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UNITED STATES '
NUCLEAR REGULATORY COMMISSION
- W ASHINGTON, D. C. 20555 N
Docket No.50-219' Jersey Central Power G Light Company ATfN: Mr. Ivan Finfrock, Jr.
Vice President-Madison Avenue at Punch Bowl Road Marristown, New Jersey 07960 Gentlemen:
Your letter dated July 15, 1974, provided additional information concerning your analysis of postulated breaks of pipes inside containment that contain high energy fluid. This additional information was provided in response to our letter of August 7,1973, concerning our review of your application for conversion of the Oyster Creek Nuc1 car Generating Station Provisional Operating License No. DPR-16 to a full-term operating license.
Based on our review of the above cited submittal, we find that your proposed augmented inservice inspection program for postulated high energy pipe breaks inside containment is not acceptabic. The enclosure describes an augmented inservice inspection. program for postulated high energy pipe breaks inside i
containment that is acceptable to us.- Our review of your analysis of the consequences of postulated high energy pipe breaks outside containment has not been completed..
We will need your response to the enclosed position by February 28, 1975, to meet our review schedule. This position was discussed with representatives of General Public Utilities Corporation in a telephone conversation January 23, 1975.
You are requested to provide this information in three signed and notarized originals and thirty-seven conformed copies.
Please contact us if you have any questions regarding the information requested.
Sincerely, A Jl N 7p'. W> J r ~
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George Lear, Chief i
Operating Reactors Branch, #3 Division of Reactor Licensing 9
Enclusure Inservice Inspection Program
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ENCIDSURE Oyster Creek Nuclear Generating Station AUGENTED INSERVICE LNSPECTION PROGRA\\f FOR PIPING COMPONLNFS INSIDE CONTAINMEN'r*
Area of Method of Extent and Frequency Examination Exandnation of Examination stulated pipe break welds that Volumetric 1.
100% each weld for at least three consecutive M upon rupture may result in un-spections** at periods of 3-1/3 years.
acceptable consequences and
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that have high stress levels ***
2.
If no defects are detected, or the defects do not exceed the allowable standards of SE Code Section XI, during inspections of 1., above, subsequent in -
spection may be limited to once during each inspec interval.
j If defects are detected that exceed the allowable standards of ASME Code Section XI, the additional examinations requirements of IWB-2430 (Class 1
(
piping) and INC-2430 (Class 2 piping) shall apply, and the frequency of examination shall revert to 1 I
B.
All other postulated pipe As required by ASME Code Section XI.
break welds that upon rup-ture may or may not result U
in unacceptable consequences.
'Ihrough the service life of the facility, the ASME Code,Section XI that may be used shall be the Edition and the Addenda in effect 40 months or less prior to 'the date of scheduled inspection to the extent practical with the limitations of design, geometry, and materials of construction of the components.
- The period of 3-1/3 years for scheduled inspection of 1. above may be adjusted to coincide with the plants' regular 3-1/3 years period for inspections.
- Table 4-2 of the study " Analysis of Pipe Breaks Inside Containment", June,1974, submitted by Jersey Central Power and light by letter dated July 15, 1974, lists the postulated pipe break locations that have high stress levels.
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i' Jersey l Central Power 6~ Light Compar.y.
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G.;F. Trowbridge, Esquire Shaw, Pittman, Potts, Trowbridge G Madden
.Bar-Building 910 17th Street, N.'W.
Washington,;D. C. 20006 Jersey Central Power G Light Compnay A1TN: Mr.. Thomas M. Crimins, Jr,
' Safety and Licensing Manager GPU Service Corporation
. 260 Cherry Chill Road Parsippany, New Jersey 07054 Anthony Z. Roisman, esquire Berlin, Roismn G Kessler 1712 N Street, N. W.
. Washington, D. C. 20036 Paul Rosenberg, Esquire Danici Rappoport, Esquiro 2323 S. Broad Street Trenton, New Jersey'08610 lionorable Joseph W. Ferraro, Jr.
Deputy Attorney General State of New Jersep 101 Commerce Street - Room 208 Newark,' New Jersey 07102 Burtis W. Horner, Esquire Stryker, Tams and Dill 55 Madison Avenue hbrristown, New Jersey 07960 George F. Kugler, Jr.
Attorney General State of New Jersey State House Annex
- Trenton, New Jersey 08625 Ocean County Library
-15 Hooper Avenue Toms River, New Jersey 08753 e
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,.4 JerseyIentral Power & Light Company v(
MADISON AVENUE AT PUNCH BOWL ROAD e MORRISTOWN, N.J. 07960
- 201-539 6111
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i February 7,1975
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Mr. K. R. Goller
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,t' Assistant Director for Operating Reactors Division of Reactor Licensing Office of Nucicar Reactor Regulation
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Washingtor., D. C. 20555
Dear Mr. Goller:
Subject:
Oyster Creek Nuclear Generating Station Docket No. 50-219 Snubber Service Life and Reliability In his October 1,1973 letter, Mr. Donald J. Skovholt requested the n/v I '. '.o
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sway arrestor) service life and reliability and proposed Technical Specifi-cation changes to incorporate a snubber surveillance program. This request was accompanied by the specification to replace all snubber seal material with
" material demonstrated to be compatibic with the hydraulic fluid at the oper-ating environment," and the specification of snubber inspection intervals (1.c.,
a 120-day maximum inspection interval for snubbers inaccessibic during reactor operation and a 30-day maximum inspection interval for snubbers accessibic during reactor operation).
