ML17319A895

Safety Evaluation Re Environ Qualification of safety-related Electrical Equipment.Licensee Should Provide Info Re Equipment Qualification Program Deficiencies within 90 Days

ML17319A895
Person / Time
Site:	Cook
Issue date:	05/26/1981
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML17319A894	List: ML17319A893 ML17319A895 ML17319A896 ML17319A897
References
IEB-79-01B, IEB-79-1B, NUDOCS 8106010434
Download: ML17319A895 (26)

Text

Safety Evaluation Report By The Office of Nuclear Reactor Regulation Equipment gualification Branch For Indiana and Michigan Electric Company 0.

C.

Cook Units 1 and 2

Oocket No. 50-315/316 Ooolrota 48 4~~

Control

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'ONTENTS Page 1

Introduction..............

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Background......................

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Staff Evaluation.........

2 3.1 3.2 3.3 3.4 3.5 3.6 3.7 3.8 Completeness of Safety-Related Equipment.....

Service Conditions...............

Temperature,

Pressure, and Humidity Conditions Inside Containment...........................

Temperature,

Pressure, and Humidity Conditions Outside Containment...................

Submergence............................

Chemical Spray...............................

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gualification of Equipment.................................

7 4.1 4.2 4.3 Equipment Requiring Immediate Corrective Action....

Equipment Requiring Additional Information and/or Corrective Action..................................

Equipment Considered Acceptable or Conditionally Acceptable......

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Deferred Requirements......................................

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Conclusions.........

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9 APPENDIX A Equipment Requiring Immediate Corrective Action APPENDIX B Equipment Requiring Additional Information and/or Corrective Action APPENDIX C Equipment Considered Acceptable or Conditionally Acceptable APPENDIX D Safety-Related Systems List :

Letter from the Foxboro

Company, dated March 2, 1981, regarding deficiencies in the Model E11 and E13 transmitters

SAFETY EVAL'UATION REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION EQUIPMENT QUALIFICATION BRANCH FOR INDIANA AND MICHIGAN ELECTRIC COMPANY D.

C.

COOK UNITS 1 AND 2 DOCKET NO. 50-315/316 ENVIRONMENTAL QUALIFICATION OF SAFETY"RELATED ELECTRICAL EQUIPMENT 1

INTRODUCTION General Design Criteria 1 and 4 specify that safety-related electrical equip-ment in nuclear facilities must be capable of performing its safety-related function under environmental conditions associated with all normal, abnormal, and accident plant operation.

In order to ensure compliance with the criteria, the NRC staff required all licensees of operating reactors to submit a reevalu-ation of the qualification of safety-related electrical equipment which may be exposed to a harsh environment.

2 BACKGROUND On February 8, 1979, -the NRC Office of Inspection and Enforcement (IE) issued to all licensees of operating plants (except those included in the systematic evaluation program (SEP))

IE Bulletin IEB 79-01, "Environmental gualification of Class IE Equipment."

This bulletin, together with IE Circular 78-08 (issued on May 31, 1978), required the licensees to perform reviews to assess the ade-quacy of their environmental qualification programs.

Subsequently, Commission Memorandum and Order CLI-80-21 (issued on May 23, 1980) states that the DOR guidelines and portions of NUREG-0588 (which were issued on January 14, 1980, as enclosures 4 and 5 to IEB-79-01B) form the requirements that licensees must meet regarding environmental qualification of safety-related electrical equipment in order to satisfy those aspects of 10 CFR 50, Appendix A, General Design Criterion (GDC)-4.

This order also requires the staff to complete safety evaluation reports (SERs) for all operating plants by February 1,

1981.

In addition, this order requires that the licensees have qualified safety-related equipment installed in their plants by June 30, 1982.

Supplements to IEB 79-01B were issued for further clarification and definition of the staff's needs.

These supplements were issued on February 29, September 30, and October 24, 1980.

In addition, the staff issued orders dated August 29, 1980 (amended in September 1980) and October 24, 1980 to all licensees.

The August order required that the licensees provide a report, by November 1, 1980, documenting the quali-fication of safety-related electrical equipment.

The October order required the establishment of a central file location for the maintenance of all equipment-qualification records.

The central file was mandated to be established by December 1, 1980.

The order also required that all safety-related electrical equipment be qualified by June 30, 1982.

In response, the licensee submitted information through letters dated March 7, May 7, June 5,

and October 31, 1980.

2.1

~Pur ose The purpose of this SER is to identify equipment whose qualification program does not provide sufficient assurance that the equipment is capable of performing the design function in hostile environments.

The staff position relating to any identified deficiencies is provided in this report.

2.2

~Sco e

The scope of this report is limited to an evaluation of the equipment which must function in order to mitigate the consequences

.of a loss-of-coolant accident

."': (L'OCA)--or.a:high-.energy-l'ine-.break'(HELB) acciderit.," inside 'or'roout&de"co'ntainmbht while subjected to the hostile environments associated with these accidents..

STAFF EVALUATION The staff evaluation of the licensee's response included an onsite inspection of selected Class IE equipment and an examination of the licensee's report for completeness and acceptability.

