recirculation Spray Pump Motcrs I
I.
SER Qualification Deficiencies 1.
Traceability between installed and test equipment i
2.
Aging degradation and qualified life / replacement schedule 3.
Temperature / pressure duration II.
Justification for Continued Operation 1.
The equivalency between the tested model (G.E.
- 5K6319XJ1B) and purchased model (G.E.
- 5K6319XJ20A) is-established.
j (Refer to Certificate of Conformance provided by G.
E, for Requisition No.
297-81938, Customer order number 1-11462 l
dated March 27, 1975).
2.
The lead splice and lead cable insulation may be susceptible to some thermal degradation, however, information on their material content is not available at the present time.
This will have to be determined at the next outage.
The data on hand indicates that the qualified life is justified based on previous testing of the stator and periodic replacement of the motor's lubricant.
The qualified life of the equipment's parts is currently being determined and the preventive maintenance replacement cycle schedule will be developed.
i 3.
An investigation of the motor's constituent parts has indicated that there is a high probability of the equipment operating for the post accident duration.
This i
investigation was based on a study of the parts aging j
phenomenon and the motor's ability to operate under simulated DBE conditions.
We have determined that the motors will be operating continuously for the first 30 days and on an intermittent basis i
for 1/3 the time for the remaining 5
months.
The total equivalent running time is expected to be 80 days in the 6 month l
interval post accident.
As pointed out above, our investigation j
of the equipment's test report and materials review, indicates that the motor should remain operable for this post DBA period.
In addition, the two fifty (50) percent design capacity, motor driven recirculation pumps that are located inside the containment are backed-up by two additional fifty (50) percent design capacity, motor driven recirculation spray pumps that are located ouside the containment.
The containment depressurization system is designed in such a way that the recirculation spray subsystems, together with the quench spray subsystems, are capable of reducing the containment pressure to subatmospheric in less than 60 minutes and remain atmospheric, thus terminating all outleakage to the environment under any combination of credible events.
h FRANKLIN TAB #64 i
79-01B TAB #48 1
CH-P-1A, Charging Pump Motors CH-P-1B, Charging Pump Motors i
CH-P-1C, Charging Pump Motors I.
SER Oualification Deficiencies 1.
Evidence of qualification of motor splice materials 2.
Lubricant-bearing-seal system 3.
Required time for continuous motor operation II.
Justification for Continued Operation 1.
Motor splice materials have been qualified for 40 years plus DBA.
2.
Investigation of the lubricant-bearing-seal system has demonstrated a high probability of operation for duration of a 6 month accident.
3.
A thermal aging analysis for continuous motor operation indicates that motor will operate for 40 years of normal operation plus 6 months of post DBA.
Multiple diverse core injection flow paths are provided by the Low Head, Outside Recirculation Spray and High Head Charging Pumps for providing adequate cooling core cooling following the depressurization of the reactor coolant system post LOCA conditions.
FRANKLIN TAB #63 79-01B TAB #47 SI-P-1A, L.H.S.I.
Pump Motors SI-P-1B, L.H.S.I.
Pump Motors i
I.
SER Qualification Deficiencies 1.
Evidence of qualification of motor splice materials 2.
Lubricant-bearing-seal system 3.
Required time for continuous motor operation II.
Justification for Continued Operation 1.
Motor splice materials have now been qualified for 40 years plus post DBA.
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2.
Investigation of lubricant-bearing-seal system has demonstrated a high probability of operation for duration of a 6 month accident.
3.
A thermal aging analysis for continuous motor operation assures motor will operate for 40 years of normal operation plus 6 months of post DBA.
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Beaver Valley Unit has the capability to cross-tie the Outside Recirculation Spray Pumps to the High Head Charging Pumps which provides additional redundancy for assuring long term integrity of the recirculation flowpath, b
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SECTION 2
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FRANKLIN TAB #3 79-01B TAB #25 MOV-RC-535, P.O.R.V.
Block Valves MOV-RC-536, P.O.R.V.
Block Valves MOV-RC-537, P.O.R.V.
Block Valves I.
SER Oualification Deficiencies 1)
Unable to establish similarity between test document and installed equipment.
2)
It has not been identified if a motor-brake is used.
3)
No aging analysis supplied.
4)
Required operating time insufficient.
II.
Justification for Continued Operation The referenced MOV's safety function is to isolate the P.O.R.V.
in the event of a P.O.R.V.
failing in the open position.
Twc-concurrent failures are not postulated of the P.O.R.V.
& Block Valve.
If the P.O.R.V has failed, the additional failure of the block valve is not considered credible.
The failure of both valves would involve simultaneous random failures and these are excluded from study. Overpressure protection is assured by the pressurizer safety relief valve.
There have been numerous tests performed on motor operated valves and the problem exists only in tying the test report to the equipment.
The tests have demonstrated the ability of MOVs to function during simulated accident conditions.
