ML20005A346
| ML20005A346 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 06/19/1981 |
| From: | Nichols T SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19276K261 | List: |
| References | |
| RTR-NUREG-0588, RTR-NUREG-588 NUDOCS 8106300231 | |
| Download: ML20005A346 (425) | |
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Mr. Harold R. Denton, Director
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U. S. Nuclear Regulatory Con =tission . ^ ', , '/ ,
Washington, D. C. 20555 ,
Subject:
Virgil C. Summer Nuclear Station Docket No. 50-395 NUREG 0588 Revision 3
Dear Mr. Denton:
In response to connents from your Equipment Qualification Branch during
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and subsequent to the March 2 - 6, 1981, audit of environmenfa1 qualification programs for the Virgil C. Succer Nuclear Station, South Carolina Electric and Gas Company hereby submits twenty-five (25) nonproprietary copies and twenty (20) proprietary copies of Revision 3 to our NUREG 0588 response of September 24, 1980, as revised by Revision 1 and 2 of .Tanuary 15, and Feb-ruary 11, 1981, respectively. Revision 3 supersedes and replaces previous versions of the NUREG 0538 report.
As this submittal contains information proprietary to Westinghouse Electric Corporation, it is supported by an af fidavit signed by Westing-house, the owner of the information. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Cocnission and addresses with specificity the considerations listed in paragraph (b) (4) of Section 2.790 of the Coc=issic n's regulations.
Accordingly, it is respectfully requested that tha information which is pr.prietary to Westinghouse be withheld from public disclosure in accordance with 10 CIT Section 2.790 of the Commission's regulations. Correspondence with respect to the proprietary aspects of this application for withholding or the supporting Westinghouse affidavit should reference CAW-80-31, and should be addressed to R. A. Wiesemann, Manager, Regulatory and Legislative Affairs, Westinghouse Electric Corporation, P. O. Box 355, Pittsburgh, Pensylvania, 15230.
If you require any additional information, please let us know.
- iours very truly, B ~
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memA 'THIS DOCUMEllT C0t4 Tali 4S Y#
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, Mr. Harold R.-Denton .
June 19, 1981 Page Two ec: Messrs. V. C. Summer G. H. Fischer T. C. Nichols, Jr. . .
E. H. Crews, Jr.
- 0. - W. Dixon, Jr. *
' W. A. Williams , Jr.
O. S. Bradham D. A. Nauman R. B. Clary A. R. Koon A. A. Smith J. B. Knotts, Jr.
J. L. Skolds B. A. Bursey H. N. Cyrus H. E. Yocom ** **
J. B. Cookinham Dr. J. Ruoff .
NPCF/Whitaker File ee l-6_____ J
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NON-PROPRIETARY SOUTH CAROLINA ELECTRIC & GA3 COMPANY VIRGIL C. SUMMER NUCLEAR STATION ENVIRONMENTAL QUALIFICATION PER REQUIREMENTS OF NUREG-0588 REVISION 3 UNIT 1: DOCKET 50-395 l
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er 31 VIRGIL C. SUMMER NUCLEAR STATION JN ENVIRONMENTAL QUALIFICATION OF SAFETY RELATED ELECTRICAL EQUIPMENT /NUREG-0588 3 REVISION 3 Instruction Sheet 25 Revision 3 supercedes the original edbmittal as
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-M 3 l previously revised through revision 2 in its entirety.
Discard previous submittal.