The criteria described in the DOR guidelines and in NUREG-0588, in part, were used as a basis for the staff evaluation of the adequacy of the licensee's qualification program.

The NRC Office of Inspection and Enforcement performed (1) a preliminary evalu-ation of the licensee's

response, documented in a technical evaluation report (TER) and (2) an onsite verification inspection (June 16-17, 1980) of selected safety-related electrical equipment.

The engineered safety features actuation, air-recirculation, and containment isolation systems were inspected at Unit 1; the containment spray system was inspected at Unit 2.

The inspection at both units verified proper installation of equipment, overall interface integrity, and manufacturers'ameplate data.

The manufacturer's name and model number from the nameplate data were compared to information given in the Component Evaluation Work Sheets (CES) of the licensee's report.

The site inspection is documented for Units 1 and 2 in an onsite inspection report,(from D.

W.

Hayes to E.

L. Jordan, dated July 1, 1980).

No deficiencies were noted.

For this review, the documents referenced above have been factored into the overall staff evaluation.

3. 1 Com leteness of Safet -Related E ui ment In accordance with IEB 79-01B, the licensee was directed to (1) establish a

list of systems and equipment that are required to mitigate a LOCA and an HELB and (2) identify components needed to perform the function of safety-related display information, post-accident sampling and monitoring, and radiation monitoring.

The staff developed a generic master list based upon a review of plant safety analyses and emergency procedures.

The instrumentation selected includes para-meters to monitor overall plant performance as well as to monitor the performance of the systems on the list.

The systems list was established on the basis of the functions that must be performed for accident mitigation (without regard to location of equipment relative to hostile environments).

The list of safety-related systems provided by the licensee was reviewed against the staff-developed master list.

Based upon information in the licensee s submittal, the equipment location references, and in some cases subsequent conversations with the licensee, the staff has verified and determined that the systems included in the licensee's submittal are those required to achieve or support:

(1) emergency reactor

shutdown, (2) containment isolation, (3) reactor core cooling, (4) containment heat removal, (5) core residual heat removal, and (6) prevention of signifi-cant release of radioactive material to the environment.

The staff therefore concludes that the systems identified by the licensee (listed in Appendix D)

.are acceptable, with..the exception 'of those, items discusse'd in-Section.5 "of

'his report.

Di.splay. i.nstrumentation which provides information for. the reactor opei ators'o aid them in the, safe handling of the plant was not specifically identified by the licensee.

A complete list of all display instrumentation mentioned in the LOCA and HELB emergency procedures must be provided.

Equipment qualifi-cation information in the form of summary sheets should be provided for all components of the display instrumentation exposed to harsh environments.

Instrumentation which is not considered to be safety related but which is men-tioned in the emergency procedure should appear on the list.

For these instru-

ments, (1) justification should be provided for not considering the instrument safety related and (2) assurance should be provided that its subsequent failure will not mislead the operator or adversely affect the mitigation of the conse-quences of the accident.

The environmental qualification of post-accident sampling and monitoring and radiation monitoring equipment is closely related to the review of the TMI Lessons-Learned modifications and will be performed in conjunction with that review.

The licensee identified 125 items of equipment in Unit 1 and 137 items in Unit 2 which were assessed by the staff.

Because Units 1 and 2 are nearly identical,"

the review can be performed as one.

Differences in the units will be identified by a parenthetical expression, with the applicable unit number enclosed.

3.2 Service Conditions Commission Memorandum and Order CLI-80-21 requires that the DOR guidelines and the "For Comment" NUREG-0588 are to be used as the criteria for establishing the adequacy of the safety-related electrical equipment environmental quali-fication program.

These documents provide the option of establishing a bounding pressure and temperature condition based on plant-specific analysis identified in the licensee's Final Safety Analysis Report (FSAR) or based on generic profiles using the methods identified in these documents.

h On this basis, the staff has

assumed, unless otherwise noted, that the analysis for developing the e'nvironmental envelopes for D.

C.

Cook Units 1 and 2, relative to the temperature,

pressure, and the containment spray caustics, has been per-formed in accordance with the requirements stated above.

The staff has reviewed Except that (1) main steam and narrow range RCS temperature transmitters are not part of Unit 2's engineered safeguards actuation and (2) Unit 1 does not have a dedicated post-accident monitoring system.

the qualification documentation to ensure that the qualification specifications envelope the conditions established by the licensee.

In addition, the staff

assumed, and requires the licensee to verify, that the containment spray system is not subjected to a disabling single-component failure.

Equipment submergence has also been addressed where the possibility exists that flooding of equipment may result from HELBs.

3.3 Tem erature Pressure and Humidit Conditions Inside Containment The licensee has provided the results of the accident, analysis as follows:

~T(

N P

i id'I LOCA

.'Lower Compartment 241 '"

'. 10' ll}0

.Upper Compartment

.130

,8 100.-

HSLB Lower Compartment 328 9.9 100 Upper Compartment 158 8.1 100 The staff has concluded that the minimum temperature profile for equipment qualification purposes should include a margin to account for analytical uncertainties in the calculated temperature profiles for postulated accidents.

