ML20086M184
| ML20086M184 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/10/1984 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | Stolz J Office of Nuclear Reactor Regulation |
| References | |
| 5211-84-2038, NUDOCS 8402160395 | |
| Download: ML20086M184 (12) | |
Text
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GPU Nuclear Corporation J Nuclear
= n g s s 48o s
Middletown, Pennsylvania 17057 717 944-7621 TELEX 84-2386 Writers Direct Dial Number:
February 10, 1984 5211-84-2038 Office of Nuclear Reactor Regulation Attn:
J. F. Stolz, Chief Operating Reactors Branch #4 Division of Licensing U. S. I'Jclear Regulatory Commission Washington, D. C. 20555
Dear Sir:
Three Mile Island Nuclear Station, Unit 1 (TM1-1)
Operating License No. OPR-50 Docket No. 50-289 Environmental Qualification of Electrical Equipment On October 5, 1983 representatives of GPUN and NRC met to discuss outstanding items of the PRC SER/TER dated December 10, 1982 on the subject. By letter dated October 17, 1983 GPUN committed to provide a resolution of each item and a justification for continued operation (JCO) for those items not com-pleted. Attachment I provides a tabular listing of the deficiencies by component from Table 4-1 of the TER (Technical Evaluation Report) for PRC categories I.B, II.A, and II.B.
Attachment II provides the resolution of each item of Attachment I and each item of NRC Categories II.C and IV of Table 4-1.
Based on these resolutions, no additional justification for continued operation is required. It is GPUN's position that TMI-l is currently in compliance with the Environmental Qualification Rule 10CFR 50.49 as applicable to TMI-1.
' ~
- Sincerely, 8402160395 840210 h
. Hukill P
Vice President - TMI-l cc:
J. Van Vliet R. Conte q
Attachment I EQUIPMENT QUALIFICATION DEFICIENCIES (Categories I.B. II.A and II.B) i TER Deficiencies
_f, Equipment Description 1 2 3 4 5 6 7A 7B 7C 7D 7E 8 9 10 11 12 13 14 15 16 1
Limitorque PNA SMB xxx Motor valve op.
2 Limitorque MVA. SMB2 xxxx 3
'Limitorque MVA SMB3 xxx 6
Limitorque MVA SMB000 xxx 7
Limitorque MYO SM8000 xxxx 10 Limitorque MVA SBJ xxxx x
11 Limitorque MVA SMBO xxxx x
14 Limitorque MVA SMB00 xxxx x
15 Limitorque MVA SMB000 xxxx x
26 ASCO Sol. Val LB8210C94 x
Solenoid valve 28 ASCO Sol. Val 8300C68G xx 29 ASCO Sol. Val 8300C68G xx 32 ASCO Sol. Val LB83146 xx 45 Westinghouse Frame 182T xxx x
Motor 46 Westinghouse HP700 xxx x
49 Westinghouse HP250 xxx x
50 Westinghouse HP350 xxx x
51 Westinghouse HP450 xxx x x x x x x 53 Victcreen x
Display Rad monitor 57 Static "0" Ring xx x
x x x x Press switch 60 Bailey RP1211C x
F/P Transd.
66 NAMCO D2400X x
Lmt. switch 67 NAMCO D1200G2 x
xx 71 Fisher Gov. 304 x
78 Foxboro E11GH2 xx x trans x
79 Foxboro E11AM x
x 81 Foxboro E11GMSAEl xx x
x 93 Foxboro E13DMK x
98 GEMS LS800 x
Level switch 106 Kerite cable x
' 107 Continental wire x
108 Raychem cable splice x
109 GE penetration F01 xx xx 111 1GE terminal block EB25 x
114 Conax connector SA1000 xx
- 115 Conax connector PL14B2-xx 116 GE Thyrector CR2095100DJA x
118 timitorque MVA SMB000 xxxx 119 Limitorque MVA SMB000 xxx 120 Limitorque MVA SMB000 xxxx e
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s QUALIFICATION DEFICIENCIES
SUMMARY
- CATEGORIES IB, IIA, IIB Total # of NRC requirement Deficiencies NRC Requirement Deficiencies Deficiencies =120 1
Documentation 20 7E steam exposure 2
2 Similarity 30 8 spray 1
3 Aging evaluation 24 9 submergence 0
4 Qualified life 21 10 radiation 1
5 Aging program 0
11 test sequence 2
6 Aging simulation 5
12 test failure 0
7A Peak temperature 5
13 function test 0
7B Peak pressure 2
14 instrument accuracy 0 7C Duration 2
15 duration margin 2
7D Profilo envelope 3
16 margins 0
--e--
4-
Attachment II Equipment Qualification Deficiencies / Resolution (Categories 1.8, 11.A, and II.8) 1.
