ML20083P664
| ML20083P664 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 01/26/1983 |
| From: | Burstein S WISCONSIN ELECTRIC POWER CO. |
| To: | Clark R, Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0588, RTR-NUREG-588 NUDOCS 8302030566 | |
| Download: ML20083P664 (7) | |
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I%SC00 Sin Electnc eom come 231 W. MICHIGAN, P.O. BOX 2046, MILWAUKEE, WI 53201 January 26, 1983 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. NUCLEAR REGULATORY COMMISSION Washington, D.C.
20555 Attention: Mr. Robert A. Clark, Chief Operating Reactors Branch 3 Gentlemen:
DOCKET NOS. 50-266 AND 50-301 ENVIRONMENTAL QUALIFICATION OF SAFETY-RELATED ELECTRICAL EQUIPMENT POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 On December 22, 1982, Mr. Clark transmitted to Wisconsin Electric the new Safety Evaluation Reports (SERs) for the Environmental Qualification of Safety-Related Electrical Equipment at Point Beach Nuclear Plant, Units 1 and 2.
You requested reaffirmation of the justification for continued operation for those equipment items (NRC Category I.8, " Equipment Qualification Pending Modifi-cations," in the SERs) identified by us as deficient because they lacked environ-mental qualification documentation meeting the provisions of the 00R Guidelines or NUREG-0588.
A majority of that equipment has already been replaced with new equipment environmentally qualified or being qualified to the provisions of NUREG-0588, Category I (i.e., IEEE Standard 323-1974).
The justification for continued operation for the remaining equipment items in NRC Category I.B were provided to you in Mr. C. W. Fay's letter dated October 8,1981 regarding
" Supplemental Response to Safety Evaluation Report for Environmental Qualification of Safety-Related Equipment." These justifications for continued operation are still applicable. We are continuing our efforts to complete the environmental qualification of the remaining equipment items by the deadline imposed by the new rule 10 CFR 50.49, " Environmental Qualification of Electric Equipment Important to Safety in Nuclear Power Plants."
joy 8 8302030566 830126 PDR ADOCK 05000266 P
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Mr. Harold R. Denton January 26, 1983 The SERs also identified several additional equipment items (NRC Category II. A, " Equipment Qualification Not Established") for which your evalua-tion judged the environmental qualification documentation to be incomplete. We have reviewed these evaluations and believe the previous documentation can be supplemented to establish qualification without modification of the equipment.
The attachment to this letter establishes the justification for continued oper-ation for each equipment item in NRC Category II.A until the documentation deficiencies can be resolved with your Staff.
No equipment items at PBNP were identified in NRC Category II.B, " Equipment Not Qualified." Therefore, we believe that Point Beach Nuclear Plant, Units 1 and 2, can continue to operate without undue risk to the public health and safety.
This letter is affirmed in accordance with the provisions of 10 CFR 50.54(f).
We would be pleased to respond to any questions you may have in this matter.
Very truly yours, n
d Sol Burstein Executive Vice President Attachment Subscribed and sworn to be ore thi 5y of J 19 fury t)6tary Publi, S ate of Wisconsin My commission
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NRC Resident Inspector y_
JUSTIFICATION FOR CONTINUED OPERATION EQUIPMENT ITEMS IN NRC QUALIFICATION CATEGORY II.A POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 SER Item PBNP Equipment No.
Unit Description Justification for Continued Operation 24 1.&2 Safety Injection An analysis in the equipment qualification Pump Motors file justifies an in plant service life of (Westinghouse forty years as explained in Note T of our Thermalastic Epoxy October 11, 1981 response.
The motor-to-Class B Insulation) lead splices are constructed with Scotch #70 silicon rubber tape which was staisfactorily testegforthermalaging, radiation (2x10 Rads gamma), and steam exposure in WCAP 7829.
FRC Report F-C3699 documents the qualification of a similar silicon rubber insulation material used on instrumentation cable.
