ML20236X750

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Final Response to FOIA Request for Insp Documents Re Plant. Apps a & B Documents Available in Pdr.App C Documents Completely Withheld (Ref FOIA Exemptions 5 & 7)
ML20236X750
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 12/08/1987
From: Grimsley D
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
To: Bauman L
GOVERNMENT ACCOUNTABILITY PROJECT
References
FOIA-87-762 NUDOCS 8712100223
Download: ML20236X750 (5)


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INFORMATION ACT (FOIA) REQUEST DEC 8 1987

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Docm uwna<s, m e,-

ua.es,e Ms. Linda Bauman PART 1.-RECORDS RELEASED OR NOT LOCATED (See checked boxes)

%o agency records subrect to the request have been located.

No oddruonal egency records subpct to the request have been located Agency records subrect to the request that are identifed in Appendia A

are si,eady avasiabie,o, pubhc inspeci,on and copymg m the NRC Public Document Room.

X 5757 H street, N W., Washington, DC.

Agency records sub oct to the request that are identified in Appendix b

are being made available for pubhc inspection and copymg c the NRC Pubhc Document l

X a<.om.1717 H Street. N W., Washington, DC, in a folder under the FOIA mamber and requester name.

1

(

'he nonpropnetary version of the proposalls) that you agreed to accTt in a 'minphone conversation wth a member of my staff is now being made avadable for pubhc mapection l

i aric coying at the NRC Pubhc Document Room.1717 H Street. N W, Westnington, DC, m a fonder under the FOIA nutnbar and requester name Er'cioned e information on how you may obtain access to and the charges for copying reco*ds placed m the NRC Pubhc Document Room.1717 H Street. N W., Washington, DC.

Agency records subpct to the request are enclosed. Any apphcable charge Mr copes'of the recosos provided and payment procedures are noted 0 the comments section.

Records subrect to the request have been referred to another Federal agencynes) for reve* and direct response to you.

Ir* www of NRC's response to the request, no further action a being takan orr appeal letter dated _

PART II.A-INFORMATIOfs WTTHHELD FROM PUBUC OfSCLOSURE Ca*.ain informaton in the requested records is being withhe6d from putAc disclosu e pursuant to the FOIA enemptions desenbed in and for the reasons stated e Part 11, sec.

r X txre B. C. and D. Any released portions of the documents for which onry pam of the record is being withheld are being made available for pubhc repMMon and copying m the NRC Pubhc Document Room,1717 H Street. N W, Washington. DC, er' a folder under this FolA number and requester name.

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l 8712100223 871200 PDR Fogg BAUMANg7-7sg pyg

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NRC FOAM 464 iPen is 65

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FREEDOM OF INFORMATION ACT r.ESPONSE FOiA NUMBER (S) 07=7h2 Daig; Q(( h

{p PART 11 B-APPLICABLE FOIA EXEMPT 109ss b

Records subject to the request that are descnbed in the enclosed Appendices re bemg withheld in thent entirety or in part under FOIA Earmptions and for the reas:es set forth below pursuant to 5 U.S.C. 552(b) and 10 CFR 9 5dat o* NRC Regulations.

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1. The withheld informanon a pr:cedy clasedied pursuant to Enocutive Order 12366 fEXEMPTION Il
2. The withheld information esistes solely to the mternal personnel rules and procedures of NRC. (EXEMPTION 21
3. The wthhe6d mformation a scacdically exempted from public disclosure by statute mdicated. (EXEMPTION 3)

Section 141145 of the Amy c Energy Act which prohibits the disclosure of Restncted Data or Formers Restrced Data 642 U $ C. 21612165L Section 147 of the Atornc E ergy Act which prohibits the dsclosure of Unclassified Safeguards Irdor-anon 142 U S C. 2167L l

4. The withheld informanon a a trace secret or commercial or financial information that is being withbed for the reason (s) indicated: (EXEMPTION 4)

The information is consa1erec to be confidential busmess (propnetaryl information.

The information is conscerec to be propnetary information pursuant to 10 CFR 2.790idH1) i The eformaton was suttnitad and recend in conhdence from a foreign source pursuant to 10 CFR 2 "'90id2 l

6. The withheld information cor,ms s of interagency or intraagency recoros that a<e not available througa disc:overy osmg litigation. Onclosure of predecmional informat. ion X

wouid iond to mnibit the acen.,d frar* e change of useas essentisi io the deliberative process. wh re reco ds are witnheid in their entirety, ine facts are ine tricae,

mtertwined with the predecaora' information. There also are no reasonably segregable factual portiors because the release of the facts would permit en mdirect mquiry mio tne pra:ac monal process of the agency. (EXEMPTION bl

6. The withheld informabon a exar 1pted from public disclosure beca se its disclosure would result m a seam. unwarranted invasion of personal privacy. (EXEMPTION 6)

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7. The withheld information cyms s of investigatory records compiled for law enforcement purposes ard a ::eing weheld for the reason (s) indicated. (EXEMPTION 71 Disclosure would interfeo we an enforcorrant proceeding because at could reveal the scope, direcnon and focus of enforcement efforts. and thus could X

possibly allow them to tane action to shield,4tential wrongdoing or a violation of NRC requirements f-3m invesugators. (EXEMPTION 7t AH Disclosure wound constit te r unwarranted invasion of personal pnvacy (EXEMPTION 74CH The informarson consats :rf ames of indnnduals and other information the disclosure of which wcud *eveal idertifies of confidential sources. (EXEMPTION 7(DH PART 11 C-DENYlNG OFFICIALS Pursuent to 10 CFR 9 9 and'or 935 9 re U S Nuc6 ear Regulatory Commineon regulations, it has been determred t*st the ardormation withheld e exempt from producton or decesure l

and that rts producton of disclosJe a contrary to the public interest. The persons responsible for the denial are t*i3se officaals identified beiow as denying officials and the Director Divoon of Rules and Records. O*ce :ri Adminstration, for any denials that may be appeaied to ine Enecer.e >ector for Operations EDOL DENYING OFFICIAL TITLE / OFFICE RECORDS DENIED APPELLATE OFFICIAL Sec m *

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Regional Administrator Appendix C X

Mr. Robert D. Martin Region IV

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PART 11 D-APPE AL RIGHTS The denial by each denying of'cial ident$od in Part II.C may be appealed to the Appellate Officia' identified in that section. Any such appeal must be in wnting and must be made wthe-30 days of receipt of this response. Appeals must be addressed as appropnate to the Executive Director for Operations or to the Secretary of the Commssicn. U.S. Nuclear Regulatory Commimon, Washington, DC 20556, a,d should clearly state on the envelope and in the letter that it is an " Appeal from an ircal FOIA Decision."

N1C F07.M #4 (Port 21 U.S. NUCLEAR REGULATORY COMMISSG

<> asi FOlA RESPONSE CONTINUATION

Re:

F0I A-87-762 APPENDIX. A RECCFOS MAINTAINED AMONG PDR FILES NUMBER DATE.

DESCRIPTION

.1.

7/6/87 Letter from Andrews to Gagliardo, subject:

Inspection Reports 87-05/E7-08, Completion of Short Term Commitments. (2 pages)

PDR Accession No. 8707220080 l

2.

5/8/87 Letter from Gagliardo to Andrews, subject:

Inspection Report 50-285/E7-08. (6 pages) j.

PDR Accession No. 8705130277 l

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Re:

F0I A-87-762 APPENDIX B

RECORDS MAINTAINED IN THE PDR UNDER THE ABOVE REQUEST NUMBER NUMBER DATE DESCRIPTION 1.

5/13/87 Notice of Significant Meeting, NRC with OPPD, Fort Calhoun Station, Enforcement Conference, with agenda.

(2 pages) 2, 5/20/87 Enforcement Conference Meeting, with attachments.

(51 pages) 3.

8/11/87 Response letter re telephone request for assurance of completion of short-term commitments.

(1 page)

)

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t Re:

FOIA 87-762 APPENDIX C

. RECORDS TOTALLY WITHHEM-NUMBER.

DATE DESCRIPT10N'& EXEMPTION

= 1.

5/19/87, Memorandum from Johnson to Hunter,, subject:

Followup on Fort Calhoun Enforcement Conference.

j (1 page)

Exemption 5 2.

10/14/87 Request for Investigation, Robert D. Martin to Donald D. Driskill.

(3pages)

Exemption 7 3.

. Undated First draft of Notice of Violation.- (4 pages)

Exemption 5 4.

Undated Second draft of Notice of Violatien.

(3 pages)

Exemption 5 1

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4, UNITED STA'ES

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NUCLEAR REGULATORY COMMISSION

$g-REGION IV j

611 RYAN PLAZA DRIVE. SUITE 1000

,e ARUNGTON, TEXAS M011 May 13, 1987 NOTICE OF SIGNIFICANT MEETING Narre of Licensee:

Omaha Public Power District Nare of Facility:

Fort Calhoun Station (FCS)

Docket Humber:

50-285 Date and Time of fleeting:

May 14, 1987 - 8:30 a.m. - 11:30 a.m.

