ML20204F463
| ML20204F463 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 04/27/1983 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Stolz J Office of Nuclear Reactor Regulation |
| References | |
| IEB-79-01B, IEB-79-1B, NUDOCS 8305020099 | |
| Download: ML20204F463 (12) | |
Text
.
e PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 SHIELDS L. DALTROFF ELECTR CPR O CTION April 27, 1983 Docket Nos. 50-277 50-278 Mr. John F.
Stolz, Chief Operating Reactors Branch #4 Division of Licensing U.S. Nuclear Regulatory Commission Washington, DC 20555
Dear Mr. Stolz:
Your letter of March 22, 1983, concerning the Clarification of Qualification Safety Evaluation Report, requested that within thirty days of the receipt of that letter we complete certain actions as follows:
Item 1 You should review all JCOs submitted to date to ensure that a JCO exists for all equipment which may not be qualified.
The thirty (30) day response required by the current SE should address equipment items in NRC Categories I.B, II.A and IV (note that Category IV was not mentioned in the previous SER) for which justification for continued operation was not previously submitted to the NRC or Franklin.
Guidelines for justification for continued operation are provided in paragraph (i) of 10 CFR 50.49.
These guidelines should be utilized in developing your justification for continued operation.
0 0[
G305020099 830427 PDR ADOCK 05000277 P
9 4hr. J. F. Stolz Page 2
Response
We have reviewed and revised our Justifications for Continued Operation-(JCOs) in accordance with the above guidelines.
The changes have been incorporated into our revised JCO, dated April 21, 1983, which is attached.
A summary of each category is provided below.
Category IB (CAT IB) - Qualification Pending Modification Our JCO has been revised to include items in CAT IB for which a JCO has not previously been submitted.
The following description is included to define which CAT IB items have been added to our JCO and which CAT IB items do not belong in CAT IB.
Franklin Research Center / Technical Evaluation Report (FRC/TER) - Cat IB Items 1)
Item 12, MO-23-19 Units 2 and 3; Item 16, MO-14-12A & B, Unit 3; Item 17, MO-14-llA & B Unit 3, the preceding have been added to our JCO dated April 21, 1983.
A copy of the revised JCO dated April 21, 1983 is attached.
2)
Item 81, DPIS-lO-121A,B,C,D Units 2 and 3 were listed in PECO September 1, 1981 submittal as having a deficiency with respect to post accident operating time and radiation.
An evaluation of the system requirements indicate that the safety function of the DPIS's will be completed during initial operation of the ECCS and is not required long term post accideat.
Based on this change to the specified time, this item is safety qualified for its intended safety function.
3)
Item 88, Units 2 and 3, Reliance Electric Motors Model CS, in CAD Analyzers.
The motors are not required post accident to take a containment air sample.
These motors were never scheduled for replacement, relocation or testing and are not currently scheduled for any modification.
We believe this item to be incorrectly categorized.
Mr. J. F. Stolz Page 3 4)
Item 125, DPIS-14-81A,B,C,D, Unit 2.
This differential pressure indicating switch is classified as a Cat IB item.
These DPIS's were never scheduled for replacement, relocation or testing and are not currently scheduled for any modification.
We believe this item to be incorrectly categorized.
5)
The following CAD Analyzer Atkomatic solenoid valves are undergoing EQ testing:
SV-4777A-D; SV-4778A-D; SV-4779A-D; SV4780A-D; SV-4782A-D; SV-4783A-D; SV-4784A-D; SV-4785A-D; SV-4792A-D; SV-4962A-D; SV-4964A-D.
These solenoid valves provide sample gas to the CAD Analyzer.
This commitment was not previously identified to the NRC.
As stated in PECO's 90 day response dated September 5, 1981 to NRC's SER of June 5, 1981, PECO committed to replacing Atkomatic solenoid valves Item 41 and 42 SV-2671A-G, SV-2678A-G, and SV-2980.
These are primary containment isolation valves.
PECO has revised the commitment for resolution of qualification deficiencies for these items from replacement to testing.