The licensee's minimum temperature profile for qualification purposes is based on a conservative MSLB analytical model that results in temperatures higher than what might realistically be expected and is acceptable.

The staff has also concluded that, for the equipment which is qualified for the LOCA environment only, use of the steam saturation temperature corresponding to the total building pressure (partial pressure of steam plus partial pressure of air) versus time will provide an acceptable margin for a postulated LOCA environmental effect on equipment.

The licensee's specified temperature (service condition) of 241.F for the lower compartment during a LOCA satisfies the above requirement and is therefore acceptable.

However, the specified temperature (service condition) of 130~F for the upper compartment does not satisfy the above requirement.

A saturation temperature corresponding to pressure profile (234'F peak temperature at 8 psig) should be used instead.

The staff also requires that, for equipment in the upper compartment which is used for the MSLB, the same service conditions as for LOCA conditions in the upper compartment should be used.

The licensee should update his equipment summary tables to reflect this change.

If there is any equipment that does not meet the staff position, the licensee must either provide justification that the equipment will perform its intended function under the specified conditions or propose corrective action.

3.4 Tem erature Pressure and Humidit Conditions Outside Containment The licensee has provided the temperature,

pressure, humidity and applicable environment associated with an HELB outside containment.

The following areas outside containment has been addressed:

(1)

Auxi 1 iary bui 1 ding The staff has verified that the parameters identified by the licensee for the MSLB are acceptable.

The maximum submergence levels have been established and assessed by the licensee.

Unless otherwise

noted, the staff assumed for this review that the methodology employed by the licensee is in accordance with the appropriate criteria as estab-lished by Commission Memorandum and Order CLI-80-21.

The licensee.'s value for maximum submergence is at elevation $14 ft 0'in.

Equip-ment below.this level has been identified by the licensee, along with the.pro-

.'posed corrective'ction..

The licensee. identified '29 safety.-related electrical components for Unit 1 and 35 for. Unit 2 as haying the potential for becoming submerged after a postulated event.'ost of these components are electrical cables (power, control, instrument) inside floodup tubes.

However, no evidence of environmental qualification of these floodup tubes was provided by the licen-see.

Furthermore, some electrical penetrations, transmitters, cable terminations, and valve motor operators have the potential of being submerged.

The licensee stated that the components in question perform their function immediately after the accident, long before they are submerged, and are not required to operate after a

LOCA.

The staff considers that a component can be exempt from submer-gence qualification if the licensee can provide an assessment of the failure modes associated with the submergence of the component.

The licensee should also provide assurance that the subsequent failure of this component will not adversely affect any other safety functions or mislead an operator.

Additionally, the licensee should discuss operating time, across the spectrum of events, in relation.to the time of submergence.

If the results of the licensee's assessment are acceptable, then this component may be exempt from the submergence param-eter of qualification.

It is not clear from the information submitted that submergence of safety-related electrical equipment outside of containment was addressed.

The licensee should address this area more specifically in the 90-day response and upgrade the CES as appropriate.

The licensee's FSAR value for the chemical conc'entration is 2000 ppm boric acid solution;

however, the exact volume percent and pH values were not provided by the licensee.

Therefore, for the purpose of this review, the effects of chemical spray will be considered unresolved.

The staff will review the licensee's response when it is submitted and discuss the resolution in a supplemental report.

3. 7

~Ain Section 7 of the DOR,guidelines does not require a qualified life to be estab-lished for all safety-related electrical equipment.

However, the following actions are required:

"5-

(1)

Make a detailed comparison of existing equipment and the materials identified in Appendix C of the DOR guidelines.

The first supplement to IEB-79-01B requires licensees to utilize the table in Appendix C and identify any additional materials as the result of their effort.

(2)

Establish an ongoing program to review surveillance and maintenance records to identify potential age-related degradations.

(3)

Establish component maintenance and replacement schedules which include considerations of aging characteristics of the installed components.

'-., The.licensee identified a. number of equipment items 'for which'a 'specii'ied qua1.i-. "'""

fied life was established (for examples, 5 years, 15 years, or 40 years).

In

~ its assessment of these submittals, the staff did not review the adequacy of'.

.the methodology nor the basis used to arrive at these values; the staff.has assumed that the established. values are based on state-of-the-..art technology and are acceptable.

For this review,

however, the staff requires that the licensee submit supple-mental information to verify and identify the degree of conformance to the above requirements.

The response should include all the equipment identified as required to maintain functional operability in harsh environments.

The licensee indicated that this phase of the response is outstanding and that the review is in progress.

The staff will review the licensee's response when it is submitted and discuss its evaluation in a supplemental report.

3.8 Radiation (Inside and Outside Containment The licensee has provided values for the radiation levels postulated to exist following a LOCA.

The application and methodology employed to determine these values were presented to the licensee as part of the NRC staff criteria con-tained in the DOR guidelines, in NUREG-0588, and in the guidance provided in IEB-79-01B, Supplement 2.

Therefore, for this review, the staff has assumed

that, unless otherwise noted, the values provided have been determined in accor-dance with the prescribed criteria.

The staff review determined that the values to which equipment was qualified enveloped the requirements identified by the licensee.