Revision 3 6
ENVIRONMENTAL QUALIFICATION-
. SAFETY RELATED ELECTRICAL EQUIPMENT /NUREG-0588 TABLE OF CONTENTS Section Titic Page
1.0 INTRODUCTION
1.1-1 1.1 ENVIRONMENTAL QUALIFICATION PROGRAM 1.1-1 1.1.1 Background 1.1-1 1.1.2 Independent Review Program 1.1-3 1.2 IDENTIFICATION OF EQUIPMENT REQUIRED TO BE QUALIFIED 1.2-1 1.2.1 . Systems Required for Accident Mitigation and Safe Shutdown 1.2-2 1.2.2 Instrumentation for Accident Mitigation and Safe Shutdown 1.2-2 1.2.3 Three Mile Island - Related Equipment 1.2-3 1.2.4 Equipment Subject to Post-Accident Submergence 1.2-4 1.2.5 Equipment Exempt from Qualification 1.2-5 1.3 ENVIRONMENTAL SERVICE CONDITIONS 1.3-1 1.3.1 Normal Operations Environment 1.3-1 1.3.2 High Energy Line Break Environment 1.3-1 1.3.3 Radiation Environment 1.3-3 1.3.4 Chemical Spray Environment 1.3-4 1.3.5 Submergence 1.3-5 1.3.6 Dust Environment 1.3-5 1.4 AGING PROGRAM 1.4-1 1.5 EQUIPMENT MAINTENANCE AND REPLACEMENT PROGRAM 1.5-1 l
1.5.1 Procurement and Materials Control 1.5-1 1 1.5.2 Programmed Preventive Maintenance 1.5-2 1.5.3 Corrective Maintenance 1.5-2 1.5.4 Personnel Training 1.5-3 1.5.5 Document Review 1.5-4
-1.6 EVALUATION AND CONCLUSIONS 1.6-1
1.7 REFERENCES
1.7-1 iv Revision 3 .
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TABLE OF CONTENTS (Continued) lll TABLES:
1.2-1 Class IE Equipment Subject to Harsh Environmenta: Conditions 1.2-2 Systems Required for Accident Mitigation and Cold Shutdown 1.2-3 Instrumentation 3equired for Accident Mitigation and Cold Shutdown 1.2-4 Items Exempt From Qualification 1.6-1 NSSS Qualificatios. Concerns 1.6-2 BOP Qualification Concerns 1.6-3 L'st af Equipment Scheduled for Replacement WESTINGHOUSE SUPPLIED ELECTRICAL EQUIPMENT: W-0 through W-30 Tables and Notes W-0 through W-21 Detailed Reports W-22 through W-31 BALANCE OF PLANT ELECTRICAL EOUIPMENT: B-0 through B-218 Tables and Notes 5-0 through B-74 Detailed Reports B-75 through P-218 ggg FIGURES Figure I through Figure 34 APPENDIX I - Plan for Review of Environmental Qualification of Class 1E Electrical Equipment APPENDIX II - Procedure for Review of Class 1E Electrical Equipment for Compliance with NUREG 0588 l
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r-e h 1.0 INTRODUCTI0if 1.1 ENVIRONMENTAL QUALIFICATION PROGRAM 1.1.1 Background In general, IEEE Standard 323-1971, " General Guide for Qualifying Class 1E Electrical Equipment for Nuclear Power Generating Stations," was the principal document for formulating environmental qualification programs for the Virgil C.
Summer Nuclear Station (VCSNS). For equipment under Nuclear Steam Supply System (NSSS) scope of supply, qualification was based on the supplemental qualification program described in a letter NS-CE-692 (7/10/75) from Westinghouse to the Nuclear Regulatory Commission (NRC). For equipment specified by the Architect / Engineer (A/E), qualification programs were based on IEEE-323-1971 avd subsidiary standards, such as IEEE-382 and IEEE-334, in ey.istence at the time of engin ring design.
. Even though South Carolina Electric and Gas Company (SCE&G) is committed to qualification of Class IE equipment in accordance with IEEE-323;1971, certain equipment has been supplied under the guidelines of IEEE-323-1974 and later revisions of IEEE stanGards. Because of the evolution of IEEE qualification standards that has occurred during the time of procurement of Class IE equipment, determination of the qualification standard applied to a particular component must depend on a review of the procurement history of the component.