The bearing /
lubricant system consists of shielded (sealed) anti-friction ball bearings with a petroleum-based, lithium-soap-thickened grease.
The bearing system is inspected yearly with additional tests of the motors also conducted periodically.
This type of lubricant has been tested satisfactorily for inpegratedradiationdosesinexcessof 10 Rads gamma which exceeds the require-ment for these motors.
The aging of the bearing / lubricant system is addressed by satisfactory service of over 12 years at PBNP as well as tests documented in WCAP 7829.
This meets the aging requirements of the 00R Guidelines as clarified by the NRC Generic Letter 82-09, Item 9.
Therefore, these motors are considered qualified to the provisions of the 00R Guidelines.
Additional documentation will be provided at a later date.
25 1&2 Containment Spray See response to Item 24.
Pump Motors (Westinghouse Premium 4
Moisture Resistant Class B Insulation) 26 1&2 Component Cooling See response to Item 24.
Pump Motors (Westinghouse Premium Moisture Resistant Class B Insulation).
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SER Item PBNP Equipment No.
Unit Description Justification for Continued Operation 27 1&2 Residual Heat See response to Item 24 Removal Pump Motors (Westinghouse Thema-lastic Epoxy Class B Insulation).
28 1&2 Containment Emer-An aging analysis was performed which gency Fan Motors justifies an in plant service life (Westinghouse of forty years based on the qualifica-Thermalastic Epoxy tion tests documented in WCAPs 7829 Class F (Class A and 8754.
The motor-to-lead splice and Temp. Rise) Insula-bearing / lubricant system qualification tion).
are addressed in items 29 and 53, respec-tively.
These motors are considered quali-fied to the provisions of the D0R Guidelines.
29 1&2 Motor-to-Lead These splices were remade several years Splices for Item ago at PBNP to conform to the splices 28 tested and qualified by WCAP 7829. Wes-tinghouse Drawing No. 206C391 is the basis for this splice.
Separate effects tests for radiation and steam exposure were also conducted satisfactorily on the individual splice materials.
Therefore, the splice is considered qualified to the D0R Guide-lines.
42 1&2 Okonite Instru-Documentation on our purchase orders estab-mentation Cable lish that the cable tested in FRC Test Report F-C3694 (Group II cables, Item 4A) is similar to our cable.
The differences were analyzed and determined to have no effect on the qualification status of these cables.
Our cables have a PVC jacket in lieu of an overall glass braid.
The insula-tion material is identical as confirmed by a telephone conversation with Dr. Jack Lasky of Okonite Company.
Therefore, this cable is considered qualified to the D0R Guide-lines.
50 1&2 Safety Injection Several references in our qualification Pump Bearing file document the radiation testing of Lubricant (Ameri-commercial grade oils and greases.
None can Industrial of these documents demonstrates signifi-35 Oil) cant degradation of any oil or grease 9t radiation doses below approximately 10 Rads. This oil has been used successfully at PBNP for approximately 12 years.
The -
SER Item PBNP Equipment No.
Unit Description Justification for Continued Operation oil is replaced and the bearing checked at one year intervals.
Therefore, the bearing system using this oil has an extremely high probability of operating satisfactorily under accident conditigns for which gamma radiation up to about 5x10 Rads is the only harsh environmental parameter.
The normal humidity and temperature are not expected to change appreciably during accident conditions.
Therefore, the continued safe operation of PBNP is justified until additional quali-fication documentation can be provided.
51 1&2 Component Cooling See response to Item 50.
Pump Bearing Lubri-cant (American Industrial 21 Oil).
52 1&2 Containment Spray See response to Item 50.
and RHR Pump Bear-ing Lubricant (American Rykon Industrial 15 Oil) 53 1&2 Containment Emer-This grease was tested for irradiation gency Fan Cooler and " working" to simulate the conditions Bearing Lubricant in containment following a design-basis (Chevron BRB 2 LOCA as documented in the PBNP FSAR, Grease)
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The results show that the greasewasstif1suitableafterirradia-tion to 1.8x10 Rads gamma.