Specific A. Limitorque Motor Ooerators o When necessary GPUN has performed a plant walkdown of Limitorque motor for model and serial number (for those required for hot shutdown).
o GPUN has qualified in containment Limitorque operators required to be qualified for hot shutdown for high temperature / radiation including limit switches, brakes, motors, and lubrication.
o GPUN central file contains all correspondence and test reports required to document qualification.
o SCEW sheets will be revised to reflect additional information in the update schedule for submittal in the fall of 1984.
- 1. TER Items 1, 3, 418-120 [WDG V-3; DHV-l&2; CAV-13; MUV-2; WDLV-303).
Limitorque models SMB/SMB-3, SMB-000/SMB-00 are shown to be similar to models tested / age analyzed / qualified life in Limitorque Generic Report B0058 Section 4.1.4.
- 2. TER Item 2 [AHV-1]
Limitorque model SMB-2 is shown to be similar to models tested / age analyzed / qualified life in Limitorque Generic Report B"058 Section 3
4.1.4 Ding motor brake model 6 '71010-6 is qualified by similarity to model 5-63009-50 which was tested as described in test report 600198 (F-62232-01). Both models are constructed of similar materials and rate for approximately the same torques but differ only in size.
- 3. TER Items 6&7 [CFV-2&3; CAV-1, 2, 3 &4; ICV-2]
Limitorque model SMB-000 is shown to be similar to models tested / age analyzed / qualified life in Limitorque generic report B0058.
CFV-2&3 which are required to function in a LOCA are located in the Intermediate Bldg. (mild environment for LOCA) and are qualified for a harsh environment.
These CF valves will be therefore deleted from the Master List.
l m
. 4. TER Items 10, 11, 14 & 15 [FWV-5; EFV-2; FWV-92; & EFV-1]
Limitorque models SB-3/SM3-0/SMB-00/SMB-000 are shown to be similar to models tested / age analyzed / qualified life in Limitorque generic report B0058. Limitorque has developed a thermal lag analysis which shows that the operator will operate through the Intermediate B2dg. MSLB temperature spike of 3260F.
B. ASCO Solenoid Valves o There are no ASCO solenoid valves required to be qualified inside containment.
o GPUN central file contains all correspondence and test reports required to document qualification.
o SCEW sheets will be revised to reflect additional information in the update scheduled for subniittal in the fall of 1984.
As described in GPUN letter 'ated August 2, 1982 (82-183) GPUN has!
J removed the EFW 1atch signal from the EFW control valves. There-fore this solenoid is no longer required to be qualified and was deleted from the Master List but the SCEWS were not removed.
This
- will be accomplished in the fall 1984 update.
- 2. TER Items' 26,27,29&32ffWV-17B(SV364);FWV-16B(SV3&4);FWV-16B; (SV 1&2) MSV-137 ASCO solenoids will be replaced with qualified ASCO solenoids by
. June 1984.
Therefore, ASCO qualification test reports AQR67368 and AQS21678/TR apply.
C. Westinchouse Motors
- 1. TER Items 45, 46, 49, 50 & 51 [MUP-4; MJP-1; BSP-1; DFP-1, EFP-2]
- a. Motorettes (stators) testing included silicon rubber insulated lead wires. Aging analysis on the assembly showed a 40 years life expectancy.
- b. Bearing Analysis showed that the bearings could withstand a LOCA/HELB (ref. GPUN calculation 1101X-5350-000 and GPUN memo R.
Spragg' to D. Slear dated 5/14/81).
- c. Motor Lubrication (Exxon Terisstic 32) is controlled within the preventive maintenance program and is rated by Exxou at a radia-tion level of 108 rads with a flash point of 4100F, (This lubricant is not used on MUP-4 which has sealed bearings.)
. d. Qualification of lead splices is controlled within the correc-tive maintenance program by G'UN procedure 1420-Y-15.
EFP-2 was analyzed in Westinghouse Report dated 1/81 for motor insulation life analysis which envelopes the thermal lag peak for the Intermediate Bldg. of 3260F.
Similarity for the above listed motors is established by Westinghouse report WCAP 8754 Rev.1 Section 2.
D. Victoreen Radiation Monitors
- 1. TER Item 53 [RM-A2; A5, A6]
These radiation monitors (RM-A2, 5&6) are indicators of LOCA and are located outside containment (subject to a mild environment).