The values required by the licensee inside containment are an integrated dose of 4 x 10 to 1.5 x 10 rads:

The radiation service condition provided by the licensee is lower than provided in the DOR guidelines (4 x 10~ rads) for gamma and beta radiation.

The licensee is requested to either provide justification for using the lower service condition or use the service condition provided in the DOR guidelines for both gamma and beta radiation.

If the former option is

chosen, then the analysis--including the basis, assumptions, and a sample calculation should be provided.

A required value outside containment of 1. 7 x 10~ rads has been used by the licensee to specify limiting radiation levels within the auxiliary building.

This value appears to consider the radiation levels influenced by the source term methodology associated with post-LOCA recirculation fluid lines and is therefore acceptable.

4 QUALIFICATION OF E(UIPMENT The following subsections present the staff's assessment, based on the licensee's submittal, of the qualification status of safety-related electrical equipment.

The staff has separated the safety-related equipment into three categories:

(l) equipment requiring immediate corrective action, (2) equipment requiring additional qualification information and/or corrective action, and (3) equip-ment considered acceptable if the staff s concern identified 'in Section 3.7 is satisfactorily resolved.

In its.assessment of the licensee'.s submittal, the NRC staff..did; not.revi.ew.

'the methodolo'gy employed to determine the values established by the licensee.

However, in reviewing the data sheets, the. staff made a determination as to the 'stated conditions presented by the licens'ee;.

Additionally; the staff has'..'ot completed its review of supporting documentation referenced by the licen-'ee (for example; test reports).

It is expected that when the review of test reports is complete, the environmental qualification data bank established by the staff will provide the means to cross reference each supporting document to the referencing licensee.

If supporting documents are found to be unacceptable, the licensee will be required to take additional corrective actions to either establish qualification or replace the item(s) of concern.

This effort'-began in early 1981.

An appendix for each subsection of this report provides a list of equipment for which additional information and/or corrective action is required.

Where appropriate, a reference is provided in the appendices to identify deficiencies.

It should be noted, as in the Commission Memorandum and Order, that the deficien-cies identified do. not necessarily mean that equipment is unqualified.

However, they are cause for concern and may require further case-by-case evaluation.

4. 1 E ui ment Re uirin Immediate Corrective Action Appendix A identifies equipment (if any) in this category.

The licensee was asked to review the facility's safety-related electrical equipment.

The licensee's review of this equipment has not identified any equipment requiring immediate corrective action; therefore, no licensee event reports (LERs) were submitted.

In addition, in this review, the staff has not identified any safety-related electrical equipment which is not able to perform its'ntended safety function during the time in which it must operate.

4.2 E ui ment Re uirin Additional Information and/or Corrective Action Appendix B identifies equipment in this category, including a tabulation of deficiencies.

The deficiencies are noted by a letter relating to the legend (identified below), indicating that the information provided is not sufficient for the qualification parameter or condition.

le<eend R

- radiation T

- temperature

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gT

- qualification time

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-f. ~

~

RT

- required time P

- pressure H

- humidity CS

- chemical spray A

- material-aging evaluation; replacement schedule; ongoing equipment surveillance S

- submergence M

- margin I

- HELB evaluation outside containment not completed gM

- qualification method RPN - equipment relocation or replacement; adequate schedule not proVided EXN -..exempted.equipment justification.inadequate SEN - separate-effects qualification justification inadequate

'I

.- qualiffcation infarmation being developed RPS - equipment relocation or.'eplacement'chedule provided As noted in Section 4'; these deficiencies do not necessar ily mean that the e'qu ip-ment is unqualified.

However, 'the deficiencies are cause for concern and require.

further case-by-case evaluation.

The staff has determi ned that an acceptab 1 e bas i s to exempt equipment from qual ificati on, in whole or part, can be established provided the fol 1 owing can be established and verified by the licensee:

(1)

Equipment does not perform essential safety functions in the harsh envi ron-ment, and equipment failure in the harsh environment will not impact safety-rel ated functions or mislead an operator.

(2a) Equipment performs its function before its exposure to the harsh environ-ment, and the adequacy for the time margin provided is adequately justified,

and (2b) Subsequent fai 1 ure of the equipment as a result of the harsh environment does not degrade other safety functions or mi s 1 ead the oper ator.

(3 )

The safety-rel ated function can be accomp 1 ished by some other designated equipment that has been adequately qual ified and satisfies the single-failure criterion.

(4)

Equipment wi 1 1 not be subjected to a harsh envi ronment as a result of the postu 1 ated acci dent.

The 1 icensee is, therefore, required to supplement the informati on presented by providi ng reso 1 utions to the deficienci es identi fied; these resol utions should incl ude a descri ption of the corrective action, schedul es for its completion (as applicable), and so forth.

The staff will review the 1 icensee '

response

, when it is submi tted, and discuss the resol ution in a s uppl cmental report.

It should be noted that in cases where testing is being conducted,

a condition may arise which res u 1 ts in a determination by the licensee that the equipment does not satisfy the qual ificati on test r equi rements.