Since toe tin:e that the NRC Commis.siocers issued Memorandum'and Order CLI-80-21 on May 27, 1980, NUREG-0588, " Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment," forms the requirements which operating license applicants must meet to estisfy those aspects of 10 CFR 50, Appendix A, General Design Criterion 4, which relate to environmental qualificatica of safety-related t sctrical equipnant. NUREG-0583 requirements are divided into'two categories. Category I posit _sas apply to equipment qualified by IEEE-323-1974; Category II positions, to equipment qualified by IEEE-323-1971. For NSSS supplied equipment, WCAP-9745 is a Westinghouse review of environmental qualification references fer Water Reactor Division supplied O) 1.1-1 Revision 3
Category II equipment with respect to the staff positions in NUREG-0588. It provides information to assess the degree of compliance of equipfsent under NSSS scope of supply to the requirements of NUREG-0588. A comprehensive testing and/or analysis program was conducted for the NSSS safety related electrical equipment and components which are required to function during and subsequent to any of the design basis accidents and that experience harsh environments. The prograr consisted of performance tests of individual pieces of equipment in the manufacturer's shop, integrated tests of the system as a whole in the field, and periodic inspection and tests of the activation circuitry and mechanical components to assure reliable performance, upon demand, throughout the qualified life of the equipment. The initial qualification tests of individual components and the integrated tests of the systems as a whole complement each other to assure performance of the system as designed and to prove proper operation of the activation circuitry. For engineered safety features (ESF) equipment, located inside the reactor building, qualification testing and/or analysis is performed considering the effects of post accident temperature, pressure, humidity, radiation and chemical environments.
For balance of plant (B0P) equipment, FSAR Section 3.11 describes the qualification programs. This equipment, including cabling, is designed to accommodate the effects of, and to be compatible with, the environmental conditions associated with the location of the equipment. The environmental conditions considered include those expected during normal operation, maintenance, testing and, if applicable, post accident periods.
Tne ESF mechanical and electrical equipment and instrumentation associated with balance of plant systems inside the reactor building are designed to perform required functions under conservative post accident temperature, pressure, humidity, radiation and chemical conditions. Where design of balance of plant equipment to withstand dynamic effects of missiles, pipe whip and jet forces was impractical, barriers were designed to protect such equipment.
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1.1-2 Revision 3
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-k_) An independent review of qualification programs for Class IE equipment has been conducted by SCE&G. The SCESG review has included identification of Class IE equipment needed to achieve emergency reactor shutdown, containment isolation, reactor core cooling, containment and reactor heat removal and prevention of significant release of radioactive material to the environment. It also included identification of TMI lessons learned, modifications and cold shutdown equipment.
The review program considered equipment location, normal, abnormal, accident environmental parameters, and design operability requirements under normal and accident conditions. It also included reviewing qualification reports against NUREG-0588 positions, equipment interfaces against qualification configuration and confirming that equipment qualifien is applicable to equipment installed in the plant. The purposes of the review were to establish the adequacy of the qualification programs, identify the need for additional qualification effort, and to provide the means to maintain equipment qualification for its intended purpose for the life of the plant. The independent review focused only on Class 1E equipment exposed to harsh environments.
1.1.2 Independent Review Program C
To accomplish the purposes of an independent review, an overall plan was developed. The plan organized the review into five major efforts:
- 1. Documentation of environmental qualification program scope.
- 2. Verification of qualification program status.
- 3. Identification and resolution of qualification program deficiencies.
- 4. Collation of qualification documentation.
- 5. Establishment of procedures to maintain qualifications.
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Overall responsibility for the review was maintained by SCE&G; however, Gilbert Associates, Inc. (GAI), the A/E, was tasked with performing the initial review of the qualification programs for B0P equipment against the NUREG-0588 positions.
SCE&G has been involved in the environmental qualification process throughout the design review of the plant. This involvement included review and approval of equipment specifications, resolution of environmental qualification problems as required, and witnessing of certain qualification testing. Review of qualification programs for equipment under NSSS scope of supply was performed under the direction of SCECG Nuclear f.ngineering and Licensing Department personnel. Personnel from different organizations, such as Shift Technical Advisors, Technical Support Engineers, Maintenance Engineers, and Independent Safety Engineers, were trained as reviewers. During the review process, an index of documents necessary to demonstrate qualification was generated for use in establishing a Central File of qualification records for Class IE equipment. To maintain an adequate depth and consistency of review, a Checklist / Summary Sheet was used to document the review process. Checklist / Summary Sheets for Class IE equipment were completed by SCE&G and GAI, and were reviewed and approved by SCE&G personnel from the organizations mentioned above. To complete the documentation link between the equipment that was qualified and the equipment actually installed in the plant, a field verification was performed by SCE&G Quality Control personnel.
