ML20112B860

Provides Info Requested,Per 841227 Generic Ltr 84-24, Certifying Compliance w/10CFR50.49 Re Environ Qualification of Electrical Equipment Important to Safety for Nuclear Power Plants

ML20112B860
Person / Time
Site:	Limerick
Issue date:	03/15/1985
From:	Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Thompson H Office of Nuclear Reactor Regulation
References
CON-#285-155 GL-84-24, OL, NUDOCS 8503190327
Download: ML20112B860 (9)

Text

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PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHI A, PA.19101 1215) 841-4 5 o 2

.... 5$7[I,'.U."dm.  !! arch 15, 1985 Mr. Hugh L. Thanpson dr., Di rector Docket No.: 50-352 Division of Licensing U.S. Nuclear Regulatory Ccmnission Washington, D.C. 20555

SUBJECT:

Limerick Generating Station Unit 1 Response to Generic Letter 84-24

" Certification of Compilance to 10CFR50.49, Environmental Qualification of Electrical Equipment Important to Safety for Nuclear Power Plants, Decenter 27, 1984

REFERENCE:

Generic Letter 84-24 FILE: GOVT 1-1

Dear Mr. Thompson:

Generic Letter 84-24, dated December 27, 1984, requested all Licensees to provide, under oath or affirmation, a certification of compliance with 10CFR50.49 "Envirorynental Qualification of Electrical Equipment Important to Safety for Nuclear Power Plants". This letter provides the InformatIon requested by providing individual responses to each of the items IIsted in Generic Letter 84-24. This is done in the paragraphs that follow.

Request (a)

That PECo has in place and is implementing an Environmental Qualification (EQ) Program that will satisfy the requirements of 10CFR50.49 within the currently approved schedule for the plant without further extension.

Response (a)

PECo has established an EQ Program which satisfies the requirements of 10CFR50.49 for Limerick Unit I without further exten-slon of the currently approved schedule.

Request (b)

That the plant has at least one path to safe shutdown using fully qualified equipment, or has submitted a Justification for continued [I safe operation (JCO) pending full qualification of any equipment not g fully quallfled. l(

,1 8503190327 850315 PDR ADOCK 05000352 P PDR

Response (b)

The shutdown cooling subsystem is an integral part of the Residual Heat Removal System (RHRS). The necessary RHR systen electrical equipnent is qualified, therefore, at least one path to safe shutdown using fully qualified equipment exists.

Request (c)

That all other equipment within the scope of 50.49 is either fully qualified or a JCO has been subnitted pending full qualification.

Response (c)

All equipnent within the scope of 10CFR50.49 has been qualified.

The PECo Environmental Qualification Report submittal of 9/84 lists the equipnent requiring EQ at Limerick and references the appilcable EQ documentation.

Generic Letter 84-24 also requested that the certifications described in (a), (b), and (c) above should specifically address all IE Bulletin and Inforretion Notices (IN) that identify'EQ problems, to the extent that such Bulletins and Information Notices are considered applicable to these certifications: '

1. IE Bulletin 82 Deficiencies in Bunker Ramo Primary Containment Electrical Penetration Assemblies:

Response (IEB82-04)

Btnker Ramo Primary Containment Electrical Penetration Assenblies are not used at Linerick Unit 1, therefore, IE Bulletin, 82-04 is not appilcabic.

2. IE Information Notice 82 Potential Inaccuracles in Wide Range Pressure Instruments used in Westinghouse Designed Plants:

Response (IEIN 82-11)

Limerick Unit 1 is a GE BWR, therefore, IN 82-11 is not appilcable.

3. IE Infonnation Notice 82 Equipment Environmental Qualifica-tion Testing Experience: Updating of Test Sunnaries Previously Pubitshed in 81-29. The following several responses are provided:

Response (EEON-1)

Equipment Environmental Qehlification Notice-1 (EEQN-1) on Limitorque Valve Operators: _Limitorque Qualification Reports satisfy the specified environmental paraneters for Limerick Uhit 1.

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_3-Response (EEON-2)

EEQN-2 on ITT Barton Transmitters: Class IE Barton transmitters installed in Class 1E appilcations in Limerick are located in secondary contairment only, not primary contairvnent, and are qualified by Barton Report R3-580A-9.

Response (EEQN-3)

EEQN-3 on D. G. O'Brien Electrical Penetrations:

D. G. O'Brien electrical penetrations are not installed in Limerick Unit 1, therefore EEQN-3 is not applicable.

Response (EEON-4,5,6)

EEQN-4,5 & 6 on Dresser Safety Valves: Dresser Safety Valves are not installed in Limerick Unit 1, therefore, EEQN-4,5 & 6 are not appilcable.

