ML20112G320
| ML20112G320 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 01/09/1985 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Stolz J Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8501160299 | |
| Download: ML20112G320 (14) | |
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PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101
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swistos L. oALinorr sLac a c Pn CTION January 9, 1985 Docket Non. 50-277 50-278 Mr. John F. Stolz, Chief Operating Reactors Branch 64 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C.
20555
SUBJECT:
Request for an Exemption to the 10 CFR 50.49 l
Schedule Regarding Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants - Peach Bottom Atomic Power Station
REFERENCE:
(1)
Letter, S. L. Daltroff to J. F. Stolz, dated February 21, 1984 (Peach Bottom Units 2 and 3 Resolution of Safety Evaluation Re prts Relating to I.E.
Bulletin 79-OlB, " Environmental Qualification of Class lE Equipment")
(2)
Letter, S. L. Daltroff to J. F. Stolz, dated June 13, 1984 (Peach Bottom Units 2 and 3 I.E. Bulletin 79-01B,
" Environmental Qualification of Safety-Related Electrical Equipment")
Dear Mr. Stolz:
This letter requests, pursuant to the exemption provisions of 10 CFR 50.49 (g), a completion date extension from March 31,19E3, to November 30, 1985, for certain environmental qualification modification commitments for Peach Botton Units 2 and 3 presented in Attachment 3 to the Reference (1) letter., " Environmental Qualification Modification Schedule", to this letter provides Philadelphia Electric Company's schedule for completion of the environmental N
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fMr.EJohn F. Stolz January 9, 1985
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Page 2 qualification modifications to the safety-related electrical equipment..The changes in the attached schedule from the schedule previously submitted February 21, 1984, are identified by the vertical bar in the right-hand an. gin.
. Attachment 2, " Justification for Continued Operation Pertaining to Environmental Qualification of Equipment Important
- to Safety", to this letter-identifies the Equipment, Safety Function, Qualification Deficiency and Deficiency Evaluation for all outstanding Justifications for Continued Operation (JCO)
- pertaining to Environmental. Qualification of Equipment Important
. to Safe ty.
These JCO's were previously submitted in Attachment 2 of Reference (2) and pertain specifically to those outstanding environmental qualification modifications identified in
. Attachment 1 to this letter.
Although most of the Peach Botton Unit 2 modifications identified in - the Reference. (2) letter are expected to be completed in accordance with the scheduled provisions of Section 50.49(g), equipment delivery may adversely impact the completion of certain environmental qualification modifications to the extent that the Unit 2 modifications will not-be completed before March 31, 1985.
In addition, modifications currently being performed to Unit 2 may not be preoperationally tested before the end of the Unit 2 refueling outage, which may extend beyond March 131, 1985.
Therefore, Philadelphia Electric Company requests,
-pursuant to the exemption provisions of '10 CFR 50.49(g), an exemption until November ~~30, 1985, to the implementation schedule
- of 10 CFR 50.49 (g) for.the'following Peach Bottom Unit 2 environmental qualification modifications:
1.-
Modification:
Replacement of valve actuators on two HPCI valves.
These actuators are being replaced.in order to eliminate the need_for actuator motor brakes.
Reason for Delays Delivery of the valve actuators is not expected until March 1985.
Any delay in delivery would result in installation after March 31, 1985.
'2.
Modification:
Replacement of ECCS pump room unit cooler selector switch cams with stainless steel cans.
Reason for Delays Philadelphia Electric Company had difficulty in obtaining a vendor to provide this component.
As a ' result, stainless steel cams. are being fabricated by a vendor who does not have an environmental qualification testing program.
The need 4 -
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. o Mr. John F. Stolz January 9, 1985 Page 3 for Philadelphia Electric Company to perform its own qualification testing for this component has delayed installation.
3.
Modification:
Replacement of safety-related differential pressure switches used to start the backup fan in the Standby Gas Treatment System (SBGT) and in the Emergency Ventilating System (EVS) for the ECCS pump r
3s.
Reason for Delays Delivery of equipment is not expected prior to March 1985.
4.
Modification:
Replacement of suppression pool level switches that are part of the High Pressure Coolant Injection (HPCI) System used to switch HPCI pump suction from the condensate storage tank to the suppression pool upon high suppression pool water level.