To establish requirements for periodic maintenance and replacement of Class 1E equipment to maintain environmental qualification, SCE&G Nuclear Operations personnel are developing maintenance procedures incorporating information concerning life limiting components to be replaced and required periodic maintenance as icentified in the qualification programs.
SC.&G Nuclear Operations personnel are developing component maintenance and/or replacement programs which include consideration of specific aging characteristics of the component materials. Also being developed are ongoing programs to review surveillance and maintenance records to assure that equipment l
which is exhibiting age related degradation will be identified and replaced as necessary.
1 1.1-4 Revision 3
The plan used for independent review of qualification programs, field verification, and maintenance of equipment qualification is included as Appendix I. The procedure followed by GAI during review of B0P equipment is included as Appendix II.
QA participation in the formulation of this response to the NRC addressing the requirements of NUREG 0588 has been undertaken by audit and review of all facets of the effort. Gilbert Associates (GAI) Quality Assurance Division under the direction and instructions of SCE&G/QA has reviewed and approved the GAI
" Procedure for Review of Class 1E Electrical Equipment for compliance with NUREG 0588" and has audited the GAI effort as further described below. SCE&G/QA has reviewed, commented, and approved the SCE&G overall " Plan for Review of Environmental Qualification of Class IE Electrical Equipment" and has conducted in process audits of the SCE&G engineering effort. The work scope involved with the response to the NRC to NUREG 0588 has been adequately reviewed and audited by SCE&G/QA and its agents to assure sufficient controls are in place and are being followed to justify confidence in the accuracy and completeness of the report.
The information accumulated from the qualification data available has been
. verified by QA to have been independently reviewed for acceptability and completeness.
4 An independent review of the GAI " Procedure for Review of Class IE Electrical Equipment for compliance with NUREG 0588" was conducted by the GAI QA Division acting as an agent for SCE&G/QA. A Quality Assurance audit was conducted during the GAI review process to verify compliance with all elements of the GAI review procedure. Upon completion of the GAI review process an independent review / audit of documevation resulting from each phase of the review process was conducted by GAI/QA. The two audits conducted by GAI/QA are documented in audit reports attesting to the fact that each required stage of the review process (e.g.,
initiation, work sheet preparation, independent review of tae work package, j
preparation of check / summary sheet, independent review of check / summary sheet by Project Engineer and final review of package by interfacing discipline project l engineers, as applicable) has been completed and documented. GAI/QA involvement has been undertaken in accordance with existing written procedures.
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l The SCE&G " Plan for Review of Environmental Qualification of Class IE Electrical Equipment" was reviewed by SCE&G Quality Assurance Department. QA comments on this Plan were resolved and docun.ented in accordance with SCE&G/QA procedures.
In process audit of the SCE&G affort by SCE&G/QA covers the review of the qualification documentation and data, identification of deficiencies, initiation of corrective action when appropriate, completion of the checklist / summary sheets, collation of the information at the. central file, and verification of
- adequate independent engineering review in accordance with procedural requirements. SCE&G/QA surveillance activities verified proper completion of the QC effort of inspection of installed Class 1E equipment using a " Field Inapection Checklist".
The completed response to NUREG 0588 received a detailed review by SCE&G/QA prior to submittal. A final Quality Assurance Audit will be conducted of the Central Qualification files prior to the next NRC audit. SCE&G/QA involvement has been in accordance with existing Quality Assurance procedures and the Quality Assurance efforts have been fully documented and are available for NRC inspection. All future work associated with the maintenance of equipment qualification will be accomplished using the same methodology and controls which g
have been used to prepare this response and will be periodically audited by SCE&G/QA to assure compliance.
