ML20202F411

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Forwards Response to Open Items Remaining from Sqrt/Pvort Site Audit Meeting.Requests That Resolution of Portion of SER Outstanding Issue 6 Be Reflected in Sser
ML20202F411
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 04/08/1986
From: Devincentis J
PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To: Noonan V
Office of Nuclear Reactor Regulation
References
SBN-997, NUDOCS 8604140152
Download: ML20202F411 (16)


Text

, - _ _ _ _ _

s SEABROOK STATION e " .

Engineering Office April 8, 1986 gggg SBN- 997 j T.F. B7.1.2 Mew Hampshire Yonkee Divleien United States Nuclear Regulatory Commission Washington, DC 20555 Attention: Mr. Vincent S. Noonan, Project Director PWR Project Directorate No. 5 '

References:

(a) Construction Permits CPPR-135 and CPPR-136, Docket f Nos. 50-443 and 50-444 I

(b) PSNH Letter (SBN-919), dated December 31, 1985, "SQRT/PVORT; Site Audit - Hecting Summary Response,"

J. DeVincentis to V. S. Noonan g (c) PSNH Letter (SBN-973), dated March 20, 1986, " Seismic i

Qualification Review of Equipment," J. DeVincentis to l V. S. Noonan j

Subject:

SQRT/PVORT; Site Audit - Open Items

Dear Sir:

I During the SQRT/PVORT site audit meeting, the Staff identified approximately 14 items which could not be closed out during the audit due to nature of the question or the question's complexity. Our responses to these items are provided herewith in Attachments A, B and C.

It should be noted that some of these items were addressed previously in Reference (b). Where appropriate, we have made reference to this letter in Attachment A.

The enclosed responds to all but one item which is confirmatory in nature (e.g., confirm that all Pre-Service testing is completed). Notwithstanding this one item, we request the resolution of that portion of SER Outstanding Issue No. 6 concendng SQRT/PVORT be reflected in the next supplement to Seabrook's SER.

Very trul yours, h41901D2960408 ADOCK 05000443 p.

E PDR John DeVincentis, Director Engineering and Licensing Enclosures cc: Atomic Safety and Licensing Board Service List P.O Box 300 . Seatxook.NHO3874

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Diane CurrO2 P:tte J. Mathews, Mayre Harmon & Weiss City Hall 20001 S. Street, N.W. Newburyport, MA 01950 Suite 430 Washington, D.C. 20009 Calvin A. Canney City Manager Sherwin E. Turk, Esq. City Hall Office of the Executive Legal Director 126 Daniel Street U.S. Nuclear Regulatory Commission Portsmouth, NH 03801 Washington, DC 20555 Stephen E. Merrill Robert A. Backus, Esquire Attorney General 116 Lowull Street Dana Bisbee, Esquire P.O. Box 516 Assistant Attorney General Manchester, NH 03105 Office of the Attorney General 25 Capitol Street Philip Ahrens Esquire Concord, NH 03301-6397 Assistant Attorney General Department of The Attorney General Mr. J. P. Nadeau Statehouse Station #6 Selectmen's office Augusta, ME 04333 10 Central Road Rye, NH 03870 Mrs. Sandra Cavutis Designated Representative of Mr. Angie Machiros the Town of Kensington Chairman of the Board of Selectmen RFD 1 Town of Newbury East Kingston, NH 03827 Newbury, MA 01950 Jo Ann Shotwell, Esquire Mr. William S. Lord Assistant Attorney General Board of Selectmen Environmental Protection Bureau Town Hall - Friend Street Department of the Attorney General Amesbury, MA 01913 One Ashburton Place, 19th Floor Boston, MA 02108 Senator Gordon J. Humphrey 1 Pillsbury Street Senator Gordon J. Humphrey Concord, NH 03301 U.S. Senate (ATTN: Herb Boynton)

Washington, DC 20510 (ATTN: Tom Burack) H. Joseph Flynn Office of General Counsel Diana P. Randall Federal Emergency Management Agency 70 Collins Street 500 C Street, SW Seabrook, NH 03874 Washington, DC 20472 Richard A. Hampe, Esq. Matthew T. Brock, Esq.

Hampe and McNicholas Shaines, Madrigan & McEachern 35 Pleasant Street 25 Maplewood Avenue Concord, NH 03301 P.O. Box 360 Portsmouth, NH 03801 Donald E. Chick Town Manager Gary W. Holmes, Esq.