Response (EEON-7)

EEQN-7 on Target Rock power-operated relief valves (PORV) model 80X-006-1: Target Rock PORV's model 80X-006-1 are not installed in Limerick Unit 1, therefore, EEQN-7 Is not applicable.

Response (EEON-8)

EEQN-8 on Control Component Incorporated (CCI) Power Operated Relief Valves (PORV's): CCI PORV's are not installed in Limerick Unit 1, therefore, EEQN-8 is not applicable.

Response (EEON-9)

EEQN-9 on Crosby Safety Valve 3K6: Crosby safety valves 3K6 are not installed in Limerick Unit 1, therefore, EEQN-9 Is not applicable.

Response (EE(N-10)

EEQN-10 on ASCO SV-NP-1 Series failure at 20 megarads of radiation exposure: Limerick ASCO SV's are-NP-8300 series and are not exposed to radiation levels greater than 0.1 megarads.

Response (EEON-11)

EEQN-11 (IN 82-03) Terminal Blocks: This concern is addressed in IN 84-47 and 84-78.

Responso (EEQN-11) cont.

EEQN Potential inaccuracles in Wide Range Pressure Instrtsnents, Westinghouse Designed Plant: Limerick Unit 1 is a GE BWR, therefore, IE IN 82-11 is not appilcable.

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4. IE Information Notice 83 Environmental Qualification Testing of GE-CR-2940 Position Selector Control Switch.

Response (IE IN 83-45)

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PECo does not have GE-CR-2940 Position Selector Control "

Switches installed in harsh environment locations in Limerick Unit 1, therefore, IE IN 82-11 is not applicable.

5. IE Information Notice 83 Equipment Environmental I i Qualification Test Experience. The following several responses are provided:

Response (EEQN-12) '

EEQN-12 on IN 83-40 Need to Environmentally Qualify Epoxy '

Grouts and Sealers: Epoxy Grouts are not used at Limerick for anchors or seals therefore, IN83-46 is not applicable.

Response (EEON-12) cont.

EEQN-12 on IN 83-45 Environmental Qualification Testing of GE CR-2940 Position Selector Control Switch: See Item 4 above.

Response (EEON-13)

EEQN-13 on Anaconda flexible condult: Any flexible conduit Installed in primary containment at Limerick, or Class 1E MOV's, ,

AO's and RV's is not-Installed as a pressure sealing device. PECo j evaluated all devices connected with flexible conduit and where  ;

required, an environmentally quallfled pressure seal was installed at the device.

Response (EECN-14)

EEQN-14 on ITT Barton pressure transducer, model D4R-29098:

These transducers have been replaced with quallfled Rosemount i transmitters at Limerick, Unit 1.

Response (EEON-15)

EEQN-15 on Microswitch, DPST toggle switch, model 12TSI-2: ,

These switches were removed at Limerick, Unit 1.

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Response (EEQN-16)

EEQN-16 on Square D disconnect switch, model 9422-RC-1:

These switches were removed at Limerick, Unit 1.

. Response (EEQN-17)

EEQN-17 on Timetrol SCR controller, model 2053C-125K: These  !

controllers were replaced with a Halmar SCR, qualification by

Rockwell, at Limerick, Unit 1. ,

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- -- ,- . - _ . _ _ - , - ~ - - - - - - - - . - - , - _ _ , . - ,

Response (EEON-18)

EEQN-18 on ATC tire delay relay, model 3198006QIC: These relays were removed from Limerick, Unit 1.

Response (EFQN-19)

EEQN-19 on ITE Gould circuit breaker, model EF3-B015:

Limerick had HE3-B015 breakers, they were removed from Limerick, Unit 1.

Response (EEQN-20)

EEQN-20 on ITT Barton Electronic Transmitter: No Barton Electronic Transnitters, Model 763 are Installed at Limerick Unit 1, therefore, EEQN-20 is not appilcable.

Response (EEQN-21)

EEQN-21 on Barksdale pressure switches Model B2T and D2H:

Barksdale pressure switches models 82T and D2H are not Installed at Limerick Unit 1, therefore, EEQN-22 is not applicable.

Response (EEQN-22)

EEQN-22 on Static-O-Ring pressure switches model SN S 12N:

Static-O-Ring pressure switches nodels SN & 12N are not installed at Limerick Unit 1, therefore, EEQN-22 is not applicable.