For that equipment, the licensee wi 1 1 be required to provi de the proposed corrective acti on,

on a time ly basis, to ensur e that qual ificati on can be estab 1 ished by June 30, 1982.

4.3 E ui ment Considered Acce table or Conditionall Acce table Based on the staff review of the licensee s submittal, the staff identified the equipment in Appendix C as (1) acceptable on the basis that the qualifi-cation program adequately enveloped the specific environmental plant parameters, or (2) conditionally acceptable subject to the satisfactory resolution of the staff concern identified in Section 3.7.

/

For the equipment identified as conditionally acceptable, the staff determined that the licensee did not clearly (l). state that. an. equipment. material. eval.uation was conducted. to ensure "that no known materials susceptib'le to degradation.because of aging have been Used;

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~

(2) establish an ongoing program to review the plant surveillance and main-

'enance records in order to identify equipm'ent degradation which may be age related, and/or (3) propose a maintenance program and replacement schedule for equipment identified in item 1 or equipment that is qualified for less than the

. life of the plant.

The licensee is, therefore, required to supplement the information presented for equipment in this category before full acceptance of this equipment can be established.

The staff will review the licensee's response when it is sub-mitted and discuss the resolution in a supplemental report.

5 DEFERRED REQUIREMENTS IEB 79-01B, Supplement 3 has relaxed the time constraints for the submission of the information associated with cold shutdown equipment and TMI lessons-learned modifications.

The staff has required that this information be provided by February 1, 1981.

The staff will provide a supplemental safety evaluation addressing these concerns.

6 CONCLUSIONS The staff has determined that the licensee's listing of safety-related systems and associated electrical equipment whose ability to function in a harsh environment following an accident is required to mitigate a

LOCA or HELB is complete and acceptable, except as noted in Section 3 of this report.

The staff has also determined that the environmental service conditions to be met by the electrical equipment in the harsh accident environment are appropriate, except as noted in Section 3 of this report.

Outstanding information identified in Section 3 should be provided within 90 days of receipt of this SER.

The staff has reviewed the qualification of safety-related electrical equip-ment to the extent defined by this SER and has found no outstanding items which would require immediate corrective action to ensure the safety of plant operation.

However, the staff has determined that many items of safety-related electrical equipment identified by the licensee for this review do not have adequate documentation to ensure that they are capable of withstanding the

harsh environmental service conditions.

This review was based on a comparison of the qualification values with the specified environmental values required by the design, which were provided in the licensee's summary sheets.

Subsection

4. 2 identified deficiencies that must be resolved to establish the qualification of the equipment; the staff requires that the information lack-ing in this category be provided. within 90 days of receipt of this SER.

Within this period, the licensee should ei,ther. provide documentation of the missing qualification information which demonstrates that such equipment meets the DOR guidelines or NUREG-0588 or commit to a corrective action (requalification, replacement, relocation, and so forth) consistent with the requirements to establi.sh qualification by. June 30; 1982;" If the latter option is chosen;

-the

"'icensee must provide justification for operation until such.corrective action is complete.

1 Subsection 4.3 identified acceptance and conditional acceptance based on. noted deficiencies.

Where additional 'information is required, the licensee should respond within 90 days of receipt of this SER by providing assurance that these.

concerns will be satisfactorily resolved by June 30, 1982.

The staff issued to the licensee Sections 3 and 4 of this report and requested, under the provisions of 10 CFR 50.54(f), that the licensee review the deficiencies enumerated and the ramifications thereof to determine whether safe operation of the facility would be impacted in consideration of the deficiencies.

The licensee has completed a preliminary review of the identified deficiencies and has determined that, after due consideration of the deficiencies and their ramifications, continued safe operation would not be adversely affected.

Based on these considerations, the staff concludes that conformance with the above requirements and satisfactory completion of the corrective actions by June 30, 1982 will ensure compliance with the Commission Memorandum and Order of May 23, 1980.

The staff further concludes that there is reasonable assurance of continued safe operation of this facility pending completion of these corrective actions.

This conclusion is based on the following:

(1) that there are no outstanding items which would require immediate correc-tive action to assure safety of plant operation (2) some of the items found deficient have been or are being replaced or relocated, thus improving the facility s capability to function following a

LOCA or HELB (3) the harsh environmental conditions for which this equipment must be qualified result from low-probability events; events which might reasonably be antici-pated during this very limited period would lead to less demanding service conditions for this equipment.

.APPENDIX A-Equipment Requiring Immediate Corrective Action (Category 4.1)

Equipment Descri tion Manufacturer Com onent No.

\\

,0 No equipment in this. category for D.C.

Cook Units 1 and 2 '

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~

APPENDIX B

Equipment Requiring Additional Information and/or Corrective Action (Category 4.2)

LEGEND:

Desi nation for Deficienc R '-

T-QT

. RT'-

p-H-

CS-A-

S-M-I-QM-RPN" EXN-SEN "

QI-RPS-Radiation

~

='

~"

Temperature Qualification time Requir'ed time Pressure Humidity Chemical spray Material aging evaluation, replacement

schedule, ongoing equipment surveillance Submergence Margin HELB evaluation outside containment not completed Qualification method Equipment relocation or replacement, adequate schedule not provided Exempted equipment justification inadequate Separate effects qualification justification inadequate Qualification information being developed Equipment relocation or replacement schedule provided Equipment Descri tion Manufacturer Com onent No.