If the valves are in the automatic mode of operation, additional protection is provided, because the pressurizer P.O.R.V.'s are automatically closed if reactor coolant system pressure decreases below 2000 psig.
FRANKLIN TAB #12 79-01B TAB #45 MOV-SI-836, Cold Leg Injection Header Isolation MOV-SI-867C, B.I.T.
Outlet Isolation MOV-SI-867D, B.I.T.
Outlet Isolation MOV-SI-869A, Hot Leg Injection Header Isolation MOV-SI-869B, Hot Leg Injection Header Isolation I.
SER Qualification Deficiencies 1.
Unable to establish similarity between test document and installed equipment.
2.
It has not been identified if a motor-brake is used.
3.
No aging analysis supplied.
4.
Required operating time insufficient.
II.
Justification for Continued Operation Similar MOVs have demonstrated operability during simulated accident conditions that are more severe than'the-Beaver Valley Power Station Unit 1 service condition and are documented in test-l reports.
The five MOVs isolate the parallel H.H.S.I.
Flow Paths from the RCS.
All valves are in the pipe tunnel and are normally closed during power operation. For LOCA, the only harsh stress mechanism is radiation.
The existence of' parallel flow paths assure accomplishment of safety injection in.the event of a single.
i failure.
Failure of all redundant flow path valves is not' credible because of the numerous diverse injection flow paths j
that are available upon receipt of a safety injection signal.
FRANKLIN TAB #15 79-01B TAB #45 MOV-SI-860A, Sump Suction to L.H.S.I.
MOV-SI-860B, Sump Suction to L.H.S.I.
MOV-SI-862A, L.H.SI. Suction from R.W.S.T.
MOV-SI-862B, L.H.SI. Suction from R.W.S.T.
I.
SER Qualification Deficiencies 1.
Unable to establish similarity between test document and installed equipment.
2.
It has not been identified if a motor-brake is used.
3.
No Aging Analysis applied.
4.
Required operating time insufficient.
II.
Justification for Continued Operation The four MOVs are in the suction lines to L.H.S.I.
pump A &
B.
They are located in the safeguard area, and will experience only an increase in radiation during a LOCA.
It is not postulated for the four valves to fail simultaneously.
In addition, a parallel flow path is available.
These valves are positioned automatically on a safety injection system very early in a LOCA in coincidence with a low level signal from the R.W.S.T.
level transmitters, therefore they attain their safety-related position prior to receiving significant radiation exposure.
The published test reports on this type of MOV has demonstrated its ability to operate during simulated accident conditions which are more severe than the service conditions the equipment is exposed to at Beaver Valley Power Station Unit 1.
FRANKLIN TAB #10 79-01B TAB #45 MOV-CH-289, Isolate Normal Charging Path MOV-CH-381, R.C.P.
Seal Water Containment Isolation I.
SER Qualification Deficiencies 1.
Unable to - establish similarity between test document and installed equipment.
2.
It has not been identified if a motor-brake is used.
3.
No aging analysis supplied.
4.
Required operating time insufficient.
II.
Justification for Continued Operation Currently the traceability between the, installed equipment and the published test reports are being established.
Both MOVs are located exterior to the containment and Are used for containment isolation.
The valves are placed in their accident position upon receipt of a safety injection signal and, therefore, would be closed prior to the more severe environmental conditions in containment during LOCA.
For these valves, the only stress mechanism is radiation due to its location outside containment, and radiation is not expected to decrease the valves' operability.
FRANKLIN TAB #4 79-01B TAB #25 MOV-CH-378, R.C.P.
Seal Water Isolation I.
SER Qualification Deficiencies 1)
Unable to establish similarity between test document and installed equipment, l
2)
It has not been identified if a motor-brake is used.
3)
No aging analysis supplied.
4)
Required operating time insufficient.
II.
Justification for Continued Operation This type of MOV has demonstrated the ability to function during simulated accident conditions that are more severe than those expected at Beaver Valley Power Station Unit 1, and document in a test report.
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The referenced MOV is utilized for containment isolation of the scal water return for the RCPs.
Should MOV-CH-378 fail to operate upon receipt of a containment isolation signal, isolation would be effectively accomplished utilizing MOV-CH-381.
The valve is placed in its accident position upon receipt of a safety injection signal and therefore would be closed prior to the more severe environmental conditions in containment post
'OCA.
FRANKLIN TAB #86 79-01B TAB #43 MOV-FW-151B Auxiliary Feedwater Pump Discharge Throttle Valve I.
SER-Qualification Deficiencies 1.
Unable to establish similarity between test document and installed equipment.
2.
It has not been identified if a motor-brake is used.
3.
No aging analysis supplied.
II.
Justification for Continued Operation The MOV is normally open and located in the Auxilary Feedwater Pump Room.