Location of Meeting:

Region IV, 8th Floor Conference Room Purpose of Meeting:

Enforcement Conference (Agenda Attached) i NRC Attendees:

E. H. Johnson, Director, Division of Reactor Safety and Projects J. E. Gagliardo, Chief, Reactor Projects Branch D. R. Hunter, Chief, Reactor Project Section B D. A. Powers, Enforcement Officer R. E. Ireland, Chief, Engineering Branch P. H. Harrell, Se'nior Resident Inspector R. P. Mullikin, Project Inspector J. R. Boardman, Reactor Inspector L. D. Gilbert, Reactor Inspector E. Tomlinson, Project Engineer Licensee Attendees:

R. L. Andrews, Division Manager, Nuclear Production K. Morris, Division Manager, QA and Regulatory Affairs D. Liebentritt, Division Manager, Engineering S. Gambhir, Section Manager, Generating Station Engineering J. Fisicaro, Supervisor, Nuclear Regulatory and Industry Affairs M. Core, Supervisor, Maintenance i

T. McIvor Supervisor, Technical i

~ NOTE: Attendance at this meeting by NRC personnel other than those listed

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above should be made known by May 13, 1987, via telephone call to D. R. Hunter, FTS 728-8103.

Distribution:

See next page m s m _ u,.

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l ATTACHMENT l

1 PROPOSED ENFORCEMENT CONFERENCE AGENDA l'

OMAHA PUBLIC POWER DISTRICT MAY 14, 1987 1

1.

Introduction and Purpose of Meeting E. H. Johnson J

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Specific and generic implications of recent findings in the areas of welding and maintenance activities.

t II.

Welding Activities J. E. Gagliardo D. R. Hunter Control of Special Processes ANI/ANII Concerns Emergency Feedwater Tank Weld Repairs III.

Maintenance Activities J. E. Gagliardo D. R. Hunter Procedure Adequacy Design Bases i

(ASE BPV Code and B 31.7/8 31.1)

Program / Procedure Update - GL 83-28 l-I IV.

Licensee Presentation.

FCS Staff V.

NRC Comments J. E. Gagliardo VI.

Enforcement Policy D. A. Powers l

VII.

Licensee Response FCS Staff l

VIII.

Closing Comments J. E. Gagliardo i

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MAY t 0198/

I'n Reply Refer To:

Docket: 50-235 Omaha Public Power District ATTN:

R. L. Andrews, Division Manager-Nuclear Production 1623 Harney Street Omaha, Nebraska 68102 Gentlemen; This refers to the Enforcement Conference conducted in the NRC Region IV office on May 14, 1987, with you and other members of your staff and Region IV staff members to discuss the findings of the NRC inspections conducted during the periods March 23-27, 1987, and April 6-10, 1987, which were documented in our NRC Inspection Reports 50-285/87-08, dated May 8, 1987, and 50-28S/87-05, dated May 8,1987, respectively.

The subjects discussed at this meeting are described in the enclosed meeting sumary.

It is our opinion that this meeting was extremely beneficial and provided a better understanding of the concerns identified during the inspection.

In accordance with Section 2.790 of the NRC's " Rules of Practice." Part 2, Title 10, Code of Federal Regulations, a copy of this letter will be placed in the NRC's Public Document Roor.

Should you have any questions concerning this letter, we will be pleased to discuss them with you.

Sincerely.

Original Signed By i

E. H. Johnson

$J. E. Gagliardo, Chief Reactor Projects Branch

Enclosure:

Attachment - Heeting Sumary cc w/ enclosure:

W. G. Gates Manager Fort Calhoun Station P. O. Box 399 Fort Calhoun, Nebraska 68023 PI I

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1 RPMullikin:cs DR ter JEGTg11ardo 1

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Clraha Public Power District j Harry H. Voigt Esq.

1 LeBoeuf, Lamb, Leiby & MacRae

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1333 New Hampshire Avenue, NW Washington, D. C.

20036 Kansas Radiation Control Program Director

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Nebraska Radiation Control Program Director bec to DMB (IE45) bec distrib. by RIV:

RPB RRI R.D. Martin, RA RPSB SectionChief(RPB/B)

MIS System RIV File DRSP

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RSTS Operator i

RSB Project Inspector, RPB D. Weiss, RH/ALF j

1 R. Hall 1

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Attachment Omaha Public Power District May 14, 1987 Meeting Summary l

Licensee:

Omaha Public Power District (OPPD)

Facility:

FortCalhounStation(FCS)

License No.:

DPR-40 1

Docket No.:

50-285

Subject:

Enforcement Conference Concerning NRC Inspection Findings (NRC l

Inspection Reports 50-285/87-05 and 50-285/87-08)

On May 14, 1987, representatives of OPPD met in Arlington, Texas, with NRC Region IV and NRR personnel to discuss the fiedtags documented in the two NRC l

inspection reports dated May 8, 1987. The attendance list and licensee presentation are attached. The meeting was held et the request of the NRC, Region IV.

The NRC discussed the generic implications of the inspection findings in the greas of welding and maintenance activities. The licensee discussed the concerns and stated their views and any corrective action proposed or accomplished.

Enclosures:

1, Attendance List 2.

FCS Presentation i

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Enforcement Conference Attendance List - Region IV Omaha Public Power District fAC Attendees:

R. E. Hall, Deputy Director, Division of Reactor Safety and Projects, RIV J. E. Gagliardo, Chief, Reactor Projects Branch, RIV D. R. Hunter, Chief, Project Section B, Reactor Projects Brar.ch, RIV

' D. A. Powers, Enforcement Officer, RIV R. E. Ireland, Chief Engineering Section, RIV P. H. Herre11, Senior Resident Inspector, Fort Calhoun Station E. B.: Tomlinson, Project Engineer, NRR, HQ J. R. Boardman, Reactor Inspector, RIV L. D. Cilbert, Reactcr Inspector, RIV

1. C. Lchroco, Pecc cr Inspector, RIV L. F. Fullikin, Project Ir.pector, RIV Licensee Attendees:

R. L. Andrews, Division Manager, Nuclear Production, Fort Calhoun Station K. J. Morris, Division Manager, QA and Regulatory Affairs R. C. Liebentritt, Division Manager, Engineering M. E. Eidem, dr., Department N4 nager, Generating Station Engineering (GsE)-Mechanical S. K. Gambhir, Section Manager, GSE J. J. Fisicaro, Supervisor, Nuclear Regulatory and j

Industry Affairs 1

T. J. McIvor. Supervisor, Technical M. R. Core, Supervisor, Maintenance J. L. Skiles, Senior Quality Project Engineer, Sergeant-3 and Lundy 1

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.i-ENCLOSURE 2 PROCEDURES UPGRADE PROGRAM i

OBJECTIVES

. i e IMPROVED TECHNICAL CCNTENT OF ALL OPERATING MANUAL PROCEDURES.

4 e ESTABLISH CONSISTENCY IN LEVEL OF DETAIL AND FORMAT FOR EACE PROCEDURE TYPE.

e INCORPORATE HUMAN FACTORS INTO ALL PROCEDURES.

e VALIDATE PROCEDURES AGAINST DESIGN Bi SIS.

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PROCEDURES UPGRADE PROGRAM-APPROACH e DEVELOP PROCEDURES WRITERS 8 GUIDE TO INCORPORATE INPO, NRC AND INDUSTRY " GOOD PRACTICES".

e PROVIDE PRELIMINARY DRAFT OF GUIDE TO ALL PERSONNEL TO BE USED AS INTERIM GUIDANCE.

e ASSIGN A MULTIDISCIPLINARY TEAM OF OPPD PERSONNEL TO CONDUCT REVIEW AND REWRITE OF THE OPERATING MANUAL.

e ESTABLISH A PROGRAM PLAN AND SCHEDULE FOR A STRUCTURED REVIEW OF EXISTING PROCEDURES AGAINST THE WRIT":RS' GUIDE 2RITERIA AND REVISION OF THE PROCEDURES AS NEEDED.

e UPON COMPLETION OF THE DESIGN BASIS RECAPTURE PROJECT, ALL PROCEDURES WILL AGAIN BE REVIEWED AND REVISED AS NEEDED TO ENSURE COMPLIANCE.

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PROCEDURES UPGRADE PROGRAM e WRITER'S GUIDE FOR MAINTENANCE PROCEDURES WILL BE REVISED TO ENSURE TORQUE REQUIREMENTS OR OTHER MEANS OF ASSURING CORRECT TENSIONING ARE SPh,CIFIED FOR CQE FASTENERS WHERE APPROPRIATE.

e'ALTHOUGH CURRENTLY INCLUDED IN THE WRITERS' GUIDE, THE NEED TO DEFINE ACCEPTANCE CRITERIA FOR ANY READINGS OR MEASUREMENTS TAKEN WILL BE EMPHASIZED.

e ALL TEST EQUIPMENT TO BE USED WILL BE REQUIRED TO INCLUDE DEFINITION OF ACCEPTABLE RANGES FOR USE.

e MEGGERING EQUIPMENT WILL BE SPECIFICALLY ADDRESSED IN THE WRITERS' GUIDE FOR MAINTENANCE PROCEDURES WHERE APPROPRIATE l

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PROCEDURES UPGRADE PROGRAM NEAR TERM SCHEDULE l

e APRIL 30, 1987 l

- COMPLETED OP/OI WRITERS' GUIDE.

- IMPLEMENTED WRITERS' GUIDE AS INTERIM GUIDANCE FOR ALL PROCEDURES.

e MAY 31, 1987

- COMPLETE WRITERS' GUIDES FOR ALL OTHER OPERATING MANUAL PROCEDURES (MP, ST, RP, EPIP, ETC.).

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- ESTABLISH PROCEDURE REVIEW / REWRITE TEAM.

f e JUNE 30, 1987

- FORMALLY IMPLEMENT ALL GUIDES AFTER INCORPORATING COMMENTS.

- COMPLETE SCHEDULE FOR FULL REVIEW AND REVISION OF OPERATING MANUAL e

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FORT CALHOUN WELDING PROGRAM I.