Deficienc Control Cable Control Cable Control Cable Power Cable Control Cable Control Cable Control Cable Control Cable Control Cable Continental Continental GE Anaconda Continental GE Continental GE Continental 3119 3120 3120 3120 3121 3121 3122 3122 3123 QT,CS,R,M,A,S,QM QT,A,QM QT,A,QM QT,A QT,CS,R,M,A,S,QM QT,CS,R,M,A,S,QM QT,CS,R,M,A,S,QM QT,CS,R,M,A,S,QM QT,A,QM

APPENDIX B (Continued)

Equipment Descri tion Manufacturer Com onent No.

Deficienc Control Cable Instrument Cable GE 3123 Boston Insulated 3064 Wire Co.

QT,A,QM QT,CS,M,A,S,QM Instrument-Cable

.Rockbesfos"

-"'.* 3064 QT;CS,A,'S,QM instrument Cable

,Instrument Cable Samuel Moore 8.Co.

3075 Continental "3075

'QT,CS,A,S,QM V

QT,A,QM Instrument Cable Instrument Cable Boston Insulated Wire Co.

Cerro Wire 8 Cable Co.

307$

3077 QT,CS,R,M,A,QM QT,CS,A,S,QM Instrument Cable Instrument Cabl'e Power Cable~

)

Power Cable Continental Okonite Okonite 3077 324 324/IM0-325, 326 Samuel Moore 8 Co.

3077 QT,CS,A,S,QM QT,A,QM RT,QT,M,A RT,QT,M,CS,A,S,QM Power Cable Power Cable Power Cable Instrument Cable Power Cable Power Cable Power Cable Power Cable Power Cable~ )

Essex Okonite Anaconda Okonite Anaconda Essex Kerite Anaconda Kerite 324 399 3102 3102 3116 3116 3116 3103 3127 T,P,QT,R,A,QM QT,CS,M,A,S,QM QT,T,P,A,QM QT,A QT,CS,A,S,QM QT,CS,A,S,QM QT,CS,R,M,A,S,QM QT,T,P,A,QM QT,R,A,S,QM (1) Unit 1 B-2

APPENDIX B (Continued) quspment Descri tion Manufacturer Com onent No.

Oeficienc Electrical Penetrations Conax Corp.

EP-1 QT,CS,A,S,QM Conax Corp.

E13DM-HSAHI T, A,QM, R (MCA)

Electrical

. EP-2 thru QT,CS,A,S,QM Penetrations EP-14 Fan Motors

'estinghouse TBDP CS,A

~

I Hydrogen: Kecombiner

.-.'.Westinghouse

'NA', IO; HR-1;2,

.QT;CS,A Differential ITT Barton '64

'T,T,P,M,CS;A,S,QM Pressure Transmitter "Differential Foxboro

- Pressure Transmitter Differential Pressure Transmitter Differential Pressure Switch "Differential Pressure Transmitter "Differential Pressure Transmitter Differential.

Pressure Transmitter'TT Barton ITT Barton Foxboro Foxboro ITT Barton 368 289A/199 E13OH-HSAHI MCA E13DH"HSAHI MCA 332 QT,T,P,H,A,QM,RPN QT,P,M,A,QM A,S,QM,R A,S,QM,T,R QT,P,M,H,A,QM

• Differential Pressure Transmitter "Differential Pressure Transmitter "Differential Pressure Transmitter Foxboro Foxboro Foxboro E13DM-HSAMI QT, P,M,A,QM, R EllGM-HSAEl QT,A, QM, R (MCA)

E11GM-HSAE1 QT, T, P,A,QM, R Pressure Transmitter'TT Barton 763 QT,P,CS,M,A,QM RTD RTO Rosemount/Sostman 176KF/11834B QT,CS,A,QM Rosemount/Sostman 176KS/11901B

. QT,, T, CS,M, A, QM See'ttachment 1:

Foxboro letter (3/12/81),."Potential. Deficiency Affecting:

Foxboro'ransmitters; fear.'corrective" action:-:

B-3

APPENDIX B (Continued)

Equipment Descri tion Manufacturer Com onent No.

Deficienc Radiation Monitor Westinghouse 1101 T, P,QT, RT,M, CS,A,QM RPN Pressure Switch Mercoid DA-7031"153 QT, T, P,A, QM, RPN

" Limit Switch Pump. Motor C

Electro-Pneumatic Transducer NAMCO Reliance I ~

~ Fisher

~

EA180

~

'810P I

546 RT; CS,'A

.. 'A,QM,QI,

~

QT,A,QM

~ Solenoid Valve Solenoid Solenoid Valve Automatic Switch Co.

Automatic Switch Co.

Automatic Switch Co.