During an accident condition that would require this MOV to function, the valve, because of its location does not experience the severe environmental conditions of the accident.
Similar MOVs have functioned under severe simulated accident conditions for worse service conditions than those occurring at Beaver Valley Power Station Unit 1.
Should this valve fail to throttle properly, shutdown of the pump could be used to prevent overfill of the steam generator until a fixed throttle position could be manually set on the valve.
FRANKLIN TAB #1 79-01B TAB #24 VS-D-5-3B,5B Containment Purge Containment Isolation Valves 4
I.
SER Qualification Deficiencies 1.
Traceability between tested and installed equipment.
2.
Required operating time.
3.
Qualified life of motor as a whole and not just the stator.
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II.
Justification for Continued Operation DLC continues to consider these items exempt for the following reasons:
VS-D-5-3B,5B are the containment purge exhaust and supply isolation valves inside containment.
Redundant isolation valves VS-D-5-3A, 5A are located outside containment.
These valves are normally closed and are opened during Modes 5 & 6.
They are not required to operate to mitigate either LOCA or a MSLB.
These valves are administratively controlled in accordance with Technical Specifications.
i Redundant isolation valves located outside containment are not subject to a LOCA or a MSLB and are opened only during Modes 5 &
6 thus ensuring containment isolation at all times.
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FRANKLIN TAB #69 a
79-01B TAB #2 1000 Volt Cerro Wire Power Cable I.
SER Qualification Deficiencies 1.
Traceability II.
Justification for Continued Operation The traceability of the cable tested to cable installed has been established by a letter from the manufacturer linking test specimens to the cable purchased.
FRANKLIN TAB #73 79-01B TAB #33 SIS Cable G.E. Vulkene Supreme #57279 I.
SER Oualification Deficiencies 1.
Traceability II.
Justification for Continued Operation The traceability of the cable tested to the cable installed has been established and the qualified life has now been i
established.
(Ref: Vendor Document-WCD-830).
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- FRANKLIN TAB #75 79-01B TAB #6 Viking Electrical Penetrations I.
SER Qualification Deficiencies 1.
Aging degradation not evaluated 2.
Qualified life and replacement schedule not established 3.
Radiation criteria not satisfied II.
Justification for Interim Operation Thermal aging analysis was conducted on the available elastomeric degradable parts such as "0" ring, gasket, insulator, and potting compound.
Based on this analysis (Ref: Thermal Aging Analysis on Electrical Cable Penetrations, Technical Report), a qualified life greater than plant life has been established for these materials.
The analysis on these materials indicates-that the required 40 years plus DBE duration qualification time is enveloped.
The radiation analysis that has been performed, based on radiation threshold values, has demonstrated that no significant degradation of the penetration materials is expected to occur.
DLC is in the process of finalizing a retesting program on these-penetrations at a higher radiation dosage level to affirm the foregoing discussion.
A detailed schedule will be provided in the 90-day zesponse.
Based on this information, DLC believes the penetrations are qualified, therefore, continued operation is justified.
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FRANKLIN TAB #80 79-OlB TAB #8 PENN UNION TERMINAL BLOCKS I.
SER Qualification Deficiencies 1.
Traceability of the number of terminal points between tested and installed equipment 2.
Steam exposure II.
Justification for Continued Operation Duquesne Light Test Report dated March 25, 1982, on the Penn Union Series 1000 terminal blocks that were tested to D.B.A.
conditions indicated that no distortions or visual damages had occurred.
The Penn Union terminal blocks tested were the 4 point and 8 point units.
As result of BVPS
- 1 plant walkdown and a review of plant
- drawings, no Penn Union 12 point terminal blocks have been identified in the plant.
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- FRANKLIN TAB # 6,7,8,9,60 79-01B TAB #28 RESPONSE TO SER QUALIFICATION DEFICIENCIES ITEf t :
RHR System Components:
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FRC TAB #
EQUIPMENT MARK #
EQUIPMENT TYPE MANUFACTURER 6
MOV-CC-112 (SMB Series)
Motor Open, tors Limitorque 7
MOV-RH-605 and RH-758 Motor Operators Limitorque 8
MOV-RH-720A, B Motor Operators Limitorque
,9 RH-P-1A, 1B Pump Motors Westinghouse 60 MOV-RH-700 and RH-701 Motor Operators Limitorque With the issuance of supplement 3 of IEB 79-01B, the NRC has determined the review of environmental qualification for all equipment required to achieve and maintain the plant in a cold shutdown condition, is not within the scope of this report.
The equipment uced in the Residual Heat Removal system can be classified under this category.
Beaver Valley Unit 1 is licensed for a Hot Standby basis and is not required to have a Class IE qualified path to cold shutdown.
For this reason, the equipment listed for the_ RHR system is considered to be exempt from qualification.
The Recent NRC Rulemaking has continued to defer cold shutdown equipment from qualification consideration.