Town of Exeter Holmes & Ells 10 Front Street 47 Winnacunnet Road Exeter, NH 03833 Hampton, NH 03841 Brentwood Board of Selectmen Ed Thomas RFD Dalton Road FEMA Region 1 Brentwood, NH 03833 John W. McCormack PO & Courthouse Boston, MA 02109

f SBN- 997 ATTACHMENT A Response to SQRT/PVORT Open Audit Items SQRT/PVORT Audit Item No. 1 For the Accumulator Tank (SI-TK-5A), confiru nozzle load calculation accounts for piping nozzle loads due to pressure in the axial direction.

Response

The following position regarding stresses induced in the shell of a vessel due to " capping effects" of an elbow attached to the nozzle of a vessel was followed by Westinghouse.

The " capping force (i.e., Pressure X Nozzle Area) due to internal pressure is a load required to satisfy the internal equilibrium of the Vessel / Piping System. It is not an external piping load. It is accounted for in the shell by the PR/t stresses (i.e., hoop stresses) in accordance with Paragraphs NC-3324.14 and NC-3234.4 of the ASME Boiler and Pressure Vessel Code. This vertical force in the nozzle due to

" capping" is exactly equal to the forces exerted on that portion of the shell directly beneath the nozzle and is thus responsible for hoop stresses in the shell. Adding this force as an external force is essentially adding the stresses due to internal pressure twice.

Westinghouse combines the hoop and longitudinal stresses due to internal pressure with the stresses induced by external pipe loads (supplied by the utility's architect-engineer) to arrive at the total stress condition.

SQRT/PVORT Audit Item No. 2 For the Diesel Generator Control Panel (DG-CP-36 and 37), confirm test anomalies identified during the seismic test are adequately addressed. During seismic testing of the subject equipment, it was noted that one of the bolta supporting the subpanel to the panel had pulled out (pull-out occurred at junction of weld and panel during Test No. 7). Even though equipment remained functional and structural integrity was maintained, the NRC was concerned that the bolt could become a missile and damage internal components in the CP-36 and 37 panel.

Response

The sketch, provided as Attachment C, details the stud to panel connection.

As indicated on the sketch, the stud was manufactured with a collar to bear against one side of the subpanel and a nut and washer on the other side. This arrangement effectively prevents the stud from dislodging from its locked position and becoming an internal missile.

g -

h) SBN 997 ATTACHMENT A f Response to SQRT/PVORT Open Audit Items (continued)

SQRT/PVORT Audit Item No. 3 i

! For the Reactor Make-Up Water Valve (RMW-V-30), evaluate nonnetallic f components and verify incorporation of results in the Preventative Maintenance I Program.

Response, See Attachment B for the Repetitive Task Sheet for RMW-V-30.

O

SQRT/PVORT Audit Item No. 4 For the Static Inverter (EDE-I-1A), provide an auditable link between qualification documents and the installed component.

Response ,

l This auditable link is provided in the Westinghouse document entitled "Auditable Link Document for Seabrook Unit 1" (NAH479, Revision 4, dated {

December 1985). This document, since it is proprietary to Westinghouse l' Electric Corporation, will be made available to the Staff out of our Bethesda {

Licensing Office. -

SQRT/PVORT Audit Item No. 5 For the Turbine and Turbine-Driven Emergency Feedwater Pump (FW-TD-2, FW-P-37A):

l (a) Currently a 3" drain pipe has been installed as a temporary fix. If this is to remain _ permanent, provide a status and final configuration / support.  ;

1 (b). Reconcile anomalies in report. Provide details of acceptance or I modification.

Response

(a) Originally, several drain pipes attached to various componer.tn of the turbine driven pump assembly were routed to a funnel drain in the Emergency Feedwater Pusp Room at Elevation 27'0". During start-up testing, substantial steaming occurred in the room. To alleviate this problem, a new arrangement of drain piping was installed for testing!

during Hot Functional Test. The drain piping includen the above and below seat trip and throttle valve drains, high pressure trip and throttle valve steam leak-off, the governor stem leak-off, gland seal drain, low prensure trip and throttle valve stem leak-off, casing drain and a two-inch drain upstream of the trip and throttle valve. As a result of start-up Hot Functional testing. The Drain System was modified and has now been made permanent. In this case, the new piping has been analyzed and qualified as ASME III, Safety Class 3, and seinsic supports have been installed as required.

SBN 997 l

ATTACHMENT A l Response to SQRT/PVORT Open Audit Items (continued)

)

(b) During the SQRT/PVORT Audit, Terry Turbine's seismic expert advised the NRC that Terry was withdrawing the 1976 seismic testing in favor of a new l approach. The new approach is based on a 1979 Terry Turbine test and a )

1985 seismic analysis. 'Ihere is, therefore, an entire new basis for seismic qualification of the EFWP Terry Turbine. The new seismic qualification has been reviewed and is acceptable. )

l l The anomalies observed during the 1979 qualification test were reviewed to determine applicability to the Seabrook Station EFWP turbine drive.