PECO has elected to extend the EQ test scope to include the CAD sample solenoid valves in addition to the isolation valves.
Our JCO dated April 21, 1983, has been revised to include the CAD Analyzer solenoid valves.
A copy of the revised JCO dated April 21, 1983, is attached.
Category IIA - Qualification Not Established After a review of available environmental qualification documentation for equipment in this category, we have concluded that this equipment is qualified.
As acknowledged in your letter, PECO has requested a meeting with the NRC to resolve these items.
Category IV - Documentation Not Made Available PECO has no equipment in this category.
Item 2 The Technical Evaluation Report contains certain identified information which you have previously claimed to be proprietary.
a Mr. J. F.
Stolz Page 4 We request that you inform us as indicated in the proprietary review section of the Safety Evaluation whether any protions of the identified pages still require proprietary protection.
Response
The summary information on the Equipment Environmental Qualification Review Sheets in the Technical Evaluation Report (TER) designated as containing proprietary information are being reviewed by GE.
Copies of the proprietary sections of the TER have been submitted to GE along with the NRC's Proprietary Review Guidelines.
We have requested a response from GE by April 28, 1983.
Should you require further information,.please do not hesitate to contact us.
Very truly yours,
/,
/ /
~ ;
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Attachments cc:
R. A.
Blough Site Inspector l
l l
l' L
Devised 4/21b 3 Justification for Continaed Operation Peach Bottom Atomic Power Station Units 2 and 3 This document supplements our September 3, 1981 response to the Safety Evaluation for the Environmental Qualification of Safety-Related I'lectrical Equipment at Peach Bottom Atomic Power Station, Units 2 and 3.
Table 1 of the September 3,
1981 response identifies those equipment itemn with environmental qualification deficiencies; Table 1 is provided here :w Attachment 1.
For clarity, the qualification deficiencies have b en subdivided into the following categories:
1.
Deficiency resolved.
2.
Equipment which performs its function prior to exposare to the harsh environment, and the subsequent failure of the egaipment cr non-essential subcomponents does not degrade other safety fanctions or mislead the operator.
3.
' Deficiency restricted to radiation.
4.
Exemption from qualification up-grade.
5.
Other equipment deficiencies.
Category 1 The following portion of the equipment deficiencies identified in Table 1 have been resolved by analysis:
1.
PS-14-044A,B,C,D Units 2 and 3 2.
PS-10-120A,B,C,D,E,F,G Units 2 and 3 3.
EPTB-003 Units 2 and 3 4
20B10,20B11,20B12,20B13 Units 2 and 3 5.
PS-10-121A,B,C,D Units 2 and 3 6.
OAE and OBE65 Units 2 and 3 PS-14-044A,B,C,D and PS-10-120A,B,C,D,E,F,G are pressure switcheF which were previously reported as deficient because documentation was not available to support their operability during post-LOCA radiation exposare.
An analysis (PECO reference 126) which identifies the materials of constraction and the radiation thresholds for the materials has been prepared.
This analysis resolves the radiation deficiency previously reported.
EPTB-003 is a terminal block which was previoasly reported ar deficient because documentation was not available to sapport its operability during
L.
. post-LOCA radiation exposure.
An analysis (PECO reference 178)
.d.: L identifies the generic material of constraction and its radiation threrhr,1d has been prepared.
This analysis resolves the radiation deficion -
previoacly reported.
20B10,11,12,13 are 480 volt power distribution load centerr which w rt previously reported as deficient because documentation was not available tc support their operability post-LOCA or llELB, An environmental qua1ific.. tit!.
report was prepared by the manufacturer for this equipment and it recolved this documentation deficiency.
DPIS-10-121A,B,C,D will perform their safety fonction daring i n i t 1:t l ECCS system operation which is enveloped by the test conditions.
l on: tern operability for shutdown cooling will not be required since the r ti r.
is established in a steady state condition and pump / motor startap ar.d rh a t +.:r.
will be infrequent.
OAE and OBE65 heaters are required in order to maintain the proe e-u:r relative hamirlity below the condensable level.