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) 1.2 IDENTIFICATION OF EQUIPMENT REQUIRED TO BE QUALIFIED FSAR Tables.3.11-0 and 3.11-0a list Class 1E equipment (NSSS and BOP, respectively) for the Virgil C. Summer Nuclear Station. Environmental qualification programs have been developed for the equipment listed in these tables. For the purposes of the independent review of environmental qualification programs, a verification of the systems and instrumentation required for accident mitigation and safe shutdown was performed. Accident mitigating and shutdown functions considered in this verification were:
- a. Faergency Re. actor Shutdown
- b. Containment Isolation
- c. Reactor Core Cooling
- d. Contai$mentHeatRemoval O
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% e. Core Residual Heat Removal
- f. Prevention of Significant Release of Radioactive Material to the Environment
- g. Certain Functions Identified as a Result of the Three Mile Island Event The identification of systems and equipment required to perform these functions was based on a review of FSAR Chapters 5 through 11, and Chapter 15.
The systems and equipment identified during the verification were compared to the data in FSAR Tables 3.11-0 and 3.11-0a to assure that all equipment required to be qualified was addressed under an environmental qualification program unless justification for exemptisn from qualification on some acceptable basis existed.
4 1.2-1 Revision 3
l The scope of review of environmental qualification programs is currently h restricted to equipment located in a harsh environment; however, the systems and instrumentation verification included all Class IE eqeipment. Class IE equipment located in a harsh environment is listed in Table 1.2-1.
1.2.1 Systems Required for Accident Mitigation and Safe Shutdown The safe shutdown design basis of the Virgil C. Summer Nuclear Station is hot standby. 'Jader abnormal conditions, the plant is designed to remain in a safe hot standby condition until (a) normal systems can be restored to permit either return to power operation or cooldown to cold shutdown conditions, or (b) sufficient systems capability can be restored (depending on plant condition) to permit cooldown to cold shutdown conditions under abnormal plant conditions.
Reactor Systems Branch Technical Position 5-1 (BTP RSB 5-1) establishes specific design requimments that address the various system functions that are required to achieve and maintain a safe hot standby and cold shutdown condition.
BTP RSB 5-1 requires plants with construction permits docketed after January 1, 1978 to comply in full with the design requirements of the BTP.
Plants with construction permits docketed prior to January 1,1978 (including Virgil C. Summer Nuclear Station) are required to address the BTP technical requirements and demonstrate partial compliance. A discussion of this compliance is provided in the FSAR in response to Question 211.86.
The systems required for accident mitigation and safe shutdown, as identified during the independent review verification, are listed in Ta' ole 1.2-2.
1.2.2 Instrumentation for Accident Mitigation and Safe Shutdown The instrumentation systems required to be qualified are those required for safe shutdown, accident mitigation, and protection of reactor coolant pressure boundary integrity. Safety-related instrumentation and control systems are identified and discussed in Chapter 7 of the FSAR. These systems are:
- a. Reactor Trip System
- b. Engineered Safety Features Actuation System
- c. Safety-Related Display Instrumentation h 1.2-2 Revision 3
As discussed in Chepter 7 of the FSAR, the safety-related instrumentation and control systems are those necessary for safe shutdown, accident mitigation, and protection of reactor coulant pressure boundary integrity. Although the safe shutdown design basis for the Virgil C. Summer Nuclear Station is a shutdown to hot shutdown conditions, Chapter 7 identifies the instrumentation and controls necessary to achieve cold shutdown conditions. The instrumentation required for ,
reactor trip, engineered safety feature actuation and safety-related display, as identified in Chapter 7, has been included in Table 1.2-3.
r i The need for environmental qualification of all display instruments available to the control room operators to follow the course of an accident was considered to determine if failure of nonqualified instrnaents could mislead the operators.
The human factors evaluation of control room display instrumentation will result in the marking of instruments that are qualified to perform their safety functions under adverse environmental service conditions. Such identification'of
. qualified instruments effectively precludes the situation of an operator being misled by a nonqualified instrument channel.