The test anomalies and the resolution are as follows:

1. The turbine tripped during the SSE run. Investigation after the run revealed loose flange bolting at the interface of the governor valve and turbine casing. This caused excessive displacement in the turbine throttle valve. Proper bolt torque corrected problem. I l

Seabrook has different governor system and, therefore, problem is j not applicable. Bolts are preloaded so that similar problem will i l not occur.

l t

2. During the resonant search and the first OBE test, excessive displacement was observed in the lube oil piping to the coupling end l bearing. A support bracket was added to stiffen the piping I assembly. Therefore, this is no longer a problem.

SQRT/PVORT Audit Item No. 6 For the Containment Air Purge 36" Butterfly Valve (CAP-V-1, 4):

(a) Complete / reconcile nonmetallic parts life evaluation. Component maintenance manual states five-year life versus 24-year life on long form. What is the correct life? Provide RTS for review.

(b) Provide correct tag number on Long Form; tag number is inconsistent with component.

Response

l (a) See Attachment B for example Repetitive Task Sheets.

(b) The Containment Air Purge Valves were purchased from Posi-Seal who is the vendor as well as the manufacturer of the valves. The vendor and l manufacturer model number for the valves is " Figure 1134-06-07-03." The Actuators for the valves were purchased by Posi-Seal from Matryx. The model number used by Posi-Seal (vendor) and Matryx (manufacturer) is the same, 45162SR60. However, this model number, as identified on the SQRT Long Form, differs from the actual in the field, Model Number 45162SR80.

A review was performed subsequent to SQRT Audit and was determined that the vendor had erroneously supplied a wrong tag for the model number.

}

l

SBN- 997 ATTACHMENT A-Response to SQRT/PVORT Open Audit Items (continued)

The QA documentation supplied by the vendor identified the correct Model Number 45162SR60. To determine the extent of vendor error, other similar valves (i.e., CAP-V-2, 3) located inside the containment were also i'

reviewed. It was determined that these valves had correct actuator Model Number 45162SR60. An NCR (No. 82-1003A) was issued to correct this apparent error. It should be noted that in spite of the incorrect actuator model number on the Containment Air Purge Valves, the actual actuators supplied were the correct pieces.

SQRT/PVORT Audit Items No. 7 l Prior to startup, the NRC wants confirmation that: )

(a) All required Pre-Service Testing is completed. l l'

(b) All Seismic Qualification of Equipment has been completed.

(c) All Equipment Qualification Reconciliation Programs are complete.

Response

1 (a) See SBN-919, Attachment 1, response to NRC Item No. 3.

(b) See SBN-919, Attachment 1, response to NRC Item No. 5.

(c) Prior to fuel load, a confirmation letter shall be sent to the staff at the completion of the Equipment Qualification Reconciliation Programs SQRT/PVORT Audit Iten No. 8 i For the Emergency Feed Pump (FW-P-37A):

(a) The NRC noticed that a cracked pump shaft seal was being replaced. They want to know i.he cause and what will be done to prevent reoccurrence in

! the future. ,

(b) Davis-Besse Station had an event on June 9,1985, involving a loss of all feedwater. The NRC wants Seabrook to address the industry generic question, provide an explanation on how it effects Seabrook, and explain how the event will be prevented at Seabrook.

Response

(a) After the new seal was installed with an original replacement part, the pump was subjected to a 48-hour endurance run during Hot Functional

. Testing. At the conclusion of the test, minor leakage was identified at the seal. An NCR was generated and a thorough dimensional check was completed. There was a missachining on the rotor in the seal area and the machining prevented the seal from being properly secured to the rotor.

The rotor has been renachined by Ingersol and is reinstalled. Retenting

.will verify seal integrity.

SBN- 997 ATTACHMENT A i: Response to SQRT/PVORT Open Audit Items L (continued)

(b) Subsequent and after the NRC SQRT/PVORT audit in November 1985, a ,

considerable amount of information has been generated about the i Davis-Besse June 9, 1985 loss of feedwater event. INPO, the NRC, and the Westinghouse Owners Group have generated several documents which address the Davis-Besse event. A review of the Seabrook Station design shows Seabrook is not susceptible to such an event as generally summarized below:

r o Seabrook Station does not employ a control system similar to the Steam and Feedwater Rupture Control System (SFRCS) employed at

} Davis-Besse. Manual SFRCS initiation isolated AFW to both steam generators and tripped both feed pumps on overspeed at Davis-Besse.