History A.

Procedures were adapted from construction procedures.

B.

Original basis - high quality welds, but limited number.

C.

Centralized nuclear / fossil welding program developed 1977.

D.

Extensive modifications, especially structurai, showed program needed improvement.

E.

AWS procedures added to program in 1986.

'II.

1985 550MI and QA audit findings A.

Workmanship. generally adequate, but could be better.

B.

QC inspections - greater consistency needed among inspectors.

C.

QC inpsection forms required additional detail.

D.

Welder qualification and performance records needed improvement.

III.

Corrective actions for SS0MI and QA audit findings A.

Maintenance training program.

B.

QC inspector training - permanent employees and contractors.

C.

Revised QC inspection log, documentation forms.

D.

Upgraded records program.

IV.

Welding program revisions - 1986

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Developed separate Standing Order (G-12A) to address just welding.

- including A.

documentation requirements.

B.

Centralized weld r* i issue.

C.

Added additional inspection requirements.

D.

Added weld design data forms.

V.

1987 Welding Inspections I

A.

Les Gilbert - 3/87 l

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B.

John Tetreault - AN!/ANII - 3/87-4/87.

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C.

Hartford steam boiler ANSI N626.1 and ASME Section XI, Division 14/87.

I D.

OPPD Quality Assurance audit of welding program 4/87.

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E.

Summary of problems identified.-

l.

Weld procedures should have additional detail - code' references, materials, etc.

2.

Qualification records are scattered,' maintenance of qualification is _ difficult to verify.

3.

Additional detail is needed in QC inspection records'- code references, etc.

F.

Basic reason for problems - lack of awareness.

VI. Generic program improvements (in progress).

A.

Additional Technical review and revision of ASME welding procedures.

B.

Additional Technical review and revision of AWS welding procedures.

C.

Automated welder qualification documentation program. - ready for data entry D.

Additional Technical review and revision of NDE procedures.

VII.

Specific responses to Inspection Reports 87-08 and 87-14 A.

Welder qualification _ records 1.

Complete review of all available documentation back to 1973 - 8 man weeks.

2.

One safety-related weld made by a welder whose certification had l

lapsed.

3.

Evaluation to be completed prior to restart.

B.

WPS-51 thickness range'- to be corrected by revision to program.

C.

F1 vs F4 filler metal - believed to be a typographical error - to be corrected by revision to program.

. D.

Postweld heat treatment for WPS-1 to be corrected by revision to program.

'PWHT will not be used unless it is adequately addressed in a procedure.

E.

Completion of MR-81-180 An engineering analysis has been perfonned to address the strength requirements of as-built configuration. A flare-bevel procedure has been developed and qualified using the same techniques that were used to make the field welds. Field welds will be reinspected and this data will be used to provide additional support for the justification of the existing welds.

F.

Pentrameter placement on radiography of EFWST OPPD believes we are on solid technical ground, position is supported by ANI. Nevertheless, all radiography of repair welds since inspection 87-14 has been done with the penetrometer on the source side and the first two repair welds have been re-examined in this manner.

3 G., Hydrostatic test pressure.

Has been revised to 55 psig (1.1 X design pressure) per ASME Section XI.

Note: operating pressure is 0.5 psig N over head pressure.

2 VIII.

1987 Refueling Outage As a result of SSOMI, strong emphasis has been placed on high quality welds and inspections. Quality has been demonstrated on jobs such as replacement of pressurizer spray valves and piping, installation of RCS root valves and replacement of HCV-247 and HCV-248. The efforts have also extended to structural welding on such modifications as the inverter bypass transformers and the storage platform in the containment.

OPPD does not believe that the problems identified are serious enough to affect restart of the unit. They are largely documentation problems and not problems with weld quality.

The problems, however, will be corrected.

I X.' Corrective action schedule A.

Confirmatory reviews of welding and NDE in progress.

8.

Procedure revisions to be in place by 9/1/87.

C.

Automated qualification records program under development.

- ready for data entry D.

Welder qualifications to be updated and records system fully operational by 10/1/87 (Revised welding procedures must be in place first).

X.

Safety related welding A.

Will be done by qualified people using qualified procedures.

B.

Special attention during interim until all upgrades are in place.

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D.

Metallurgical analysis - brittle fracture, no fatio.e (not service - induced)

V.

Repair procedures A.

Grind or arc gouge to remove defects.

B.

QC inspection to verify cleaning, MT to verify that :efect has been removed.

C.

Weld repair using E7018 rod, 200*F preheat.

D.

MT and RT following repair.

j E.

Hydro to 55 psig following completion of repairs.

F.

EFW tank is part of our ISI program.

Examined under ASME Section XI.

I Repaired to ASME SectionIII, Subsection ND 1983, sumner 1984.

l G.

Repair procedure approved by ANI.

VI. Eaton tanks A.

Survey performed to determine what tanks were constructed by this manufacturer, followed by failure assesment.

B.

EFW tank is most critical.

C.

Diesel generator fuel oil tank.

1.

Cleaned and inspected 1987 - no readily apparen: problems.

2.

Petro-Tite leaks test performed - ok.

3.

Buried tanks - soil support.

4.

Engine ar.d wall-mounted day tanks.

D.

CCW tank 1

1.

Operating pressure is a fraction of design (201:.

2.

Fluid is clean, non-corrosive.

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3.

Hydrotest to 55 psig in 1983.

4.

RW is installed back up.

VII.

General considerations on return to operation A.

Catastrophic failure is unlikely.

B.

Leaks are detectable.

j C.

Leaks can be dealt with - comercial consideratic,n, not a nuclear safety problem.

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j POTENTIAL VIOLATION FAILURE TO IDENTIFY AND RETRIEVE RECORDS 3.b.2 THE NRC INSPECTOR REQUESTED THE ORIGINAL DESIGN BASE CALCULATION AND ORIGINAL INSTALLATION RECORDS (" CODE DATA PACKAGE") FOR THE MS SAFETY RELIEF VALVE LINE FLANGE JOINT BOLT STRESS LEVEL. THE LICENSEE WAS UNABLE TO RETRIEVE THESE RECORDS.

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... VIOLATION OF 10 CFR 50 APPENDIX B CRITERIA XVII.

3.c.2 THE NRC INSPECTOR REQUESTED ORIGINAL DESIGN BASE CALCULATIONS AIO INSTALLED RECORDS FOR THE PRESSURIZER SRV LINE FLANGE JOINT BOLT STRESS LEVEL AND BOLT TORQUE.

... VIOLATION OF 10 CFR 50 APPENDIX B CRITERIA %VII.

I 3.d.3.a THE FAILURE OF THE LICENSEE TO IDENTIFY AND RETRIEVE ORIGINAL DESIGN CALCULATIONS FOR BLADE ANGLES ON FANS VA-3A, VA-38, V/.-7C, A2 VA-70 IS ANOTHER EXAMPLE OF POTENTIAL VIOLATION (285/8705-02), FAIURE TO MEET 10 CFR S0, APPENDIX B, CRITERION XVII.

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SUWARY 1.

DESIGN RSIS RECORDS ARE NOT EASILY RETRIEVABLE.

2.

TORQUE VALUES FOR THREADED FASTENERS ' ARE NOT TRACEABLE TO THE DESIGN BASIS i

DOCUMENTS.

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SHORT TERM CORRECTIVE ACTIONS:

PLANT STAFF HAS DEVELOPED AN INTERIM PROCEDURE FOR VERIFYING TORQUING REQU MENTS FOR SELECTED SAFETY RELATED EQUIPMENT WHICH WERE DISASSEMBLED AND/0R MAINTAINED DURING THIS OUTAGE.

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THREADED FASTENER ANALYSIS

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DOCUMENT l PRC Appc4VCD FNW NUMBER MO SNO Nb l PROC?

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NUMBER FASTENER SIZE

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l MATERIAL l ALLOWABLE LUBRICAFP l STRESS l IMPOSED TOROUE VALUE O l STRESS BASIS (REFERENCE CODE / VENDOR DATA):

SUPPORTING DOCUMENTATION: (SAFETY ANALYSIS, TELECON, ETC.)

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STCDS RETORQUED?

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r) W STUDS CHANGED?

Y N

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COMPLETED BY:

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1 REVIEWED BY:

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a LONG TERM CORRECTIVE' ACTIONS I.

REVIEW MAINTENANCE PROCEDURES TO VERIFY THAT APPLICAP4E DESIGN DRAWING CODES AND/0R VENDOR MANUALS ARE REFERENCED ON THE MAINTENANCE PROCEDURES.

l 2.

REVISE MAINTENANCE PROCEDURES TO INCLUDE INSTRUCTIONS THAT ONLY ONE FOR ONE FASTFNER REPLACEMENT IS ACCEPTABLE.

. 3.

TORQUE VALUES SPECIFIED SHALL BE CONSISTENT WITH THE TYPE OF HARDWARE PER EPRI PUBLICATION AND DESIGN DRAWINGS AND APPLICABLE CMtSTRUCTION CODE REQUIREMENTS.

4.

GSE MVIEW APPLICABLE DESIGN DRAWINGS TO ENSURE THAT ACCURATE FASTENERS DATA IS' AVAILABLE ON DESIGN DRAWINGS REFERENCED IN MAINTENANCE PROCEDURES.

(PIPE SUPPORTS, PIPING IS0 METRICS, SEISMIC SUPPORTS FOR MECHANICAL AND ELECTRICAL EQUIPMENT.)

5.