Response (EEON-23)

EEQN-23 on ITT Barton electronic transmitter: The fa!!ure mode reported in EEQN-23 occurred at 320oF; the maximtm tanperature the Barton Transmitter (Model 580A-2) will be exposed to at Linerick is 120oF, therefore, EEQN-23 is not appilcable.

Response (EEQN-24)

EEQN-24 on Limitorque Valve Operators: Limitorque Valve Operators have been inspected at Limerick Unit 1 for proper quallfled components and are inspected periodically. Terminal blocks are not used in the Limitorque operators at Limerick Unit 1.

6. IE Infornation Notice 84 Results of the NRC Sponsored Qualification Methodology research Test on ASCO Solenoid Valves:

Response (IE IN 84-23)

The SV's at Limerick are rebuilt on a routine schedule.

Also ASCO SV's are not installed in primary containment, therefore, they would not be exposed to the extreme environmental conditions as in the FRC EQ test.

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7. IE Information Notice 84 Environmental Qualification Testing of Rockbestos Cables:

Response (IE IN 84-44)

PECo has two representatives on the Industry advisory conmittee to assist in the Rockbestos supplemental qualification test program for Class IE electrical cable. Also, Bechtel on behalf of PECo and several other ut!11 ties has prepared a test report on Rockbestos cable which addresses each of the NRC findings.

8. IE Information Notice 84 Environmental Qualification Tests of Electrical Terminal Blocks:

Response (IE IN 84-47)

Terminal Blocks are not used in instnmentation circuits in primary containment. Terminal blocks used in secondary containment which are associated with Instrumentation will not be exposed to the extreme harsh environmental conditions as described in IN 84-47.

9. IF Information tbt tce 84 Operating Experience Related to Moisture Intrusion in Safety-Related Electrical Equipment at Cornnercial Power Plants:

Response (IE IN 84-57)

Equipment Installed at Limerick has moisture seals Installed if the qualification test requires that seals be installed. ,

Termination boxes and Junction boxes have drain holes to eliminate accunulation of water. Maintenance requirements require that equipnent gaskets be replaced with new gaskets whenever disturbed or replacement intervals are defined.

10. IE Information Notice 84 Potential Deficiency in improperly Rated Wiring to Solenold Valves:

Response (IE IN 84-68)

PECo has recently Installed Valcor SV with high temperature fleid Installed wiring and heat shrink on spilcing, where the possible maximun termperature inside the valve body may exceed the

! rating of the insulation.

_7-e

11. IE Information Notice 84 Underrated Terminal Blocks That May Adversely Affect Operation of Essential Electrical Equipment:

Response (IE IN 84-78)

Beau Products 76000 series Terminal Blocks are not installed in Limitorque Valve Operators at Limerick. Electrical Connections in Limitorque Valve Operators are made directly to the torque switch and limit switch and the motor leads are spliced to the source leads.

Sincerely,

.b S &h

~ .

l DFC/dg/03078504 Copy to: A. Schwencer, Chief

Division of Licensing - USNRC I (See Attached Service List) l s t

I

• t

. t COPH0tMEALTH OF PENNSYLVANIA :

ss.

f COUNTY OF PHILADELPHIA  :

i

d. S. Kemper begin first duly sworn, deposes and says:

1 That he is Vice President of Philadelphia Electric Ccunpany; that l

' he has read the foregoing response to Generic Letter 84-24 and knows the contents thereof; and that the statements and matters set forth

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therein are true and correct to the best of his knowledge, Information 5-and belief.

l i-I (2d T k< L 2

l Subscribed and sworn to before me this /[hy i

of March,1985 s

Notary Public PATit1 CIA D. ScitOLE Motary Publ4e. Phil*fpN8 It*l I'hI8 U"'

My Coomumon bpnes Ictuary 10, 1536

cc: Judge Helen F. Hoyt Judge derry Harbour Judge Richard F. Cole Troy B. Conner, Jr., Esq.

Ann P. Hodgdon, Esq.

Mr. Frank R. Romano Mr. Robert L. Anthony Ms. Phyllis Zitzer Charles W. Elliot, Esq.

Zori G. Ferkin, Esq.

Mr. Thomas Gerusky Director, Penna. Emergency Management Agency Angus R. Love, Esq.

David Wersan, Esq.

Robert J. Sugarman, Esq.

Martha W. Bust, Esq.

Spence W. Perry, Esq.

Jay M. Gutierrez, Esq.

Atomic Safety & Licensing Appeal Board Atomic Safety & Licensing Board Panel Docket & Service Section Mr. James Wigt, Ins Mr. Timothy R, S. Campbell