I o Seabrook Station has an emergency feedwater system (EFW) to serve the function of the Davis-Besse AFW system. It utilizes one l motor-driven EFW pump and one turbine-driven pump. It is,

therefore, not susceptible to common mode overspeed trips of both EFW pumps.

o The Seabrook steam generators do not " dry out" for over thirty minutes (minimus) with no feedwater. Both of the steam generators dried out at Davis-Besse about nine minutes following loss of all feedwater.

o The Seabrook startup feed pump automatically starts with loss of l both MFW pumps, unless there is a safety injection or steam j generator high high level signal. i j o The Seabrook startup feed pump is normally supplied by a nonemergency bus. It can, however, be powered by the opposite emergency bus (train A) from that which powers the motor-operated EFW pump. Thus, in the event of a loss of off-site power the pump can be operated. Furthermore, the only operator actions required j outside the control room to transfer buses are to operate two breakers and a selector switch in the switchgear rooms. This evolution, including operator transit time, is expected to take approximately five minutes to accomplish.

o Startup feed pump flow can be directed to the steam generators, with a loss of off-site power, bypass line to the EFW header. Minimal operator action is required to establish either of these paths.

SBN- 997 ATTACHMENT A Response to SQRT/PVORT Open Audit Items (continued) o As a result of problems identified during hot functional testing at Seabrook involving water slug formation in the steam supply lines to the turbine-driven EFW pump, several design changes are being implemented. These changes protect the piping and supports and minimize associated problems with the EFW pump turbine. The changes include the addition of drains, resloping lines, adding time sequenced valves, modifications to the turbine governor control, and the use of a lower viscosity hydraulic fluid in the turbine governor.

The summarization above is not a total explanation and generally i explains why the Davis-Besse event cannot happen at Seabrook. The Westinghouse Owners Group published (March 1986) a more detailed evaluation supporting fundamental design differences that preclude

( the specific Davis-Besse event from occurring at Westinghouse l plants. The evaluation does recognize there were human errors and I equipment failures that could happen at Seabrook. These have been

! considered at Seabrook through training, system testing, and work on motor-operated valves.

l SQRT/PVORT Audit Item No. 9 i For the Deep Draft Service Water Pump (SW-P-110A) there are some 0-Rings in the seismic restraint and the NRC wants to see the requirements for replacement.

Response

See Attachment B for the Repetitive Task Sheet for SW-P-110A.

SQRT/PVORT Audit Item No. 10 FW-V-331 is a controlled check valve in the Feedwater System that is slow acting by design to prevent water hammer. The question is how are we going to assure the speed remains correct for the 40-year life of the plant? The Section XI IST Program will require testing for flow but does not monitor closure timing of the valve.

l

Response

{

I Seabrook's IST Program will not require the monitoring of the closing time for l

! these check valves in regards to the slow acting design because: l l

l 1. A valve closure time slower than design is acceptable for purposes of water hammer concerns. i i

2. Speeding up of the valve closure over time is not considered credible.

l 3. Valve closure times were established based on faulted plant conditions (i.e., ruptured line flow conditions).

l

. . . _ J

r-SBN- 997 ATTACHMENT A Response to SQRT/PVORT Open Audit Items (continuca) l

4. Because of the relatively short design closure times, a meaningful test would have to simulate as near as possible the system condition that established the valve closure times (i.e. , rupture flow). Accordingly, we. cannot conceive of any test which, if performed, would not be categorized as a faulted plant condition.
5. Performing a test that did not simulate rupture flow conditions is not meaningful because the valve will always pass (e.g., valve would not close as fast as under rupture conditions).

SQRT/PVORT Audit Item No.11 Due to the timing of the audit, no final Repetitive Task Sheets (RTS) could be produced which demonstrate that the Equipment Qualification life-time requirements are being integrated into the maintenance program.

Response

See Attachment B for the Repetitive Task Sheet for SW-P-110A.

SQRT/PVORT Audit Item No. 12 The Active Valve List was changed about a week before the audit. One of the NRC-selected active valves for audit was removed from the list. The NRC wants to see a completed Active Valve List in the FSAR prior to startup.

Response

See SBN-919, Attachment 1, response to NRC Item No. 2.

SQRT/PVORT Audit Item No. 13 Verify new identified active valves have been fully qualified for seismic and operability.

Response

All valves whose status has been changed from inactive to active will be fully qualified for operability and seismic requirements.