1.2.3 Three Mile Island - Related Equipment Equipment added as a result of the Three Mile Island Unit 2 accident and subsequent NUREGS (i.e. , NUREG 0578, NUREG 0660, NUREG 0737), and which is or will be environmentally qualified, is included within this report. This consists ;
of the following equipment:
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Action Plan Requirement
- 1. Reactor coolant system vents (RV head vents) II.B.1
- 2. Post-accident sampling II.B.3 j
- 3. Relief and safety valve position indication II.D.'
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- 4. Auxiliary feedwater system - additional ;
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i flow indication channel II.E.1.2 ;
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I l 5. Additional accident monitoring instrumentation: II.F.I l
- a. Containment pressure f
- b. Containment water level l
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- c. Containment H2 C "C'"'#8'I "
- d. Containment radiatien intensity .
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- e. High-range noble gas effluents from j steam safety and atmospheric steam dump valves
- 6. Subcooling and core level II.F.2 1.2.4 Equipment Subject to Post-Accident Submergence The response to FSAR question 040.5 addresses safety grade end non-safety grade equipment, both NSSS and B0P, that may be sulmerged as a result of site flooding or a pipe break inside or outside containment. To respond to the question, a review was conducted; and certain valves and instrumentation inside the containment vere identified as being subject to possible submergence.
The valves identified during the review are listed below.
Valve System Class Function / Remarks 137 CS non-1E Letdown flow control. Provides no safety function.
1003 WL 1E R.B. isolation. Safety function is performed prior to submergence.
8143 CS non-1E Excess letdown divert. Provides no safety function.
8153, 8154 CS 1E Isolation of RCS from excess letdown HX. Valves are NC during normal operation.
8701A,B RH IE RB and RCS isolation. Valves are 8702A,B RHR isolation valves.
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'Q!T In all cases, should flooding occur, the analysis concluded that circuit fuses prevent spurious operation of affected valves and protect the remaining circuit for those valves which do not have power locked-out during normal plant operation.
No Class IE instrumentation is flooded with the exception of sump level transmitters which are designed to operate submerged. Flooding of certain non-Class IE instrumentation associated with safety grade equipment is possible.
In these cases, fuses and/or circuit breakers provide sufficient protection to prevent adverse consequences to the safety related equipment.
1.2.5 Equipment Exempt from Qualification In the review of qualification requirements for electrical Class IE equipment, it was determined that certain equipment could be exempt from qualification to a harsh environment. The basis to exempt equipment from qualification is:
- a. The equipment does not perform essential safety functions in the harsh A
(_,/ environment, and failure *= the harsh environment will not prevent other safety-related functions nim'ead an operator.
- b. The equipment performs its functions before its exposure to the harsh environment with adequate time margin.
- c. The equipment will not be subjected to a harsh environment as a result of the postulated accident.
The equipment which can be categorized into items a and b, above, is included in this report, and the basis for exemption from qualification is included in the associated Detailed Report. Table 1.2-4 lists equipment categorized in
- accordance with items a and b which is exempt from qualification. The equipment which falls into item c, above, has been excluded from this report, based on a review of equipment location and the areas of the plant where a harsh environment may exist following a postulated accident.
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1.3 ENVIRONMENTAL SERVICE CONDITIONS h 1.3.1 Normal Operations Environment The ambient environmental conditions are determined by the operation of the plant ventilation system. The ventilation systems for various buildings and areas are designed to maintain the ambient air temperatures between maximum and minimum '
levelt, suitable for personnel occupancy and equipment operation. The design of the system was performed using accepted practices of the industry to fulfill the design criteria of each system. Detailed descriptions of the ventilation systems are located in Final Safety Analysis Report (FSAR) Section 9.4.
1.3.2 High Energy Line Break Environment 1.3.2.1 Peak Pressure and Temperature Analysis Inside Containment In the event of a loss of coolant accident, much of the released reactor coolant will flash to steam. This release of mass cad energ raises the temperature and pressure of the atmosphere within the reactor building. A rupture of a main steam pipe produces similar effects. The severity of the temperature and pressure peaks depends upon the nature, size, and location of the rupture.