Reason for Delays Prooperational testing for those switches will occur at the end of the Unit 2 refueling outage.
The refueling outago may be extended beyond March 31, 1985.
5.
Modification:
Replacement of motor brakes which do act have adequato qualification documentation on colected
'Q'-listed limitorque valve actuator motors.
Reason for Delay:
Modification to two of the motor brakes will be delayed because a new motor for each of the two valvon will have to be purchased to accommodato the now brakes.
Delivery of the new motor is not expected prior to June 1985.
Although most of the Peach Bottom Unit 3 modifications i
identified in the above Referenco (1) letter were expected to be completed in accordance with the scheduled provisions of Section 50.49(g), a delay in the start of the Unit 3, Cycle 7 Reload Outage, now precludes implementation prior to March 31, 1985.
This delay resulted from a lower than expected capacity factor experienced during the current Unit 3 Cycle 6 operation.
At this time, there is uncertainty as to the dato of the beginning of the Unit 3 Cycle 7 Reload outage.
Although our previous schedules had anticipated the refueling outage to be completed prior to March 31, 1985, it now appears that the refueling outage will not be completed until after March 31, 1985, thereby impacting the
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Mr. John F. Stolz January 9, 1985 Page 4 scheduled outage modification work to certain environmentally qualified equipment.
Therefore, Philadelphia Electric Company requests, pursuant to the exemption provisions of 10 CFR 50.49(g), an exemption until November 30, 1985 to the implementation schedule of 10 CFR SJ.49 (g) for the following Peach Bottom Unit 3 environmental qualification modifications.
1.
Modification:
Replacement of valve actuators on two HPCI valves.
These actuators are being replaced in order to eliminate the need for actuator motor brakes.
Reason for Delay:
Delivery of the valve actuators is not expected until March 1985.
Any delay in delivery would result in installation after March 31, 1985.
2.
Modification:
Replacement of ECCS pump room unit cooler selector switch cams with stainless steel cama.
Reacon for Delays Philadelphia Electric Company had difficulty in obtaining a vendor to provide this component.
As a result, stainless steel cama are being fabricated by a vendor who doca not have an environmental qualification testing program.
The need for Philadelphia Electric Company to perform its own qualification testing for this component has delayed installation.
3.
Modification:
Replacement of safety-related differential prenante switches used to start the backup fan in the Standby Cao Treatment System (SDGT) and in the Emergency Ventilating System (EVS) for the ECCS pump roomD.
Reason for Delay:
Work is outage related and the next refuel outage may not accommodate this ochedule.
In addition, delivery of equipment is not expected prior to March 1985.
4.
Modification:
Replacement of motor braken which do not have adequate qualification documentation on selected
'Q'-listed limitorque valve actuator motors.
Reason for Delay:
This modification in outage related and the refueling outage may be extended beyond March 31, 1985.
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Mr. John F. Stolz January 9, 1985 Page 5 Should you have any questions or require additional information regarding this matter, please do not hesitate to contact us.
very truly yours,
/ r x4 6L ALCL"l [
Attachments
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J. H. Williams, Resident Inspector 4
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ATTACHMENT 1 PIIILADELPIIIA ELECTRIC COMPANY PEACil DOTTOM ATOMIC POWER STATION UNITS 2 AND 3 DOCKET NOS. 50-277 AND 50-278 ENVIRONMENTAL QUALIFICATION MODIFICATION SCHEDULE January, 1985 I
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a Philcdalphic ElCctric C: spiny Peach Bottom Atomic Power Station Units 2 and 3 Docket Nos. 50-277 and 50-278 y
EQ MODIFICATION SCHEDULE P:APJ UNIT-EQUIPMENT IDENTIFICATION NUMBER EQ MODIFICATION STATUS C mmon.OAV20,OBV20,0CV20 These motors will be replaced.
Completion due by 3/85.
2 s.3 MO-14-11A,11B,12A,12B The brakes on these valve actuators,
2& 3 MO-10-25A,B,MO-10-31A,D will be replaced; 2& 3 MO-14-26A,B,MO-10-13A,B,C,D Unit 2 - Completion to all 2& 3 MO-10-34A,B,MO-10-154A,B but MO-14-12B and MO-10-34B due by end of 4/84 Refueling Outage; MO-14-12D and MO-10-34B due by 11/30/85.