DEVELOP THE FOLLOWING DOCUMENTS TO SUPPLEMENT THE AB0VE ACTIONS:

- CRITERIA FOR USE OF FASTENERS (SPECIFY ACCEPTABLE FASTENERS, APPROVED LU6RICANTS, STRESS VALUES, TORQUE REQUIREMENTS, ETC.).

- DESIGN GUIDE - DISCUSS APPLICATION OF THE CRITERIA.

- FC STANDING ORDER ON FASTENERS TO DOCUMENT REVIEW PROCESS.

SCHEDULE l

l 2

l THE AB0VE ACTIONS ARE PLANNED TO BE COMPLETED BY 6/88.

l

i POTENTIAL VIOLATION 50-285/8705-14 l

l FAILURE TO USE REQUIRED LUBRICANT IN ELECTRICAL EQUIPMENT QUALIFIED (EEQ)

LIMITORQUE VALVE OPERATORS.

THE LICENSE INDICATED THAT HCV-383-4-0, HCV-347-0, HCV-348-0, HCV-331-0, WCV-383-3-0, AND HCV-333-0 LIMITORQUE OPERATORS CONTAINED A MIXTURE OF NEBULA EP-I AND MARFAK GREASES WHICH THEY CONSIDERED QUALIFIED EVEN THOUGH SUCH PRACTICE CONTRADICTED THE SPECIFIC REQUIREMENTS OF THE APPLICABLE LIMITOROUE TYPE SMB INSTRUCTION AND MAINTENANCE MANUAL, BULLETIN SM81-828. THE DOCUMENT USED AS JUSTIFICATION WAS BOLT AND ASSOCIATES LETTER DATED JUNE 17, 1986, j

l

  • MIXING MARFAK WITH NEBULA EB OR (SUN OIL COMPANY) PRESTIGE 50 EP."

j l

1 l

l w_-

THE LETTER BEGINS WITH A STATEMENT THAT NO PROBLEM EXISTS WITH LIMITORQUE OPER-ATORS BECAUSE OF MIXING, SINCE INCOMPATIBILITY IS LIKELY TO RESULT IN " SOFTEN-ING" ( A DE-HYDROLYZATION OR DE-SAPONIFICATION OF.THE GREASE INCREASING ITS-FLUIDITY). THE LETTER STATES TPST THIS WOULD BE NO PROBLEM SINCE THE GREASE IS CONTAINED IN THE GEAR 80X. ADVERSE CHEMICAL REACTIONS (BEARING CORROSION.

ETC.). REDUCTION OR LOSS OF EXTREME PRESSURE (EP) CHARACTERISTICS. OR SEPARA-TION OF OIL FROM THE MIXTURE. ALL OF WHICH MAY RESULT FROM INCOMPATIBILITY OF THE GREASES. WERE NOT ADDRESSED.

i e

THE LETTER SUMMARIZES WITH A PARAGRAPH WHICH STATES:

"I DO NOT WISH MY COMMENTS ON MIXING GREASES TO BE CONSTRUED AS ENDORS-ING SUCH A PRACTICE.

I AGREED WITH LIMIIORQUE (BULLETIN SMBL-80) THAT THIS SHOULD NOT BE DONE AS A MATTER OF POLICY.

IT IS NOT A GOOD IDEA, PARTICULARLY IF THE GREASES MIXED INVOLVE DIFFERENT GELLING AGttiTS, AS IS TRUE WITH THE SITUATION AT HAND. THE BEST PRACTICE IS TO PICK AN APPROVED GREASE (NEBULA IS THE ONLY ONE APPROVED FOR EVERYTHING) AlO STAY WITH THIS PRODUCT DOWN THE ROAD.

IF MORE THAN ONE SUPPLIER IS DESIRED OR AS OTHER PRODUCTS ARE QUALIFIED, IT WOULD KEEP WITH MATE-RIALS CONTAINING AT LEAST THE SAME GELLING AGENTS."

MARFAX AND NEBULA EP GREASES HAVE DIFFERENT GELLING AGENTS.

LIMITORQUE HAS STATED THAT QUALIFICATION OF THEIR OPERATORS IN CONTAIMENT IS CONTINGENT UPON THE SOLE USE OF EXXON NEBULA EP GREASES.

FAILURE TO USE THE REQUIRED GREASE IS A POTENTIAL VIOLATION OF 10 CFR 50.49 (285/8705-14).

.l_

Bolt & Associetes Consulting Services Lubricants. Lubrication. Radiadon EEeets j

t June 17, 1985 Roben O. Bolt, Ph.D.

I I

Mixing Marfak with Nebula EP or Prestice 50 EP f

Mr. J. E. Tho.aa s l

Duke Power Company

.f Design Engineering Department Box 33189 j

Charlotte North Carolina 28242 l

Dear Jim

'You ask if a problem exists with Limitorques as a ' result of the above.

The simple answer is no, and I will detail the

_ reasons here.

~ Incompatibility due to mixing or radiation and thermal stresses are likely to result in softening of the grease mixtures.

This I

I softening creates increased possibility of leaks away from parts to be lubricated.

This is no concern with Limitorques because the lubricant is contained in a sealed gear case.

A i

A l

grease gg an oil is quite satisfactory in such equipment.

The 1

(grease is specified just to reduce leakage through seals. base oil and ' additives t

@l will do their job irrespective of the softness of the' lubricant j

(in the gearboxes.

l You can satisfy yourself on incompatibilities (even though I do not believe there is a problem) through periodic inspection of the lubricants in the gear cases.

Visual observation should suffice, but representative L samples can also be taken for analy-sis For direct observation, use a~ spatula and poke it into the

('grea.

se to work the lubricant around to judge consistency.

This should be after having done the same thing with the fresh prod-uct to become familiar with the " feel" of the material.

Look for any leakage through seals, as well.

Such leakage leaves behind increased concentrations of gelling agent and a harder grease mixture.

If one has to add say 15% as make-up due to f

leakage, the Limitorque should be removed from service for

'l repair.

{

l The grease specified by Limitorque for use inside containment is Exxon Nebula EP.

This is a calcium-coenplex-gelled product.

The Texaco Marfak is a sodium soap-gelled grease.

I have no 4

f 55 Cullodo M. Rd.. San Rafael. CA 94901. (415) 453-6095 f

1 i

LIMITORQUE LUBRICATION DISCUSSION BACKGROUND:

UP.UNTIL AUGUST OF 1986, OPPD'S POSITION ON LIMITORQUE LUBRICATION WAS THAT TEXACO MARFAX GREASE ALONG WITH LIMITORQUE QUALIFIED EXXON EP-0, AND A MIX-TURE OF MARFAX AND EP-0 WERE ADEQUATE FOR USE IN VALVE OPERATORS.

THE MARFAK WAS JUDGED ADEQUATE BASED ON INFORMATION SUPPLIED BY TEXACO AND THE MIXTURE WAS CONSIDERED ADEQUATE BASED ON INFORMATION WHICH TOLD OPPO TO MIX THE GREASE AND SEE IF IT SEPARATED, WHICH IT DID NOT.

(LIST REFERENCE AND SUMARIZE)

MIXING IS BELIEVED TO HAVE OCCURRED IN 383-3 AND 383-4.* THIS STANCE WAS BASED ON THE ANALYSIS WICH OPPD BELIEVED TO BE ALLOWED UNDER T}E DOR GUIDELINES. (NEED COPY OF D0R GUIDELINES)

OPPD HAD INFORMED THE NRC EARLIER IN THE 1984 TER MEETING RESPONSE THAT MARFAK GREASE WAS CONSIDERED QUALIFIED.

ON AUGUST OF 1986, OPPD LEARNED THROUGH INFORMATION SUPPLIED ON TVA AND DUKE i

POWER STATIONS AUDITS THAT OPPD'S POSITION ON LIMITORQUE LUBRICANTS SHOULD BE RE-EXAMINED.

  • EXXON EP-0 WAS CONSIDERED 10 BE THE PRIMARY LUBRICANT.

[.

l 4

BASED ON INFORMATION SUPPLIED BY DUKE POWER, IT WAS LEARNED THAT HIXING IS i

NOT A GOOD PRACTICE AND THAT THE MARFAX 2 ANALYSIS MAY BE INADEQUATE.

TO ENSURE THAT NORMAL OPERATION COULD CONTINUE AND COULD BE CONSIDERED SAFELY, A JC0 WAS PREPARED AND DOCUMENTED IN GSE-FC-86-822.

GREASE CHANGE OUT DURING THE 1987 REFUELING OUTAGE WAS REC 0f HENDED.

TO DATE, NEARLY ALL OF THE GREASE HAS BEEN CHANGED OUT INCLUDING 383-3 AND 383-4.

DISCUSSION WITH PLANT MAINTENANCE INDICATED THAT NO DAriAGE TO T!!E GREASE AND BEARINGS HAS OCCURRED WITH ANY OF THE GREASE CONFIGURATION.

IN ADDITION, THE GREASE THAT WAS FOUND IN 383-3 AND 383-4 LOOKED IN GOOD CONDITION.

THE GREASE WAS FOUND TO BE OF A 'DIFFERENT COLOR" DUE TO MIXING, BUT SHOWED NO SIGNS OF SEPARATION OR HARDENING.

MOV TESTING BY MOVATS INDICATED THAT MOV VALVE OPERATORS AT FCS WAS NOT BEING IMPACTED BY SUCH THINGS AS LUBRICANTS SUBSTANTIATING OPPD'S BELIEF THAT LUBRICATION WAS ADEQUATE.