They are not required for a main steam line or feedwater line break. These SCEW sheets will be deleted.
E. Static 0 Ring Pressure Switch
- 1. TER Item 57 [FW Iso. Press Switch (600-607)]
These switches will be replaced prior to June 1984 by a qualified pressure switch. No justification for continued operation is required since the plant will not go critical prior to restart and therefore no nuclear heat will be generated.
F. Bailey E/P Convertors
- 1. TER Item 60 [MSV-4]
The ADV's are not required for Licensed (hot) shutdown and are therefore not required to be qualified. Pressure control is maintained in hot shutdown via the MS safety valves.
G. NAMCO Limit Switches
- 1. TER Item 66 & 67 [MSV-6; MSV-13]
Under LOCA and MSLB sufficient flow is provided to the OTSG's by a single motor driven EFW pump.
(See GPUN letter dated 3/22/83).
The steam driven EFW pump is only required for station blackout which does not produce a harsh environment. Failure of the limit switch (MSV-6) with MSV-6 open may result in initially overfeeding the OTSG's which could be reduced immediately (manually) based on qualified EFW flow and OTSG level instrumentation.
Therefore the EFW system will function and the operator will not be misled.
Failure of the limit switch (MSV-13) results in the inability to monitor valve position and may result in lifting reliefs but
. l because of qualified EFW flow and OTSG level this will not mislead the operator. These switches will be deleted from the Master List.
H. Fisher Limit Switch
- 1. TER Item 71 [MSV-4]
The valve position indication for the atmospheric dump valves will be deleted from the Master List (see discussion of item F).
I. F_oxboro Transmitters
GPUN possesses original purchase orders which are part of the QA file which refers back to a plant tag number or vendor letters which are part of the EQ file. GPUN calculations were based on a B&W evaluation of Class lE In Containment Controls and Instrumen-tation (77-11207001-00) dated 7/81, which is part of GPUN central file.
The Ell series transmitters were purchased prior to 1974 and were qualified by D0R Guidelines which do not require sequence testing.
The time duration listed in the SCEWS indicates qualification for 86 hours9.953704e-4 days <br />0.0239 hours <br />1.421958e-4 weeks <br />3.2723e-5 months <br /> which exceeds the 29 hours3.356481e-4 days <br />0.00806 hours <br />4.794974e-5 weeks <br />1.10345e-5 months <br /> (104 sec.) of the profile (Items 78 & 81). Item 79 is. located in the Aux. Bldg. and is not subject to as severe an environment.
- 2. TER item 93 [RB EC Flow]
The utility report (Wyle 45592-4/Model E13 DW ) on Foxboro trans-mitters documents the qualification of this transmitter.
J. GEMS Limit Switch
- 1. TER Item 98 [WDL LS-ll6]
The Reactor Building Sump Level instrument has been upgraded in accordance with NUREG 0737 Item II.F.1 and qualification will be documented in a revision to the SCEW sheets in fall 1984. Conse-quently, the limit switch.of item 98 will be deleted.
II.
Generic A. Kerite Cable
- 1. TER Item 106 GPUN has in central file the original Bill of Materials which documents the applicable test report for the Kerite cable.
. B. Continental Cable
- 1. TER Item 107 GPUN has in central file a letter from the vendor which establishes similarity between the cable tested and that installed at TMI-1.
The lots are traceable through purchase orders which are part of our QA files.
C. Ray Chem Cable Splice
- 1. TER Item 108 GPUN has reviewed the applicable Ray Chem Test Reports and deter-mined that it is applicable to the splices at TMI-l because the material composition is the same for all Raychem splices.
D. GE Penetration
- 1. TER Item 109 GPUN had reevaluated the penetrations installed at TMI-1 and have determined that they are all above flood level; and that the hyperlon paint is immune to caustic spray. GPUN has also performed an aging analysis on the penetrations.
E. GE Terminal Blocks (EB-25)
The SCEW sheets will be revised to reflect this change.
F. Conax Connectors
- 1. TER Item 114 & 115 GPUN has reviewed the Conax Connectors and determined that they are pressure seal modules described in PL-14-BL and IPS 409 and 325.
G. GE Thyrectors
- 1. TER Item 116-The GE Thyrectors have been replaced by General Semi Conductsr Bi Polar Transient Voltage Suppressors (Square D) (which are quali-fled). A new SCEW sheet will be sent in our fall 1984 submittal.