Unit 3 - Completion due by 11/30/85','
2& 3 Ho-23-19,MO-23-20 Actuators on these valves will be replaced; Unit 2 - Completion due by end of 4/84 Refueling Outage.
Unit 3 - Completion due by 11/30/85 2
LS-23-91A,B These level switches will be replaced.
Completion due by end of 4/84 Refueling Outage.
2& 3 N3692,N36a3,N3772,N3773 GE Control Stations (CS) test complete..
N3783,N3784,N3884,N3885, N3994,N3995 Modification to C8 will be completed by 3/31/85.
Common DPS-00014,00015 Dwyer Differential Pressure Switches 2& 3 DPS-20400-03,04,05,06,07, (DPS) test completed; switches did 08,09,10,11,12,13,14,15, not meet test acceptance criter$a.
16,17,18,19,20 DPSs will be replaced by 11/30/85.
2& 3 2-PT-6-105 Unit 2 - Completion due by end of 4/84 3-PT-6-105 Refueling Outage.
Unit 3 - Completion due by end of next Refueling Outage.*
CThis particular modification has been determined as not subject to 79-01B requirements.
This modification is being performed in ro ponse to Regulatory cuide 1.97.
Rev. - 0 1/3/84 Rev. - 1 1/85 L
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. Attachment 1 EQ Modification Schedule (continued)
PBAPS UNIT
_ EQUIPMENT-IDENTIFICATION NUMBER EQ MODIFICATION STATUS 2& 3 TE-2442A,B (old TE)
Unit 2 - Completion due by 3/31/85 TE-3442A,B (old TE)
Unit 3 - Complete TE-2-71-Al,B1,C1,Dl,El,F1,G1, H1,K1,L1,M1,N1 (new TE)
A2,B2,C2,D2,E2,F2,G2,H2, K2,L2,M2,N2 (new TE) 2& 3 POT 71 A, B, C, D, E, F, G, II,
Unit 2 - Completion due by 3/31/85 J,X,L,M' Unit 3 - Complete Rev. 0 1/3/84 Rev. 1 1/85 4
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r ATTACllMENT 2 Pl!ILADELPl!IA ELECTRIC COMPANY PEACH BOTTOM ATOMIC POWER STATION UNITS 2 AND 3 DOCKET NOS. 50-277 AND 50-278 JUSTIFICATION FOR CONTINUED OPERATION PERTAINING TO ENVIRONMENTAL QUALIFICATION OF EQUIPMENT IMPORTANT TO SAFETY January, 1985 k
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<e-PHILADELPHIA ELECTRIC COMPANY PEACH BOTTOM ATOMIC POWER STATION UNITS 2 & 3 DOCKETS 50-277 & 50-278 Justification for Continued Operation Eq3ipment.
MO-10-13A,B,C,D) 10-154A,B) Group 1 14-llA,B) 23-20 MO-10-34A,3 ) Group 2 14-26A,B )
MO-10-25A,B )
r 10-31A,3 )14-12A,3 ) Group 3 23-19 Safoty Function:
Group 1 - passive essential Group 2 - normally closed and passive l
essential unless a surveil-lance test is in-progress coincident with a W A.
Group 3 - essential active Qualification Deficiency:
Lack of material traceability for drive motor brakes only.
Deficiency Evaluation:
A review of operability requirements for the Group'1 and 2 valves reveals 1
that they are normally in ~their required position for safety system function and would not be required to change position for resMnse to a safety system initiation algnal.
The Group 3 valves are normally closed and would be required to open post LOCA; however, they are located outside primary containment, and based on a 3-hour time lag between L
inside and outside containment, they would. experience no adverse temprature or humidity during the perlod in which their operation l
might be required.
F-The 10-25A,3 valves would be required to open pont-HEL8; however, both valves would not be subjected L
to the immediate effects of the same HELB and therefore the potential for L
common mode failure of these valves m.
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Attcchment 2 does not exist.
Furthermore, discussions with the manufacturer
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indicate that typical actuator drive l:
motor stall torque is approximately 4 times greater than the static brake torque capability; therefore, it can be concluded and demonstrated by field experience that the motor can position the actuator regardless i
of brake failure.