_ _ __ __ A

c l

+ ; _.

i i

l l

A MAY II, 1987 CONVERSATION WITH EPRI'S LUBRICANT CONSULTANT DR. ROBERT 0.

BOLT, INDICATED THE FOLLOWING:

- THERE SHOULD BE NO CHEMICAL REACTION ONLY A POSSIBLE CHANGE IN THE GELLING AGENT COULD OCCUR.

IF THE GREASE HAD NOT HARDENED OR SEPARATED IT SHOULD BE OK - WHICH IT APPEARED TO BE.

-- THE BEST WAY TO DETERMINE DAMAGE VIA LUBRICATION PROBLEMS, WOULD BE TO INSPECT..THE GREASE CHANGE OUT PLUS MOVAT TESTING SHOWED N0 GEAR OR BEARING PROBLEMS.

- COLOR IS NOT A PROBLEM - IT IS COSMETIC ONLY.

I DURING EARLIER REPLACEMENT OF MARFAX WITH EP-0 IN THE 1983-1984 TIME FRAME, THERE WAS NO LUBRICATION. DAMAGE QUESTION RAISED, WHICH FURTHER SUBSTANTIATED

~

OPPD'S JUDGMENT WHICH DETERMINED THAT A JC0 COULD BE SUPPORTED.

l l

CONCLUSIONS i

l IN 1985, BASED ON GOOD FAITH, OPPD CONCLUDED THAT MIXED GREASES WERE ACCEPT-ABLE PER DOR GUIDELINES.

AFTER LEARNING THE RESULTS OF DUKE POWER AUDIT, OPPD TOOK PROMPT ACTION TO ANALYZE THE SITCATION AND PREPARED A JCO.

DURING 1987 OUTAGE GREASES IN ALL LIMITORQUES WERE REPLACED WITH EP-0 GREASE.

MOVAT TESTING HAS VERIFIED THAT NO DAMAGE WAS CAUSED BECAUSE OF MIXED GREASE.

i b

1

)

l I

UNRESOLVED ITEM (285/8705-13)

LUBRICATION OF CONTAINMENT COOLING FAN MOTORS AND LIMITOROUE OPERATORS _

i THE LICENSEE WAS LUBRICATING RELIANCE MOTORS IN CONTAIMENT ON AN 18-MONTH (REFUELING OUTAGE) IN LIEU OF 3-6 MONTH PERIODICITY, AE HAD USED MARFAX LUBRICATION IN LIEU OF NEBULA EP-0 IN LIMITORQUE OPERATORS IN CONTAINMENT.

THIS WILL REMAIN AM UNRESOLVED ITEM PENDING FURTHER REVIEW DURING A SUBSEQUEKr INSPECTION (-285/8705-13).

O l

l l

i l

1 3

l l

CONTAIWiENT FAN LUBRICATION l

VA-3A, 3B, 70, 7D THE LUBRICATION FREQUENCY OF THE CONTAINMENT VENTILATION FAN MOTORS (VA-3A, h

3B, 7C, 70) 15 BASED ON APPENDIX B,

" GENERAL DESIGN COMMENTS FOR RELIANCE MOTOR...," 0F " SIMULATED ENVIRONMENT TEST FOR J0Y AXIVANE FAN /MUTOR FOR l

NUCLEAR CONTAINMENT FOR THE FORT CALHOUN NUCLEAR POWER STATION...," WHICH i-RECOMMENDS A MAXIMUM LUBRICATING FREQUENCY OF TWO YEARS.

l l

l THIS INFORMATION WAS REVIEWED BY S&L AS PART OF OUR 19F,5/1986 EEQ Comt!TMENT i

TO REVIEW MOTOR MAINTENANCE IN THE EEQ PROGRAM TO CLOSE OUT THE 1985 INSPEC-TION REPORT ON OPPD'S EEQ PROGRAM.

BASED ON THE ABOVE INFORMATION, A MAINTENANCE FREQUENCY OF EVERY REFUELING OUTAGE IS ADOPTED FOR LUBRICATION OF THE FAN MOTORS.

o OPPD BELIEVES THAT OUR PRESENT LUBRICATION SCHEDULE IS ADEQUATE.

i t

, GSbE-2-2 IO" LL I PREPARED BY / / # 'b-'

-- l l CHECKED BY S >'h" l APPROVED BY W. N

-- l SH. 1 CMT. M SH. 1 Rev. 10/85 l REV.

de

~ DATE)[n/w

\\

MR No.

0MAHA PUB [!C POWER DISTRICT ~

I.

i (GENERATING STATION ENGINEERING _

ELECTRICAL EQUIPMENT QUALIFICATION DOCUMENTATION FILE EEQ.H-08 5.0 MAINTENANCE REQUIREMENTS EQUIPMENT:

Reliance Fan Motors QUALIFIED LIFE: 40 YEARS MAINTENANCE REQUIRED TO MAINTAIN QUALIFIED LIFE:

Per the,E.<Q. Anal the fan motors VA-3A, VA-38, VA'7C,[.'and, VA-7D'ysis, S&L CQD-020062pequire relubrication

($

oT2 years. Procedute.P! HEE.12 provides the direction to perform this maintenance. tee-Q.L. Program schedules the perfomance of PM-EE 12 for the four t~aTres., at Ta afnfjieffreqeency'of eyery(6 stage. '

)

PERIODIC TESTING REQUIREMENTS TO MAINTAIN QUALIFIED LIFE:

None Required ADDITIONAL MAINTENANCE REQUIREMENTS:

ins &LLetterNo.CQD-026793 of January 3, 1986 it is stated that there needs to be drainage path for moisture condensation in the conduits that go to the fan motors. The conduits that carry the power feed to these actors runs horizontally from the terminal boxes. The conduits that carry the >ower feed to the terminal box enter the terstnal box from the bottom. Tits will provide sdequate dratnage.

j l

7_ _:_.

__q gar, re, Hel w.ce IDtor ces to CQ~ ~. 2 006 2 (y

\\ f)N m-axp F R" i

$ 3.EjIh!.{'[jDY FanIotor t.

och,*4-8-85 m. _... _

9, c *-* tC ^ C o X

Sdety-attated l

No a.Df ety-Oc'ated

_Page 6 7

.f[.;,,

o OPPD

((,,,kN k

Prepend by Dre i

Fort Calhoun Tf/j

)

Unit 1 7]6-40 g;p.no.See page 1,

Read by D:e 3.

App,end tri Den

!.} G5" 1

6)

Chemical Spray n.:,s j %. ?$'y Per Reference 3, page 12 and Reference 2, page 4 the boric acid

'Y.\\.

5000 PPM injected into tho chamber during accident environment performance

."T ' $

(2.5 pounds of boric acid in 500 pounds of water)

'*

  • f; *'

wts tast.

It envelops our requirements'of 2000 PPM Boron.

(7 4

j 7)

Submergence and Flood Level M 1.'t '

V As per Electrical Equipment Qualification Manual, the level of k..?!i flooding for containment is 1000.9'.

M/D The subject motors are f-4 %'

located above the flood level (per SCEWs) and submergence is, n ' *.'.

i therefore, not applicable.

W.:

3)

Operability

~.

b.(,ck;e.

I' The functional operability of the motor is shown in the Accident W

Environment Performance Test iMt' *

(See' Reference 2, pages 4 and 5, r TN Ssction 4.2.

Since the motor was energized for the test, operability of the moter is urified.

tie

' MTk i M.;

(g.'M'$

))

Synergism

g..(l.

.* gy/j j

There is no known synergistic effect identified on the materials

%q.,.. w v.

1 of the subject equipment.

Pi-j

))