Condensation is andes i rdle because it would reduce charcoal filter officiency; however, the nyster i <:
equipped with mechanical de-misters and high officiency particalate f i 1 t e r r.
which will~ remove.03 micron particles which perform the same function.
'! ).e loss of efficiency due to charcoal filter wetting may approach 901
- ed c
- .
the FSAR analysis, the resalting plant dischargo is still within plant boundary radiation 1cvels.
Also, discussions with the manafacturer indie -
that the materials of constraction are metallics and phenolics, nared r the proceding it is concluded that the present lack of documentation const it at e:
minimal risk of failure due to post-LOCA radiation exposure..'An analysit 1.a s been performed by PECO to resolve the qualification deficiencies.
(plt 0 her.
128.)
Category 2 b
This category applies to that portion of the equipment identified in Table 1 whien has either a passive essential safety function or it perform i't s safety function prior to exposure to the harsh environment.
The following equipment has a passive essential safety fonction:
1.
MO-10-13A,B,C,D Units 2 and 3 2.
MO-10-154A,B Units 2 and 3 3.
MO-14-11A,B Units 2 and 3 4.
MO-10-34A,B Units 2 and 3 5.
MO-14-26A,B Units 2 and 3 6.
MO-23-20 Units 2 and 3 7.
MO-23-25 Units 2 and 3 i
t:
. The following equipment has an initial short daration act.ive et.nent i o i safety function:
1.
MO-10-25A,B Units 2 and 3 2.
MO-14-12A,B Units 2 and 3 3.
MO-23-19 Units 2 and 3 4.
SV-2671A,B,C,D,E,F,G Units 2 and 3 5.
SV-2678A,B,C,D,E,F,G Units 2 and 3 6.
SV-2980 Units 2 and 3 None of the active essential valve actuators identified above would 1.e exposed to post-LOCA environmental effects within the time period that their operation would be required since they are located outside primary contain-ment.
In addition, the MO-10-25 actuators are physically separated ara cr redundant-loops; the same is true of the MO-14-12 actuators.
Therefore, a llELB is not capable of causing a common mode environment daring the time period that the equipment woald be required to operate.
In addition, the particular deficiency for all motor operated valve actaators (MO) except MO-23-25 involves a subcomponent, the drive motor brakes. Oar evalaatirr. of this deficiency reveals that the actaator coald perform its safety function despite failure of this nabcomponent.
Discussions with the manaf act arer indicate that typical actuator drive motor stall torque is approximatel, 4 times greater than the static brake torque capability; therefore, it can he concluded and demonstrated by field experience that the motor can position the actuator regardless of bcake failure.
The solenoid valves (SV) ase the force developed by process pressure to close, and coil failure woald e m e the valve to close thereby satisfying its safety function objective tt isolate.
Category 3 The following portion of the equipment identified in Table 1 ir e> posed to post-LOCA radiation, however, it is not exposed to prolonged temperatare changes:
1.
2A,2B,2C,2DP35 Units 2 and 3 2.
LS-23-91A,B Unit 2 3.
OA,OB,0CV20 Common plant 4.
N3692,N3693,N3772,N3773 Units 2 and 3 N3783,N3784,N3884,N3885 N3994,N3995 5.
DPS-00014,15 Units 2 and 3 DPS-20400-03 thra -20
l
. The RHR pump motors 2A, 2B, 2C and 2DP35 are qualified to 2.1 m<.
Although these motors would be expected to survive the postulated 101 day post-LOCA dose of 33 MR, an alternate method of shutdown cooling via the min condensers could be used.
Level switches23-91A,B automatically transfers HPCI suction from the CST to the torus on high torus level. Alternate redundant torus level indication is available to the operator from LT-8027A and B.
In addition, those level transmitters provide the operator with a high level alarm.
OA, OB, and OCV20 are the Standby Gas Treatment fan drive motors.
<f the three motors which are available, only one is required, therefore, the system would be expected to be operational post-LOCA.
System design user twc 100% capacity redundant filter trains with capability of using a third motor / fan for either train.