HP"8300C58RU QT,T,P,H,A,QM,RPN HT-8300B58RU HT-8316B17 QT, M,T, P, A, QM NP-831654V QT, A,QM, CS Control Cable Termination NA NA QT,CS,R,M,A Control Cable Termination At valve T,P,A,QM motor operator Control Cable Termination NA Various QT,A,QM Control Cable Termination Control Cable Termination NA NA At terminal QT,A,QM block At solenoid QT,T,A,QM Instrumentation Termination RTD Termination Penetration Terminations NA Barton Instrument Termination RTD termina-tion Penetration termination QT,CS,M,R,A,S,QM QT,CS,R,A,S,QM QT,A,S,QM B-4

APPENDIX B (Continued)

Equipment Descri tion Instrument Cable Termination Manufacturer Com onent No.

Deficienc Splice at QT,CS,M,R,A,S,QM penetration Instrument Termination Power Cable

,Termination

~ 4

~

FoxboroNA'A Spliced to standard.

." kapton QT,CS,A,S,QM QT,.R,M,A,S,QM Power Cable Termination Spliced to QT,R,M,A,QM standard h)palon Termination NA At value motor opera-

tors, hydrogen recombiners, fan motors QT,CS,R,M,A,S,QM Cable Termination NA Valve Motor Operator Limitorque Valve Motor Operator Limitorque SMB"1,-00,"2/

IMO"51,52,53 54,128; ICM" 111,129 CS,A,S SMB-1/IM0-315, CS,A,QM 316,325)326 At pump motor QT,A,QM Valve Motor Operator Limitorque Valve Motor Operator Limitorque SMB"00/QCM-250 Various outside cont.

CS,A,S T,A,QM Instrument Cable(

~

Instrument Cable( )

Instrument Cable Instrument Cable Boston Insulated Mire Co.

Raychem'aychem Continental 3077 3111 3112 3069 QT,CS, R,M,A,S,QM QT,CS,A,S QT,CS,A,S QT,T,P,A,QM (2) Unit 2 B"5

APPENDIX B (Continued)

Equipment Descri tion Manufacturer Com onent No.

Deficienc Power Cable Power Cable Power Cable Power Cable

. Power 'Cable~

~'",

Power Cabl e Power Cable Power Cable Differential Pressure Transmitter~

~

Cyprus Cyprus Cyprus Anaconda

".Cy'prus" Essex Anaconda Anaconda ITT Barton 324 325 347 0

347

- 3102 324 3102 3103 764 QT,T,A,QM QT,T,A,QM QT,CS,A,S,QM QT,CS,A,S,QM

QT;T,'A;QM "'

QT,T,P,A,QM QT,T,P,A,QM QT,T,P,A,QM QT,P,CS,A,S,QM (2) Unit 2.

B-6

'APPENDIX C

Equipment Considered Acceptable or Conditionally Acceptable (Category 4.3)

LEGENO:

Desi nation for Deficienc R - Radiation T, - Temperature gT - gual ificati on. time

. - RT."; Required:time.

'P

-,'Pressure'

- Humidity CS - Chemical spray A - Material aging evaluation, replacement

schedule, ongoing equipment surveillance S - Submergence M - Margin I - HELB evaluation outside containment not completed gM - gualification method RPN - Equipment relocation or replacement, adequate schedule not provided EXN Exempted equipment justification inadequate SEN - Separate effects qualification justification inadequate gI - qualification information being developed RPS - Equipment relocation or replacement schedule provided Equipment Descri tion Grease Pump Grease Motor Oil Manufacturer Mobil Mobil Mobil Com onent No.

Deficienc Mobilux EP-2 Mobilux ¹2 D.T.E. Oil Medium Motor Grease Pump Oil Mobil Mobil Mobilux ¹2 D.T.E.

797 Oil Coupling Grease Mobil Coupling Grease Motor Oil Coupling Grease Mobil Mobil D. T.E. Oil Heavy Medium Sovarex L-0

g APPENDIX C (Continued)

Equipment Descri tion Pump Motor Manufacturer Mestinghouse Com onent No.

Deficienc 5808Z,5009H 5009-p24 Control Cable.

Termination Valve Motor Operator Valve Motor Operator NA Cable Term.

at Valve

'L

~

Limitorque SMB-000/VMO-101,102

'imitor'que.

.. Various outside cont.

A Valve Motor Operator Limitorque Valve Motor Operator Limitorque SMB-00/NMO-151,152,153 SMB"2/ICM-306,305 C-2

~ APPENDIX D

Safety-Related Systems List~

Function System Emergency Reactor Shutdown Reactor. Coolant

. Reactor Protection Safeguards Actuation Chemical and Volume Control Containment Isolation Main Steam Main Feedwater Chemical and Volume Control Residual Meat Removal Reactor Cor e Cooling

. Reactor Coolant Pump Seal Mater Ice Condenser Refri'gerant Supply Containment Purge Emergency Core Cooling Auxiliary Feedwater High Pressure Injection Intermediate Pressure Injection Low Pressure Injection Accumulators

~he N

C staff recognizes that there're differences in nomenclature of systems because of plant vintage and engineering design; consequently some systems per-forming identical or similar functions may have different names.

In those instances it was necessary to verify the system(s) function with the responsible IE regional reviewer and/or the licensee.