Maintenance and Surveillance

~~~

s'.'

En recommended bfTh'elendor (Reference 1, page 10,)R7-lubrica j<.

.)

Main Steam Line. Break (MSLB) Analysis P

r.

MSLB analysis perfor'ned by the Dist rict indicates a temperature transient of 355*F in contain-

' g, l

This transient shows that the containment temperature ment.

exceeds the predicted LOCA temperature of 305'F fGr a period of g

35 seconds.

gg 4

i Since during the " Rapid Pressure Rise Cycles" testing motor was sn r

operated in the chamber at temperature,at 400'F and with fuli I

electrical load the MSLB requirements are met, 5

j I

p (i

E p l[.

i I(y r,t,

)

1

r.

2.-....

M"1

  • R/144 Reliance Motor c.ie. w.. coo- 0 2 0 0 6 2 c,im,,,

TAllGENTbujNDY Fan i4otor R ev.

00 Det. 4-8-85 3.~..~..

N c - c ^c-o X

s,1, y Related Non-Safetv-Rohted Page 1 of 7

Prepared dAhehf/4-Date M'8 ~ [

i

[

OPPD k-hggh[ey Date 4 - 9.E '

f Unit 1 Revievred Q

Fort Calhoun Q,,

7236-40 g,;,. N., See below Appro,ed t,, //J[ffy/yi-p.t. h.g. fr I

[

Purpose t

f Perform engineering evaluation and analysis to show that the components 7

identifed below are environmentally qualified for use at Fort Calhoun t

Unit 1 Nuclear Station.

References 1).

Wyle Laboratories R,eport No. 26333-28, Thermal Aging Analysis of,

~

Containment Venti 1ation Fan Motors Manuf actured by" Reliance Electric, dateil June I2, T5'8f

~

~

2)

Joy Manf acturing Company Report No. FF-12521, Test Procedure for 6

Accident Environmental Testing of Fan for Nuclear Fueled Power y

Generating Station, dated July 31, 1970 i

3)

Joy Manuf acturing Company Report No. X-377A, the Simulated Environment Test for Joy Axivan Fan / Motor for Nuclear Containment, y

dated September 3,1970 4)

OPPD Interoffice Memorandum IGSE-FC-82-222, dated March 2, 1982..

p.

5)

Letter f rom R. D. Schilz of Joy Manuf acturing to M. Watson of f

Stone & Webster with attachment, dated April 5, 1983.

~

Equipment Identification 4

Tag No.

Name Serial No-Function Location VA-3A Hotor 2X321793Al-CV Fan Motor Containment "2X321793A2-CV VA-3B VA-7C 1X321793A2-CV j

VA-7D 1X321793Al-CV 8

Assumptions 2o i

C It is assuned that the non-metallic materials of motors for fans R

S VA-7A & 7B are same as those for fans VA-3A & B since both have the i

same insulation Class

'N'.

T

]

3 [

9 e

I c

4 h )t S

l c

1 4

i 4

e

' M necu e.o 26333 28

-mm us w c u un s msn-s =

wesrenw octnAnows woeco agiurr Io

5.0 CONCLUSION

The intent of this report was to identify materials susceptible to significant thermal aging degradation when subjected to the specified temperatures for the durations associated with each temperature.

Based on a degradation parameter of 30 percent loss of dielectric strength as the critical property, all materials of the motor insulation system are not considered susceptible to significant degradation when evalucted for the time / temperature degradation effects of the environmental service conditions of Section 2.1.

If the motor bearings are relubricatSA Alma 4 mum two. (2), ye_anjntervals,as...recomrnendsxLin_.Riferen,ch W time /_tcJapgr.Atyre_ aging..affects_are _.noL_ anticipated to significantly degrade the lubricat.ing greas_e.

9 9

l

"E ateou no 26333-23 NUuL3 K3kT84 $UMtt 5 & 575 ft w$ C,aCUP

(

I, WE3Fmed orf tAnoods, svoeCo F ACluTY

[

1I i

  • aci uo i

l

6.0 REFERENCES

1 l

l 1.

1 Docket No. 50-285; Omaha Public Power District's Response to the USNRC Safety 1

l Evaluation Report on Environmental Qualification of Safety-Related Electrical l

f j

Equipment at the Fort Calhoun Station; Enclosures I and 16.

2.

Letter to Mike Capella (OPPD) from Jim Thompson (Wyle) dated April 27, 1982.

Subject:

Containment temperatures, Fort Calhoun Station, Unit 1.

3.

Contact Report: Mike Capella (OPPD) to Bruce Vatth' auer, Jim Thompson (Wyle) dated June 14, 1982.

Subject:

Containment ventilation motor (items VA-3A/3B) operating time requirements and plant specific levels for post-accident duration and environmental temperature.

1 f,.

Elements of Polymer Degradation, Leo Reich, et. al., McGraw-Hill Book Company, New York,1971, Library Code 256-80.

5.

"iEEE Guide for the Statistical Analysis of Thermal Life Test Data,"IEEE 101-1972, Library Code 265-80.

6.

" General Design Comments - Reliance Electric Co. Motor Fan Drive for Reactor Containment Building _ Ventilation and cooling sys,te,rn," Joy 'MiiiriUfactu; ring y

C91DRa.ny:_,

7.

" PYRE-M.L. Wire Ename)," E.1. duPont de Nemours & Company, Bulletin fl9 (Revision f5), January,1977, Library Code 399-80A.

8.

" Life Eruations - DuPont's U.L-Recognized Insulation Systems," April g

21,1979,and "Proputies and Performance of Nomex Type 410 Aramid Paper," DuPont Bulletin No. NX-7, November,1977, Library Code 145-78A.

9.

DuPont U.L. F11e No. E 39505, November 15,1968, Library Code 173-78A.

10.

-Temperature Indices of Industrial Tiwasetting Laminates," NEMA Pub. L15-1969, March 19,1969, Library Code 001-78A.

11.

" Varnished Glass Cloth, Exremely Flexible Class 180C," Westinghouse Electric i

i Corporation Technical Data No.64-580, Febrtsary,1979, Library Code 459-81.

12.

" Thermal Stability of Electrical Varnish," April 30, 1954, Dow Corning Number CE50A, Library Code 371-80A.

e

'I I

[

JOY M MANUFACTURING CO.

PA E OF HED PHILADELPHIA, OHIO REPORT mo.

X-377A PREPARED DY C H E C K E*,,

BY DATE Smember 3,1970 l

l Report On The SIMULATED ENVIRONMENT TEST FOR JOY AXIVANE FAN / MOTOR FOR NUCLEAR CONTAINMENT REFERENCE JOY MANUFACTURING CO. FF12521 For FORT CALHOUN NUCLEAR POWER STA*I1ON OMAHA PUBLIC POWER DISTRICT FORT CALHOUN, NEBRASKA CUSTOMER:

WALDINGER CORPORATION Thru l

1 AMERICAN AIR FILTER COMPANY LOUISVILLE, KENTUCKY AAF P.O. No.7391-CN481-108 SECTION 21)

JOY AXIVANE FAN MODEL 60-30-1200(MM) NUCLEAR SERIAL NO. GF-13111 PART NO. 500722-49 Incorporating a Motor of RELIANCE ELECTRIC CO. MANUFACTURE FRAME 5008 SERIAL NO. 2X32175SA1-CV RATED 460V/3 PH/60 CY FORT CALHOUN : SECTION 21 : UNIT VA 3A/B n.

Dit k FcoTE l

.:. ; MD- % 200 l

l l

1, comu esa

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}

000106

.C

/144 I

(g. i;...oyi 4

siwmot.noelmu onnstow i

4 JOY MANUFACTURING COMPANY e

35 SOWTM SAO&EuweT P, O. e04 eat e e= eaues vma.omo a.eas

}

i I

I s

.)

GENERAL DESIGN COMMENTS RELI ANCE ELY.CTRIc co. HOTOR FOR' FAN DRIVE

~

~~

a LO_!L REAC.IOR._CQhlgERT M]I.LAING

)

j YMTILAII.QN AND COOkJNG g15J114 r

1 i.

% (:i {.

r A!.m The following delineated conditions trere the basis for I

j the motor / fan design specification:

Gamma Radiation during tbe.of 10' Rads of

~

  • I 1

Radiation. Maximum dosa life of motor.

,.3 '

Short time temperature during, emergency mode

., 1, j 2

of 300' F. sabient for 3 to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> duration, d.

than a gradual decay to 150' F.

3.

Vapor pressure of 80 psig during emergency mode.

.4 8

4.

Short time exposure to 1004 relative humidity I

Nj during emergency mode.

With vapor droplets and slightly caustic atmosphere.

4 5.

Normal air pressures of 18.3 psia.

j 6.

Normal exposure to 50% re.1stive humidity, y

at 125 to 1508 F.

'4 7.

Average noter winding temperature of 1808 C.

l (Class 11 llotspot). ~

l

.]

8.

Design life of 40 years.

'.h!

sj ;

kl t

l

'.y) i l

  • 'g 1

l'.

31

.<' + p-

..p.g,..,- y n.,.

7.,.., m,3.

l too rco a4 in%, u.u-o r.o.c 21 x.

00011Dl1 %

.(

w CORI50SIONPROTECTION For added moisture and corrosien resistanco protection, an-epoxy resin is applied to al) internal motor metal surfaces and over.the varnished radiation resistant winding.

This epoxy coating has been used by Reliance for over'10 years and has performed satisfactorily in special chemical

  • and
  • weather-proof a-c motors.

It has been demonstrated that this epoxy is not affected by a lot Sodium Hydroxide Solution.

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BEARINGS AND LUBRICATION

.f

+

'3

t Bearings both th' rust and radial will be of the anti-fr.i'ction

'M type, double shielded ball bearings.

Bearings will be held

.f in place by a cast iron cartridge enclosure.

This enclosure 70 provides for a large capacity' grease reservoir and incorporates the '%ternatic" lubrication system which provides an auto-matic grease relief a2ong the shaft preventing overdressing.

f' Bearings shall have calculated 5-10 Life in the magnitude of 100,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />.

'.(

1 Lubrication, grease, shail be suitable for the radiation

's and temperature exposure.

Crease will be Aeroshell No. 5 or.

l Chevron BRB No. 2.

In the interest of maintaini du,p~

'4 lubricated'st two D.Js.tI_ intervals h[j) reliaM 11 tv. it la recommended that the be 6 fn~

a.m

..d exy.g).)..

h

..M sll d

STANDARD FACTORY TESTS

..)

"O Bach furnished motor shall undergo standard factory test