Post-LOCA accident environment can he considerem mild except radiation dose from SGTS filters.
BasedonBig) 21544 the 4f' year normal and post-LOCA total integrated fan dose is 4.33x10 rads.
Dao to the physicaglayout, the third (standby motor) dose is expected to be le e:r t h ar.
4.33yl0 rads.
Based on the above and in consideration of the typical materials used for motor construction, the likelihood of a motor Iailure dae to the common mode post-LOCA radiation exposure is insignificant.
GE control stations N3692 thru H3995 have had JCO's submitted to the MPc on 3/16/83 S.
L. Daltroff to J.
F. Stolz and on 3/23/83 S.
L.
Daltroff tc R. C. DeYoung.
DPS-20400-03 thru -20 are control components for the IIPCI and FCCF area coolers. Each ECCS pump room has redundant area coolers.
Each cooler has a differential pressure switch (dps) which monitors the fan operation.
Their control function is to initiate the alternate cooler in the event that the preferred fan does not start. The application of these dps is a fail rafe
- design, i.e.
failure of the dps to actuate will cause both area coole rn to operate simultaneously.
Category 4 The following portion of the equipment identified in Table I has been exempted from a qualification up-grade basec. on our response to SEE iten 4.2:
1.
MPL 23-1,2 Units 2 and 3 2.
FT-23-82 Units 2 and 3 i
3.
PS-23-68A,B,C,D Units 2 and 3 4.
PS-23-84-1 Units 2 and 3 5.
PS-23-97A,B Units 2 and 3 The equipment in this category is the HPCI pump-turbine and associated instrumentation. The exemption from a qualification up-grade is based on the facts that (1) a fully redundant ADS system and multiple low pressure s'/ stems are available to mi tigate the accident, and (2) the equipment is protected l
l
. tram an adverse environment with the exception of radiation by redambo.t local area coolers.
The area coolers maintain temperature well 1:elcw the system specification limit.
A qualification up-grade for an apparcnt r uli-ation deficiency alone is not warranted since the successful operation c:
in system will prevent radiation exposure, and if core damage of the re.gnit ade associated with the post-LOCA source terms does occur, the system's oporatim would be either of no benefit or minimal benefit at best.
Category 5 The following additional equipment with qualification deficiencies remains to be covered in this category.
1.
20D11,20D11A Ilnits 2 and 3 20B36,20B37,20B38,20B39 N210025A,N210025B 2
SV-4777A-D, SV-4778A-D, SV-4779A-D tinits 2 and 3 SV-4780A-D, SV-4782A-D, SV-4783A-D SV-4784A-D, SV-4785A-D, SV-4792A-D SV-4962A-D and SV-4964A-D Similar motor control centers (MCC) to Item 1 have been tested to temperature and pressure conditions which envelop the PDAPS requirements.
This equipment would not be exposed to harsh environmental effects immediately af ter a LOCA, since the MCC's are located in secondary con-tainment.
In addition, the equipment enclosure is of dust tight con-struction; there are no vents, and compartment doors are gaskered, in the event of a IIELB, RCIC can depressurize and provide the required water inventory make-up.
Alternatively, ADS is available in combination with the low pressure ECCS systems and conventional plant equipment such as the condensate pumps.
This conventional plant equipment is located in mild environment areas.
The Item 2 solenoid valves are required to open post-LOCA to take primary containment samples for the CAD Analyzers.
Since the Peach Botten containment is inerted and post-accident combustible gas control is maintained by oxygen deficiency, the control of combustible gas concentration in containment is relatively insensitive to the rate or extent of hydrogen generation due to metal-water reaction.
Maintenance of containment gas concentrations below combustible limits is accomplished by the addition of nitrogen to limit oxygen concentration to less than St.
Tndication of hydrogen concentration is used only to determine if a level of hydrogen exists within containment such that control of oxygen concentration is needed.
Based on Safety Guide No. 7 (now Regulatory Guide 1.7) assumptions, approximately one day will elapse after a loss of coolant accident before
m.m
. nitrogen addition is required.