~

~

s I'-1

APPENDIX D (continued)

Function System s ~ (

a Containment Heat Removal Core Residual'eat Removal Containment Spray Containment Ventilation v

Containment Sump

~ ~ " ".

Recirculation Residual Heat. Removal Power Operated Relief Valves Prevention of Significant Release of Radioactive Material to Environment Supporting Systems Main Feedwater Auxiliary Feedwater Main Steam Component Cooling Mater Essential Service Water Containment Spray (Iodine Removal)

Hydrogen Control Post Accident Monitoring Containment Radiation Sampling~

Emergency Power Control Room Habitability Remote Shutdown Monitoring To be covered as part of TMI-2 Lessons Learned.

I~

s a

'J

~

~

D-2

I The Foxboro Company 12 March 19S1 ATTACHMENT 1 Foxboro, MA02035 U.SW (617) 543-8750

Subject:

Potential Deficiency'ffecting Foxboro Transmitteis, Model Numiers N-E11, N-E13 or Ell, E13 with.suffix

'. Codes

./MCUS;./MCA/RRW, or'.-(MCA/RR 4

'I Gentlemen:

Our records indicate that you have received one or more of the Foxboro model numbered transmitters listed above.

This letter is to notify you that two deficiencies have been discovered in some of these transmitters which may exist in the units shipped to you.

The transmitters in question operate at a signal level of 10-50mA.

Similar model numbered units operating at 4-20mA are not affected.

The first issue involves the possible use of incorrect insulating sleeving on transistor and zener diode lead" wires in the amplifier.

Th'e second issue involves the use of a specific vendor's capacitor which is not hermetically sealed (although claimed to be so}.

As a result, the capacitor electrolyte can leak under. adverse service conditions, specifically heat and time.

The failure mode is a decrease in resistance across the capacitor resulting in electrical leakage.

The transmitter operation can be affected by limiting the output to something less than full value which, in time, can degrade to no output at all.

Insulatin Sleevin Radiation resistant sleeving consisting of a silicone coated glass fiber braid has been substituted by a teflon sleeving in some transmitters.

Tests have shown that teflon will become brittle and deteriorate with a substantial integrated radiation dose.

Foxboro testing has demonstrated that the teflon sleeving used in these devices willwithstand an integrated dose of 10 megarads with no noticeable deterioration.

Tests to 200 megarads produce the brittle conditions which can result in the teflon flaking from the wires.

Based on these tests, operating plants not expected to exceed an integrated dose of 10 megarads have no potential problem and no action is zequired.

@here the integrated dose rate could exceed 10 megarads, then units in service should be inspected to determine if the proper insulating material has been used.

This can be accomplished by opening the transmitter in accordance with Foxboro Master Enstzuction MX 20;3.45.

The amplifier cover must be removed exposing the amplifier assembly.

~ At one end of the assembly, a transistor and a zener diode are mounted in the base casting which serves as a hea" ~ink.

The insulating material in question is a sleeving sl'pped over the lead ~ires from these'two co'mponents.

.-.The proper material is. white and: heavy. looking.

. Positive.;

Q2CBO

~ V Page.

2 12 Harch. 1981 Sub]ect:

identification can be made by inspecting one end of the material to establish that the outer material covers an inner braid.

Teflon, if used, will be a single layer material and could be either clear or white.

If improper insulation is present, then the corrective action is to replace the-amplifier (Foxboro P/N N0148PW).

Replacement amplifiers can be purchased from

., your local Foxboro Sales, or:Service Representatives.

.If you prefer to have Foxboro Serv'ice Persorinel inspect the equipment and, if necessary,'eplace the amplifier, this can be arranged at standard service rates.

r

~

~Ca icitoz - The capacitor degrzdatioc problem was discovered over time throogh tracking failure situations.

Internal corrective action has been taken to remove the vendor involved from the qualified vendor list and to purge all stock

'of capacitors from this vendor.

Degradation of this capacitor is a function of time and service conditions with heat being a primary contributor.

This phenomenon was observed in 'recent tests of transmitters using these capacitors.

The capacitor in question is manufactured by Cornell-Duebilier and can be specifically identified by a type number in the form TX-65-XXZX as well as a monogram in a box followed by a date code, e.g.

CD 0874

. It is assigned Foxboro part number N0141MP.

To determine if this capacitor is present requires a visual inspection of the amplifier which can be accomplished as described above for the insulating sleeving inspection.

The recommended aorrective action should the above described capacitor be present is to replace the amplifier (Foxboro P/N N0148PW) although is is possible to replace the capacitor with a Foxboro provided substitute.

Use of Foxboro Service personnel to perform the inspection and replacement, if necessary, can be arranged at standard service rates as described above.

Due to lack of knowledge of specific application, redundancy, and the like, Foxboro cannot determine if the NRC reporting requirements of 10CFR Part 21 are applicable.

This determination is the responsibility of the user and any such reporting would be made by them after completing their evaluation of the situation.

If you have any questions regarding the above, please contact the undersigned directly.

Very truly yours, THE FOXBORO COMPAiK William Calder, ager Corporate Quality Assurance hoy 120381 Enclosure'E 20-'145 CUEBQR