..d.

as follows:

i.I.k 1.

Runn'ing light current.

1 2.

Running light watts.

J.'.

3.

Resistance, stator.

Y.j 4.

Hipot Test.

5.

Cold insulation neggar.

,1 6.

Air gap measurement.

,j k.

7.

Generated noise in operation.

1 j

5-5 i

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. feg*'t Vftf *g*lt j 9."f uS'e I.i n'.J.J'*t V

  • e' t '

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.J LUBRICATION OF MOTORS

' 1.

lOTORS f urnished in all JOY Series 6'0/1000/2000/

Lubrication frequer.cy per ne following schedu' p' y fans have been lubricated with Chevron SRI #2

-rease and it as recommended that tre customer con-NoRsEPoWER CDesDmoNs CONDITloN' rive to use this lubricant in future lubrications. If this 1 thru 7W hease cannot be obtained, the only omer suggested 1800 RPM and slower 3 years 1 year foricants are:

10 thru 75 iPERATING TEMP. -25' C. (-15' F.) to 50' C. (120' F.)

1000 RPM and slower 2 years 6 to 12 moni i

CHEVRON OIL SRI No. 2 100 and greater (6 months' SHELL OIL CO.

DOLIUM R 1800 RPM and slower 1 year TEXACO, INC.

PREMlUM RB All over 1800 RPM 6 rnonths 3 months stNIMUM STARTING TEMP. -75" C. (-- 100* F.)

  • STANDARD CoNDITI,oNs: Egns hours per day, normal or I SHELL OIL CO.

AEROSHELL #7 loading, clean. @ 40 C. (100* F.) smaximum ambient.

..sEVE5tE CONDITIONS; Twentr4oest ho irs per day operation shock loadsng, vibration. of a dirt or dust @ 40-s0' C. I 120' F.) amtnent.

ping a hand operated grease gun onty, pump in the

>Ilowing recommended grease volume:

Motors with Class H. Type FN or Class H, Type RH in lation systems, nuclear appEcations, must be lubrica i

with Chevron SRI #2 with no substitutions permitt i

VOLUME IN CUB 8C INCHES FRAME SIZE 1800 RPM 3600 RPM Some high horsepower motors have special bearir And Slower These fans have a motor lubrication instruction pl j

182 Thru 215 05 05 mounted on the outside of the fan near one of the gre

{

l _ 254 Thru 286 10 10 fittings. Follow the instructors on this plate in liet i

the standard instructions pnneed here, f

324 Thru 365 1.5 15 404 Thru 449 25 10 5000 25 15 grease in the bearing ccvities to lubricate the bearing' NJ Theref% no grease fittings ase provided on these I

(

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LOBNICATION OF CONTROLLABLE PITCH MECHANISMS l

' NTROLLABLE PITCH FANS require periodle lubri-O stion for fan pitch control mechanisms and blade bear-ROLLER BEARING CottTROL MECHANISMS igs (depending upon hub size or style) an addition to E

,,7, f fan motor bearings. An external grease fitting is g

,sT w o

  • *sEvtRE l

rmmarrioNs coNomoNs i

gcated on the actuating tsar cf the lever assembty or on se casing near the actuating bar or on the mechanism P/N 500988-152, l

'xl bell. PUMP BY MEANS OF HAND GREASE GUN 156s 157 I

for 26%" dia. hubs 3 INDICATED BELOW AT SIX (6) WEEK INTERVALS:

% cia, nn.

1% cu. in.

U P/N 500988151, l

BALL BEARING CONTROL MECHANISMS I

1, 1

g9

! eMC ByRs

.UB A N e T

N P/N 500988-167 l

for 30" dia. hubs j P/N 500988-84, Hold the grease relief cap I

85,86,87 closed and care 9ulty pump

  • STANDARD CoNDmoNs: Eigm hours per day, normal or 14 lot 26%* dia. hubs in grease until ilt is seen nonding. cie n. e 40' c. (100* F.) uneximum amb nt.
    • sEvtag coNomoHs: Twenty 4mst hours per day operstbn oozing between the bearing shock loading, vibration, or in art er dust e 4o.50* C. (tt housing and the adjusting 120' F.) ambient.

l disc. Rotate tan rotor slow-RECOMMENDED LUBRICANT FOR CONTROLLABLE l PIN 500988-115, ty by hand whae lubricating PITCH MECHANISMS

  • j 116 1 to insure grease cavity is
or 171b 17 118 f

dia. hubs completely filled, TEXACO PREMlUM RB NO. 2 i

Operating Temperature l

%LTTIONS:

} Grease slowly to preveat rupture of the bearing

-- 35'C (- 30*F) to + 150*C ( + 300 shield-BLADE BEARINGS in textile service rotors and large

. Use only SRI 2 or Joy recom. mended equivalent horsepower units have tube fr:angs at the base of eac grease.

blade. These should be greased orsce per year.

L______

HISTORY NRC CONCERN #285/8705-03 APPLICABLE CODE AND SPECIFICATION REVISIONS FOR PIPING-SYSTEM DESIGN NRC CONCERN:

1.

LICENSEE PLANT ENGINEERING PERSONNEL WERE UNABLE TO IDENTIFY TO THE NRC INSPECTOR WHICH REVISION OF THE CODE WAS BEING USED BY FORT CALHOUN STATION OR, DURING PREVIOUS PERIODS OF TIME, WHICH REVISIONS WERE APPLICABLE.

NRC CONCERN:

2.

SINCE NEBRASKA IS A CODE STATE, LATER PIPING SHOULD HAVE BEEN TO THE ASME B & PVC, WHEN CODE WAS EXTENDED TO PIPING.

APPLICABLE CODES (PIPING. VESSELS) WHEN FORT CALHOUN STATION DESIGN WAS STARTED USAS B31.1 - PIPING ASME SECTION III - VESSELS - NUCLEAR l

VIII TANKS /H/E/VESSLES LATE 1960'S - 1967 - 1968 USAS B31.1 - NON

  • NUCLEAR" PIPING USAS B31.7 - NUCLEAR PIPING CL. 1, 2, 3 ASHE SECTION III - NUCLEAR VESSELS VIII - VESSELS EARLY "G70'S - 1973 - 1974 ASME SECT. III NUCLEAR VESSELS - PUMPS - VALVES - PIFING

FORT CAL 5KXJN ' STAT 10N DESIGN i

L CODES l B(1 PIPING:

-USAS B31.1 & WITH A STRESS ANALYSIS MEETING REQUIREMENTS OF ASME.

(

' SECT. III - 1967'

[Di PIPING:.USAS B31.7 1968 OTHER PIPING:

USAS B31.1 1967

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. _.4.

e 69

  • l l

t.

I 1

DESIGN BASIS CODES-

' LOCATION USAR l

SYSTEM (SEE RC FOR: EXAMPLE)

APPENDIX.(SEE APP. F FOR EXAMPLE)

DRAWINGS GO TO P & ID. PICK OFF IC DRAWING LOOK AT IC DRAWING - GIVES DESIGN BASIS OTHER DRAWINGS GIVE DESIGN BASIS ("D" DRAWINGS ALS0) l APPLICABLE VENDOR DRAWINGS J

a 1

l

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i N

s

APPENDIX N DID N_QI REDESIGN OR RECONCILE (AS REQUIRED BY SECTION XI) ANYTHING IN l

UTILIZE NEWER CODES A N.fW SET OF DESIGN BASIS CALCULATIONS (RECONCILIATIO CALCULATIONS) MUST BE DONE L

CQE LIST EXPLAINS WHAT RECLASSIFY MEANS IN USAR APP. N

SUMMARY

RESOLUTION OF NRC CONCERN:

I.

DEVELOPE PROGRAM / TRAINING SESSION TO INFORM P'LANT ENGINEERING OF

{

x S m SIS C0x S, m RE m v ARE LOC m D.

{

.ESeU1.

NRC...

2.

ASME SECTION XI DOES NOT REQUIRE MODIFICATIONS TO BE ACCOMPLISHED TO THE LATEST CODES. WHAT IT QQJJi REQUIRE IS MEETING OR EXCEEDING THE ORIGINAL DESIGN CODES.

I e

-__._____m_-__-__.--_-.m.

3 '14/87 12:02 OPPD BPSNDIES iO. OCG 002 NLenorandum

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September 16, 1986 GSE FC-86-822 From:

S. K. Gambhir D

J. K. Casper

~

W. G. Gates

SUBJECT:

Electrical Equipment Qualification Program Limitorque Motor Operator Lubricants j

Refe'rence: GSE-FC 86-783, 'Limiterges Motor Operator Qualification

  • The referenced letter, SSE FC-86-783, indicated that a potential problem may arist in the qualification of the lubricaat used in the EEQ Program Limitergue Motor Operators.

This concern was amplifted in the Safety Systen: Functiemal Ins >ection Report Nos. 50-26g/861G, 50-270/86-16, and 50-287/86-16 connected at ) uke Power Company's Oconee Nuclear Station.

The concerns are centered on two issues:

2.

The qualification of lubricants other than the lubricant used by Limitergue (Exxon Nebula EP-0, or EP-1) in the qualification testing.

2.

The potential incompatibility of greases of differsnt galling agents (lith-ium, sodium, calcium) when mixed in the gear cases of the Limitorque opere-tors as a result of maintenance ever the years.

Although the concerns had been addressed in the EE0-TER meeting response, it was judged that the issued should be re-examined based on the informatiea cam-tained in the TVA's and Duke Power Company's reports.

Based on the information supplied in Table 1, it appears both concerns may exist at the Fort Calhoun station. From Table 1, eight operators are kana to contain Texaco Marfak Multi Purpose 2. nineteen are known to contain Exxon EP-2 and three may contain a mixture of Marfak 2 and other grease.

To resolve this issue and deteristne a course of action, additional information was obtained from Duke Power Compuy, a laboratory test for the gelling agent in HCV-347 was performed, and a Justification for Continued Operation was t

prepared, see the attached copy.

The justification although techatcally adequate, relies on engineering. judgment i

to support the material (grease) which was analyzed and determine the type of grease in HCV-383-3 and HCV-383-4.

~

1

< @ i.1 87 12:02 OPPD BFWNDIES NO.002 003 GSE-FC-86-822 Page.

I Based on the Jco, continued operation to the 1987 refueling outage is

. Justified. SSE recommends all Narfak 2 gru se be changed out to Exxon Nebula l

EP-0 in the 1987 refueling outage.

Please review this letter and the JC0 carefully and indicate your concurrence.

If there any questions, please contact ESE.

S.1;. 'Cambhir I

Section Manager I

Generating Station Engineering i

l

1z ATTACitiENTS xt:

M. R. Core l

J. J. Foley i

J. J. Fisicaro 1

D. J. Munderloh I

J. R. Tucker i

EEQ File e

l l

I