A similar Westinghouse grease was tested in the qualification tests documented by WCAP 7829.
Therefore, it is concluded that the grease will perform its safety function satisfac-torily until additional documentation on its qualification can be provided.
Therefore, the continued safe operation of PBNP is justified until the item is resolved.
54 1&2 Limitorgue Valve The grease is a petroleum-base, lithium-Motor Operator soap-thickener grease with extreme pressure Lubricant (Amolith (EP) additives.
A number of similar greases
- 1EP) were r9 ation tested satisfactorily to di 2.7x10 Rads and higher as documented in an ASLE paper.
The greases are checked annually and have shown excellent service in over twelve years of operation at PBNP.
Similar greases have been used in numerous qualifi-cation tests of Limitorque operators under LOCA and SLBA conditions.
Therefore, con-tinued safe operation of PBNP is assured until additional documentation is generated regarding similarity and aging.
55 1&2 Pump Motor See response to Item 24 regarding bearing /
Bearing Lubricant lubricant system.
(Amolith #2) 56 1&2 Limitorque Valve Mobil 28 grease is a synthetic lubricant Operator Geared which has been radiation tested satisfac-g Limit Switch torily to 3x10 Rads mixed gamma / neutron Assembly Lubricant radiation and tested satisfactorily in (Mobil Model #28) bearings at temperatures of 580*F.
The grease is checked annually to ensure satis-factory service.
Therefore, since radia-tion and high temperature are the only adverse environmental conditions encountered by the grease under postulated accident conditions, the continued safe operation of PBNP is assured until additional qualifi-cation documentation can be provided.
61 1&2 Power Operated This item is not required to mitigate a LOCA Relief Valve or HELB accident and is not considered Blocking Valve safety-related.
Therefore, lack of quali-Limitorque Motor fication documentation does not affect Operators (Peer-plant safety.
Less Motor with Class B insulation).
62 1&2 Safety Injection These valves are administratively main-Line Valve tained in this required position for safety Limitorque Motor injection and are therefore, not normally Operators (Peerless required to operate on receipt of a safety Motor with Class B injection signal.
These valves may be insulation) opened within 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> of a small-break LOCA to aid in coolant mixing to prevent boron precipitation.
As discussed in Mr. Sol Bursteins' letter to your staff dated May 7,1975 regarding "ECCS Long Term Cooling," boron precipitation is not a problem at PBNP even if these valves failed to open within 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> of a LOCA.
There-fore, PBNP can continue to operate safely until this item is resolved.
63 1&2 Safety Injection These valves are administratively main-Line Valve tained open during normal operation which Limitorque Motor is their required position upon receipt Operators (Reli-of a safety injection signal.
If these ance Motors with valves were initially closed, they would Class B insulation) open immediately upon receipt of a safety,-
injection signal.
Their required operating time should be 1/2 hour and not 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> as stated on the SCEWs.
Similar valve operators operated satisfactorily for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> in simulated LOCA conditions as documented in WCAP 7410L.
Therefore, PBNP can continue to operate safely until this item is resolved.
65 1&2 Auxiliary Feedwater Limitorque has confirmed that the valve Pump Steam Supply motor operators at PBNP are identical Valve Limitorque to those tested in Limitorque Test Operators (Peerless Report No. B0003 except for the Peerless Motor with Class B motors.
The Peerless motors were tested Insulation) as documented in WCAP 7410-L.
Since the temperature / pressure profile used for qualification of these valves is extremely conservative, the operators are judged to be able to perform their safety function based on a combination of the two test reports.
Since these valves are located in an area normally caintained between 65 F and 85 F and based on their satisfac-tory service for over 12 years at PBNP, no significant thermal aging degradation has occurred up to this point.
Therefore, the continued safe operation of PBNP is assured until this item is resolved..___. _
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