During the September 1973 shutdown of the Oyster Crock Nuclear Generating Station, all snubbers within the Oyster Creek drywell and most of the snubbers in the Reactor Building were rebuilt with seals made of molded poly-crethane, viton, and othylene propylene.
In December of 1973, General Electric Company reported that snubber seal tests indicated that ethylene propylene (EP) seal material was best suited for use in Bergen-Paters'on snubbers.
Additional tests by the Packer Scal Company demonstrated the ability of EP seal material to withstand the operating environment of the drywell (ref. Mr. D. A. Ross's Ictter of November 8,1974 to Mr. K. R. Coller on " Snubber Temperature and Radiation Environment"). A program to rebuild snubbers with EP seals was started, and at present all drywell snubbers contain only EP seals and Reactor Building snubbers have been rebuilt to a large extent with EP scals.
To date, the EP seal performance has been exec 11cnt.
The detailed inspection procedures presented in the letter of December 7,1973 from Mr. D. A. Ross, Manager of Generating Stations-Nuclear, to Mr. A. Giambusso have shown that no snubbers.have failed g 1G29 r o i ~. ui, y
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wc' Mr.~Goller-February 7,_1975 due to EP seal deterioration.
The failures of snubbers containing EP. seals have
'been the result of mechanical failures-such as main piston rod burrs cutting the main cylinder shaft U-cup.
(Ref. Abnormal Occurrence Report No. 50-219/74-40.)
Rebuilding-and inspection procedures have been modified to identify and minimize such mechanical failures. The incorporation of the EP seals in the snubbers t
- has significantly improved snubber service life and reliability. Therefore, inspections 6f those snubbers in the drywell will henceforth be dont only whan the drywell_ must be entered and the snubber..insrc.cfion_hasaot been_perfpImpf wITEIE~the. previous 120. days.
Defective units will be repaired or replaced before returning to power.
Only EP seals will be used in repairing and rebuild-ing these units.
Snubbers that are not in the drywell and are not accessible during reactor operation will be inspected when they are accessible but not more frequently than 120-day intervals.
Defective units will be replaced or repaired only with EP seals.
Snubbers in the Reactor Building (i.e., those accessible during reactor
. operation) will be inspected at 1 cast every 60 days.
This inspection will include a fluid level determination and a general visual examination.
Units leaking fluid severely will be removed to determine the cause of the leakage.
Repaired and/or rebuilt replacement units for the Reactor Building snubbers.will contain only EP seals except for the main shaft packing seal.
EP main shaft packing seals are not available for some of the snubber models currently in use i
in the Reactor. Building.
Operating experience has shown that this' 60-day inspection interval is sufficient to detect conditions that could lead to snubber inoperaoi11ty (e.g., leaking).
The current snubber surveillance program is part of the periodic a
Oyster Creek maintenance activities. This new inspection program (i.e.,
inspection during drywell accessibility if not performed within previous 120 days, l
etc.)1is currently being included in the Oyster Creek Preventive Maintenance.
i Program.
It is felt that this type of inspection program is best suited for' the maintenance program rather than the Technical Specifications.
Its inclusion in l
the Preventive Maintenance Program safeguards the proper implementation of the
. inspection program.
A proposed Technical Specification change to incorporate the snubber inspections into the Oyster Creek Technical Specifications is there-l fore not included, t
While tests and experience have shown that the EP seal material is a viable solution to the snubber seal deterioration problem, Jersey Central Power 6 Light Company believes that a better solution is the replacement of the hydraulic snubbers with mechanical units.
Analysis and tests have shown that the seismic response characteristics of the mechanical snubbers are equivalent or better 4
than those of the hydraulic snubbers, and it, of course, does not have the seal deterioration problem.
The. Generation Engineering Department of Jersey Central Power G Light Company, therefore, is in the process of purchasing mechanical snubbers.
It is anticipated that procurement procedures will be completed so that some of the drywell hydraulic snubbers can be replaced with mechanical 4
units during the Spring 1975 Refueling Outage.
When this is done, those units i
removed from the drywell (i.e., those containing EP seals only), vill be used l
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Mr. Goller February 7, 1975 I
to replace the snubbers in the Reactor Building. This will allow the surveillance interval for those Reactor Building snubbers containing all EP seals to be
. increased from 60 days to 120 days or greater.
Functional checks of the mechanical units in the drywell will be made in accordance with the specification of the Oyster Creek Station Inservice Inspection Program.
Very truly yours, 3
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f:kr' sV
'/ van lllR. Finfrock,,'Jr.
I Vice President CS k
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