Recent evaluations submitted by the !a',;1 Owners' Group and reviewed by the NRC staff have demonstrated that the Regulatory Gaide 1.7 radiolytic oxygen generation is extremely conservative.
(Refer to letter number BWROG-8224 from T.
J.
Dente of the BWROG to D.
C.
Eisenhat of the NRC dated June 21, 1982, and the letter from W.
G. Coancil of NUSCO to W. J. Dircks of the NRC dated August 6, 1982.)
This analyFiF PhCWF that nitrogen addition will not be required.
WJC:LCY 4/21/83 s
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9 Attachnent i Table 1 CAT B Items Equipment Description
' Unit Manufacturer Component No.
Deficiency Fan Motor Conmon GECO 0A,0B,0CV20 QT,T,P,II,R,A
,'I,T,1,H,I,A Valve Actuator 2
Limitorque MO-14-11A,B
(
Valve Actuator 2
Linitorgae MO-14-12A,B Valve Actuator 2& 3 Limitorque MO-10-25A,B (motor 1.rako only)
Valve Actuator 3
Limitorque MO-23-19 Valve Actuator 2& 3 Limitorque MO-14 -?G A, B,10- 154 A, lt Valve Actuator 2& 3 Limitorque MO-10 -13 A, B, C, D Valve Actuator 2& 3 Limitorque MO-23-20,10-34A,8 Valve Actuator 2& 3 Limitorque MO-23-25 (motor onl/)
Solenoid Valve 2& 3 Atkomatic SV-2671 A, B, C, D,1:, F, G
<.T,T,P,H,v,A Solenoid Valve 2.&
3 Atkomatic SV-2678A,B,C,D,E,F,G Solenoid Valve 2& 3 Atkomatic SV-2980 I
Solenoid Valve 2& 3 Atkomatic SV-4777A-D,4778A-D, 9T,T,r,H,1,A SV-4779A-D,4780A-D, SV-4782A-D,4703A-D, SV-4784A-D,4785A-D, SV-4792A-D,4962A-D, SV-4964A-D Control Switch 2& 3 GECO N3692,N3693,N3772, QT, P,II, R, A N3773 control Switch 2& 3 GECO N3783,N3784,N3884, N3885 rontrol Switch 2& 3 GECO N3994,N3995 Level Swit'ch 2& 3 Robertshaw LS-23-91A,B R,A Pressure Switch 2& 3 Static-o-Ring PS-14-044A,B,C,D R,A Pressure Switch 2& 3 Static-O-Ring PS-10-120A,B,C,D,E,F,G,ll P,R,A Prersure Switch 2& 3 Barksdale PS-23-68A,B,C,D R,A Pressure Switch 2& 3 Static-O-Ring PS-23-84-1 R,A Static-O-Ring PS-23-97A,B R,A Differential Common Dwyer DPS-00014,15 T, P,11, R, A Presnure Switch Differential 2& 3 Dwyer DPS-20400-03,04,05,06, Pressure Switch 07,08,09,10,11,12,13, 14,15,16,17,18,19,20 lleater Common American Air Filter OA & BE65 R,T,9T, F,II, A Terminal Block 2& 3 GECO EPTB-003 R,A
b
. 1:quipment Description Unit Manafacturer Conponent No.
Deficiency Motor 2& 3 GECO 2A,2B,2C,2DP35 H,A 4
Load Center 2&3 ITE 20B10,11,12,13 R,T,OT,P,11,A Motor Control 2
Cutler llammer 20D11A P,T,OT,P,II,A Contor flotor Control 2&3 Cutler llammer N210025A,B,20B36,37 Center Motor Control 2& 3 Cutler llammer 20B3G,39,20D11 Centor Flow Trans-2& 3 GECO FT-23-82 QT,T,P,II,R,A mitter itPCI Pamp/
2& 3 GECO MPL23-1,2 QT,T,P,11,R,A Tarbino Differential 2& 3 Barton PS-10-123A,B,C,D T,A Pressure Ind.
Switch WJC:LCY
<1/? ?/83
.