SQRT/PVORT Audit Item No. 14 The FSAR does not specifically state active valves 2" in diameter on the BOP side have been qualified. The FSAR shall be revised to reflect they have been

-qualified.

Response

See-SBN-919, Attachment 1, response to NRC Item No. 4.

SBN- 997 ATTACHMENT A Response to SQRT/PVORT Open Audit Items (continued)

Notes

1. At the exit meeting the review teams indicated that:
a. Items 1-6 were SQRT questions.
b. Item 7 was.a confirmatory items.
c. Items 11-14 were Generic PVORT questions.
d. Items 8-10 were PVORT questions.
2. Those items identified with change bar in right hand margin indicate that we revised the response submitted via SBN-919.

r

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APPLIC MODE: 01 PLANT COND REQ: EARLY START DT: 9108 REQ COMP DT: 9121 DT LAST PERF: 00/00/00 TASK DESCRIPTION: (EQ) - REPLACE COIL AND ELASTOMERIC PARTS PER ASCO DATA. NOTE: EQ MAINTENANCE FREQUENCY IS 5.8 YEARS SERVICE LIFE.

ESTIMATED MANHOURS: 1 ESTIMATED TIM ~ EQUIPMENT OUT OF SERVICE (HOURS): 1 ACCEPTANCE CRITERIA:

MORK PREP l l l CHECKLIST l l NUMBER / COMMENTS / LOCATION l CHECKLIST l l COMMENTS / LOCATION CHECKLIST lY/Nl NUMBER l CONTINUED lY/Nl (IF APPLICABLE) l CONTINUED lY/Nl (IF APPLICABLE)

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l TASK DESCRIPTION: (EQ) - REPLACE COIL AND ELASTOMERIC PARTS PER ASCO DATA. NOTE: EQ MAINTENANCE FREQUENCY IS 5.8 YEARS SERVICE LIFE.

ESTIMATED MANHOURS: 1 ESTIMATED TIME EQUIPMENT OUT OF SERVICE (HOURS): 1 ACCEPTANCE CRITERIA:

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LIST REQUIREMENTS ASCO DATA: . ELECTRICAL EQ FILES 248-41-03. SPARE PARTS: COIL-CIDs--------- . SPARE PARTS KIT-CIDa----------

SUPERVISOR SIGNATURE: DATE SIGNED:

SECT I ON I I PRECAUTIONS: SOLINOID MUST BE MOUNTED IN THE VERTICAL AND UPRIGHT POSITION. SOLINOIDS MUST BE INSTALLED USING SEALED VENTED CONOUIT/ JUNCTION BOX SYSTEM. COVER SCREW TORQUE REQUIREMENTS: 10 INCH POUNDS.

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ESTIMATED MANHOURS: 1 ESTIMATED TIME EQUIPMENT OUT OF SERVICE (HOURS): 1 ACCEPTANCE CRITERIA:

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APPLIC MODE: 01 PLANT COND REQ: EARLY START DT 8607 REQ COMP DT: 8633 DT LAST PERF: 00/00/00 TASK DESCRIPTION: PERFORM PROCEDURE MSO508.03 "4KV ROUTINE MOTOR TESTING, INSPECTION AND PM". PERFORM PROCEDURE MSO500.01 "4KV BREAKER TESTING. INSPECTION AND PM".

4 ESTIMATED TIME EQUIPMENT OUT OF SERVICE (HOURS): 4 ESTIMATED MANHOURS:

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APPLIC MODE: 01 PLANT COND REQ: EARLY START DT 8607 REQ COMP DT: 8633 DT LAST PERF: 00/00/00 TASK DESCRIPTION: PERFORM ANNUAL v!BRATION ANALYSIS ON PUMP AND MOTOR PER PROCEDURE MS0500.07 " VIBRATION MONITORING" AND MD0526.05 " OPERATION OF THE MODEL 840" OR MD0526.06 " OPERATION OF THE MODEL 810". RECORD FOR TRENDING. <

ESTIMATED MANHOURS: 1 ESTIMATED TIME EQUIPMENT OUT OF SERVICE (HOURS): 0 ACCEPTANCE CRITERIA: AS STATED IN PROCEDURES.  !

WORK PREP l l CHECKLIST l NUMBER / COMMENTS / LOCATION l CHECKLIST l. I COMMENTS / LOCATION CHECKLIST lY/NIl NUMBER l CONTINUED llY/Nl (IF APPLICABLE) l CONTINUED lV/Nl (IF APPLICABLE)

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LIST REQUIREMENTS SECT I ON I I PRECAUTIONS:

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