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Equipment:
LS-23-91A,B
', 83fsty Function:
Automatically transfers HPCI suction from CST to torus on high torus water level.
Ouclification Deficiency:
Radiation qualification test.
' Deficiency Evaluation:
The radiation dosage level is below the threshold value for most materials; the probability of a failure caused by radiation is insignificant.
Eq]ipment:
N3692,N3693,N3772,N3773,N3783,N3784, N3884,N3885,N3994,N3995~
83f0ty Function:
Maintain area coolers control circuit-continuity post accident -
time' required is consistent with
. associated =BCCS system performance.
requirements.
,0ualification Deficiency:
Test documentation radiation level too low.
Deficiency Evaluation A temporary modification has been 3,
completed to ensure.that the control stations will not fail'in such a way
',i as to disable.the area coolers.. The contacts required for operation of the switch under post LOCA conditions will not render the area coolers inoprable.
Also, the contacts whlch are used to manually initiate operation of the NPCI, RCIC and Core Spray area. coolers for surveillance testing during normal plant operation have been removed to avoid the possibility of the operation of all cochers in the event of a switch' failure.
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- L Operation of all area coolers cannot be supported by the ESN System.
This temporary rewire guarantees that the area coolers will operate as required post LOCA.
Equipments:
.DPS-00014,00015,20400-03,04,05,06,07,08, 09,10,11,12,13,14,15,16,17,18,19,20.
' Saf3ty Function:
Maintain ~ electrical continuity for area cooler control circuit post accident, passive essential.
< Qualification. Deficiency:
No qualification documentation for g
this equipment has been located.
Deficiency Evaluation:
Dwyer Differential Pressure Switches (DPS's) have been environmentally tested by Franklin Research center for PECo.
The switches functioned successfully through baseline functional testing,. thermal aging, radiation aging, seismic testing and.
for 4.5 days into the DBA simulation which represents a postulated post DBA period of=13.5 days.
The test switches were thermally aged for periods off20 years and 40 years before DBA testing which adds to the margin of the DPS's installed at PBAPS which'are only 10-years old.
The DPS failure was such that the pressure actuated diaphragm became increasingly stiff during the test and eventually would not move when pressurised.to open the micro ~ switch within the DPS.' No electrical insulation failure or. structural failure occurred which would affect the operation of Jafety-related equipment for the entire 31 days of the DBA simulation.. The DPS's are used'to control the. operation of area coolers in RNR rooms.
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failure of the DPS such that'it will
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not change state does not-affect the operation of the running area cooler.
These switches are installed in the discharge side of the area cooler fans which would reduce their operating temperature by 10 degrees F'and in addation, a 10 degree F margin was added'to'the t
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- 4-general area postulated DBA temperature resulting in a DBA test temperature margin of +20 degrees F.
Failure of the DPS could affect the capability of the backup area cooler from automatically initiating on the loss of the running cooler.
The RHR system (LPCI Model) has four pump / motors located in four different rooma with two area coolers /RHR room.
The failure mode of'the DPS is such that it will not change state af ter 13.5 days post DBA and initiate operation of the backup area cooler for the RHR pump / motor.
The existence of the backup area coolers is not required to meet system requirements or the single failure criteria; as redundant RHR equipment can meet the cooling requirements resulting from a DBA.
Based on the results of the FRC test, the RHR area coolers will start at the onset of an accident and cycle between -the lead fan and backup fan (if required due to loss of lead fan) for 13.5 days.
Ten minutes after the start of the DBA, only two RHR pumps are required to effect an emergency shutdown, (ref.
If the DPS's failed 13.5 days after the beginning of a LOCA and the backup area cooler did not start, an increase in room temperature would be indicated in the control room and the operator would take appropriate action to~ start the redundant equipment in one of the other 3 RHR rooms.
Operation of the RHP.
pump / motor initiates operation of the area coolers with the DPS in the closed psition.
The DPS is normally in the closed position during system shutdown and does not have to change state to initiate e
o peration of the area coolers; t1erefore, it will perform its safety function.
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- Based on the failure mode of the DPS, the fact that the DPS does not have to change state to initiate operation of the area coolers and the RHR pump / motors are redundant, PEco concludes that PBAPS can continue to operate without undue risk to public health and safety.
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