L
. Equipment Qualification Deficiencies / Resolution (Category 11.C)
I.
Qualified Life A. Limitorque Motor Operators TER Items 5, 17-22, 24 [BS-V-1, 2, 3; DH-V-3, 4, 5, 6, 7; MU-V-12, 16, 16, 36, 37; NS-V-35]
Qualified life is established in Limitorque Generic Report B0058.
B. ASCO Solenoid Valves TER Item 33, 36, 39, 40 [SV/AHV-1A; SV/CAV-2, 5, 189; GV/ ICV-6; SV/MUV-3,26; SV/WDL-Y304, V534, V535]
The qualified life, based upon an Arrhenius Analysis, is shown on the SCEW sheets.
C. Static 0 Ring Switches TER Item 56 [PS-672 through 675]
The qualified life is established by the calculations listed on the SCEW sheets.
The basis for these calculations is an Arrhenius Analysis.
D. Square D Switches TER Items 58 & 59 [PS-283, 284,~286, 287, 289, 290, 480 (745)]
The MUPS 480 (745) (Item-56) will be replaced by qualified pressure switches by June 1984. All other PS listed above are now qualified for 40 years due to material replacement which will be reflected in I
our fall 1984 submittal.
E. Namco Snap Locks Switches TER Items 63, 64, 69 [(LSA, LSB) AHV-1A; (LSA, LSB) CAV-2; (LSB, 33)
ICV-3; (LSA, LSB), MU-V-3, 18, 20, 26; (LSA, LSB) WDL-V304, V534, V535]
The material evaluation for a 40 year life of Buna N is correct based upon an Arrhenius Analysis. The conflicting temperature data in the TER does not include an Arrhenius Analysis and therefore cannot be evaluated.
~
.O F. Micro Switches TER Item 72 [(LSA, LSB) CAV-19, 20, 189; (LSA, LSB) hDG-V4]
Same resolution as E above.
II. Replacement Schedule The replacement schedule for all environmentally qualified equipment at TMI-1 is included in the computerized Preventive Maintenance Schedule or Licensing Action Item List (for transmitters). The replacement schedule is not included on the SCEW sheets. The SCEW sheets specify qualified life on sub components or materials only when that life is less than the plant design life of 40 years.
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i.
. Equipment Qualification Deficiencies / Resolution (Category IV)
I.
Generic This documentation was not requested by the Franklin Research Corporation from GPUN in any of their requests for documentation. GPUN has provided all of the documentation requested as documented in GPUN letters dated March 2,1982 (E&L: 4062/82-052), March 24,1982 (5211-82-067) and June 25, 1982 (5211-82-155). All documentation is contained in the GPUN central file. - '
II. Specific A. Rosr Solenoid Valves TER Item 42 [SV/MUV-18, 20]
See I above.
B. GE Motors TER Item 44 [(A, B, C) MU-P-2, 3]
The TER states that these motors are considered to be qualified.
C. GE Motors TER Item 47 [(A, B, C) AH-E-1]
See I above.
l D. Roscmount Pressure Transmitters TER Item 76 [(PT1, 2) RC3A, B]
The SCEW sheets will be revised to list specific (instead of summary) qualification reports and change the qualified life from 40 to 10 years. Revised sheets are scheduled for a fall of '84 submittal.
E. Barton D/P Transmitters TER Item 77 [EFW FI-S-77, 78, 79]
These flow switches are for the EFW pump recirculation line. Per our discussion in GPUN letter dated February 4,1983, the valves are now locked open. Therefore, these switches will be deleted from the Master List in the fall of 1984 submittal.
. F. Bailey Level Transmitters TER Items 85, 88 [(LT1, 2, 3) RC1; (LT4) SPlA, B]
Report is on file at the NSSS vendor, B&W.
G. Bailey Level Transmitters TER Item 87 [(BS1) DPT1, 2; BS3-LT; BS5-LT]
- 1. FRC disagrees with GPUN's analysis thst this display instrumenta-tion need not be environt.ientally qualified. FRC did not have the documentation necessary to make this conclusion.
- 2. See I above.
H. Rosemount Temperature Transmitter TER Items 90, 91 [(TE2, 3) RC4A, B: (TEl, 2, 3, 4) RC5A, B]
- 2. The qualified life on the SCEW sheets will be changed from 40 to 10 years.
J. Stanwick Terminal Blocks TER Item 113 [ Common Item]
Qualification is based upon a report that is proprietary to the Duke Power Co. Only summ.ary information is available to GPUN.
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