  • 05/14/87 12:03 OPPD BRRO!ES NO.003 004 a

ELECTRICAL EQUIPMENT QUALIFICATION LIMITORQUE MOTOR OPERATOR LUBRICANT JUSTIFICATION FOR CONTINUED OPERATION I.

PURPOSE The purpose of this analysis is to determine if adequate justification exists to insure (1) that Texaco Marfak Multi Purpose 2 grease and (t) a mixture of Marfat Multi Purpose I and the grease previously instal-led.in three operators will not degrade resulting in the tenbility of the valves to perform their DBA/ Post 08A functions, (see Reference 4, 5 and 6).

11.

METMQ0 i

Material analysis,- test results, and functional requirements will be assessed to determine o be assessed as a group. perability. Valves with similar functlens will III.

INPUT DATA 1.

EEQ Manual 2.

E0P 1. 3, 5, & 20 3.

USAR Section 14 4.

NRC Inspection Report 50-269/86-16, 50-270/86-16, & 50-IP7/86-16 5.

EPRI EQAG Attachment to 6.

GSE-FC-86-783 7.

Texaco Letter - C. R. Olives te Mike Watson dated 3/10/83 8.

Bolt & Associated Letter - Robert 0. Bolt to J. E. Thomas of Duke Power dated 6/17/86 i

9.

Professional Service Industries, Inc., Report 174-53186-1

10. Rock Island Arsenal Laborat6ry Report 61-2132
11. Lubricant Summary Table 1
12. EEQ-EQOF Records File IV.

ANALYSIS A.

The Use of Marfak 2 Grease:

1.

Mtgh Pressure safety Injection Valves McV-314. Mct-315. and McV-321:

These valves open on receipt of a Safety Injec-tion Actuatine Signal (SIAS), (s:a Reference 2 and 3), la the first seconds of a LOCA or itSLB, and remain open natil long term core cooling is established, if required, during the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> followisp a LOCA, (see Reference 2). These valves must operate in a 1.0CNM5LA as defined'in Reference 1.

SCEW 4-29.

l

35/14/87 11 @

OPPD BRft4DlES NO.003 005 -

4 It should be noted that the one year operating time passive and is used in the ag(see Reference 1) is primarily ing calculation, the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> referenced previously is the active operation, based on the large Break LOCA long term core cooling, to prevent boron precipitation.

Other actions such as safety injection termination after leak isolation are not expected to stress the operator as severely as the targe Break LOCA, (see Reference 1 and 2).

A review of the environmental perforisance data for Marfak 2 indicates that no significant degradation is expected. Refer-7 indicates adequate thermal properties, with short time ence exposures to 350*F permissible.

The gear case is expected to protect the grease and gears from significant amounts of chen-ical spray and moisture, only the grease surface is expected to be expo, sed to any moisture, no degradation is expected.

Pressure on the grease is not expected to affect the proper-ties of the lubricant'.

It should be notad that the grease is expected to ersand thus further reducing 1.74x10}he potential for an itadiation Rads (1000 NR dose) y leakage.

levels of areexpectej. Refer-ence 7 indicates an acceptable dose of 2.3x10 Rads and Reference 8 supports the conclusion that the grease will not degrade preventing valve operation.

4 The 1985 refueling cutage inspectice required by the EEQ pro-gram (References 1 and 2) indicate that the grease has not degraded.

In summary, the HPSI va)wes 4rs expected to perform their intended function with Marfak 2 grease.

2.

How Pressure Safety Injection Valves HCV-327 HCV-329 4

HCV-331, and McV-333:

These valves open on receipt of a Safety Injection Actuation Si LOCA/MSLB (see Reference 2)gnal (SIAS) and remain open, for a

These.LPSI valves may.be esed to establish shutdowq cooltag within the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time frame if the Reactor Coolant Systhe condition permits (see refer-ence 2).

Environmental conditions are given in Reference 1 SCEW 4-34.

The LPs! valves have the similar operating requirements to

'the HPSI valves discussed in IV A.1 on that discussion these va(operating time 1000 HRS).

Based lves should perform the intended DBA/ Post LOCA DBA function.

l i

o

.... - 05/14/87 13:48 0::t 94HDIES W.004 E

3..

Shutdous Cooling (SDCS) Suction Line Isolation NCV-348 (see taference 11):

This valve may be used to conjunction with tw LpSI valves, (see Section IV A.t.), to establish Shutdows cooling, (see Reference 2 The environmental Reference).

conditians are given in 1,

SCOf 4 45.

The operating requirements are to open for shutdown cooling, there is no automatic operation in a 08A. Based on that similarity (note HCV-348 is qualified for 250 HR post DBA operatini vs. 3000 HR for the HPSI valves) MCV-348 can be considered operational for a 084.

4.

Shutdeus cooling Valve HCV-347s This valve is the second SOCS section line-isolation valve, located im Room 13 see Referesca 1 SCEW 4-44.

The operation of this is the sam,e as HCV-348 and is-related to the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> LICC requirement.

.Although listed as " mixed grease,' a laboretary test (see Referenta 9) indicates a sodium based grease which is the base of Marfak 2 (see Reference 8). Since HCV-347 la room 13 would see less severe DBA condition than HCV-348. HCV-347 is considered operattenal.

l 8.

Nixed Greases 1.

Post Accident Containment Sump Recirculatten Valves, HCV-383-3 and HCV-383-4:

These valves are reqeired to open at Recirculatten Actuation to provide the safety injection pumps l

with a section from the containment suus. This'esy occur from 20 minutes after a LOCA to several 'upers after a LOCA depending on break size, (see Reference 2). These valves are located. in the containment extension and see a temperature and ratation stress only, (see Reference 1 SCEW 4-50, note SCEW tausersture is incorrect, the value is 174*F).

{

i The type of grease in HCV-383-3 and HCV-383-4 at.the time of mixies is judged to be Marfak 2.

This judgeset is based on visual asamisation of saeples of grease taken darlag the 1983 refuellag mutage, and a recent laboratory test (Reference 9) of grease samples i

taken from HCV-347. The grease. samples taken to 1983 were very dark in color with the same appear-ance as Itarfak 2.

Laboratory tests on the HCV-347 lubricant which costained both ' original" and Harfak 2 tedicated virtu-ally teestical 'ceacentrations of the bottom of the grease. gelling agent (sodius) t at the top and Based en the similar appearasca and laboratory analysis, the lubricaet is believed to be Marfak 2.

t i

, ? # O M 4/87 32:48 OPPD BRAND!ES W.004 003

-:.. s o

All Limitorque valve operators appear to have had their lubri-cant t.hange out at some point in time as evidenced by the samples.

No maintenance records of this were found.

It ts known that Limitorque originally supplied the operators with l

I a Exxon Nebula EP calcime based lubricant which is tan in color.

It should be noted that industry records indicate that Limitorque supplied certain non-contalhaent operators with a Sun 011 grease dich is lithium based, which also sup-ports the change out judgeset.

Based on the above discussten it appears. that no mixing occur-i red and the Marfat 2 can be considered adequate. If for what-ever reason alther of the original greases remains in the i

operators. Reference 8 indicates adequate compatibility with either the Exxon or San 011 products. Sivan these condi-

- tions, the valves should operate satisfactorily.

A1TA00ENT 1.

NRC Inspection Report 50 269/86 16, 50-27tV86-16,.150-287/86-16.

2.

EPRI-EQAG Attachment 24 3.

GSE-FC-86 783 4.

Texaco Letter 5.

Bolt & Associated Letter 6.

Professional Service Industries, Inc., Report 174-53186-1 7.

Rock Island Arsenal Laboratory Report 61-1132 8.

Lubricant Summary Table 1 1

e 4

e

0 f

A

' AUG 111987-t In Reply Refer To':

Docket: 50-285/87-05 1

50-285/87 Omaha Public-Power District ATTN:

R.'L. Andrews, Division Manager-1 Nuclear Production-

)

1623 Harney. Street Omaha, Nebraska-68102 i

Gentlemen:

Thank you'for your letter of July 6,1987, in response to our telephone request for assurance of completion of short-term comitments.

Sincerely, OrQinct Stmed By J. E. Gac:larda J. E. Gagliardo, Chief Reactor Projects Branch I

'CC:

W. G. Gates, Manager Fort Calhoun Station P. O. Box 399 Fort Calhoun, Nebraska 68023

]

Harry H. Voigt, Esq.

LeBoeuf Lamb, Leiby & MacRae 1333 New Hampshire Avenue, NW Washington, D. C.-

20036 I

Kansas Radiation Contrb1 Program Director Nebraska Radiation Control Program Director bectoDMB-(IE01) bec distrib. by RIV:

RPB RRI R.D. Martin, RA RPSB SectionChief(RPB/B)

MIS System RIVFile[

DRSP RSTS Operator RSB Project Inspector, RPB D. Weiss, RM/ALF R. Hall T. Bournia, NRR Project Manager I

RIV: SRI PI C

B C:RPB PHHarrell/df hRPMullikin DRWunter JEGagl ' do

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'f;gg/87 q/sq/87 4/c.f/87 1/p/

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