A steam line break yields higher reactor building pressure than does a feedwater line break inside the reactor building. The same amount of water is added to the reactor building in each case. However, a steam line break causes the water to be added as superheated vapor, while a feedwater line break adds liquid with much lower enthalpy to the reactor building atmosphere. The feedwater line break is not considered to be as limiting as the main steam line break or primary system j LOCA. Therefore, the feedwater line break was not analyzed.
j In order to identify the worst case for peak reactor buildint pressure, a spectrum of hypothetical LOCA and large steam line break accidents has been
! analyzed using the CONTEMPT LT/22 computer program. The cases considered, methods of analyses used, and initial conditions assumed are fully discussed in l
l FSAR Section 6.2.1.3.
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('N) In order to identify the worst case for peak reactor building temperature, a
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spectrum of steam line breaks has been analyzed using the CONTEMPT LT/26 computer program. The methods used, initial conditions and single active failures assumed for the main steam line break analyses, are discussed in FSAR Section 6.2.1.3.
The results of these calculations for a line rupture inside the reactor building
- are summarized in FSAR Table 3.11-3 and discussed in detail in FSAR Section 6.2.1.
1.3.2.2 Peak Pressure and Temperature Analysis Outside Containment For the postulated rupturcs of high and moderate energy lines outside containment. the possibility exists that adverse environmental conditions may result. To ensure proper design of safety related equipment to withstand such an environment, it is necessary to identify the possible ruptures and to calculate the extent to which the environment would be affected by such ruptures. The limiting events which were identified are: (1) the rupture of main steam and feedwater lines within the penetration access areas at floor elevation 436'-0",
() (2) the rupture of main steam and feedwater lines on the upper level of the intermediate building, and (3) the rupture of 3-inch CVCS and 4-inch auxiliary steam lines in the Auxiliary Euilding.
These calculations are performed using the FLASH-2 and FLASH-4 computer code results for the mass energy released from these ruptures as input to the MN0DE and CONTEMPT computer codes. When it is desirable to calculate the environmental response to a postulated rupture in a few int-rconnected volumes, the MNODE computer code is used. However, when a one-node study of the resulting environmental conditions is sufficient, the CONTEMPT program is used. Both of these programs-give the pressure and temperature of each control volume directly.
The relative humidity must be calculated by using the relationship between the control volume saturation pressure and the vapor partial pressure.
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The environmental conditions of the various ccmpartments of the penetration access areas and the intermediate bu?lding are studied to determ'ne how they are h
affected by postulated ruptures of ths 32-inch diamete.r main steam line, the 4-inch main steam line to the emergency feedwater pump turbine, and the 3-inch steam generator blowdown line. The methods used, initial conditions and single active failures assumed in the main steam and small line break analyses are discussed in FSAR Section 3.6.
The results of these calculations for a line rupture outside the reactor building are presented in FSAR Table 3.11-3 and FSAR Figures 3.6-2, 3.6-6, 3.6-10 through 3.6-12, and 3.6-16 for the structure gage pressures, and in Figures 24 through 29, and Figure 33 of this report for the structure temperatures.
1.3.3 Radiation Environment The radiation environment, fo/ the equipment qualification review, designated the conditione of maximum total integrated dose (TID) received. Per the criteria of NUREG-0588, the total integrated dose stated within this report is the sum of the normal operating dose over the expected forty year life of the plant, and of the dose received during the required operating period after the postulated LOCA or MSLB event.
The normal operating doses are determined using the plant radiation zone designations contained in Chapter 12 of the Virgil C. Summer Nuclear Station FSAR. The area dose is assumed to be the dose received in the are. due to a constant maximum area radiation dose rate over the expected forty-year life of the plant.
The post-accident integrated doses outside of containment were calculated for the Class 1E equipment using the methodology cont:aned in the plant shielding design review report (Appendix 12A of the FSAR) e~1 in FSAR question 331.34. The report l was prepared in response to the September 13, 1979 letter from Darrel G. Eisenhut l
of the NRC to all operating nuclear power plants, and the subsequent l clarifications of this letter (References 1,2,3,4). The dose rates uere calculated for each piece of equipment by determining the poten'..al contributing 0
1.3-3 Revision 3 l
() sources at the equipment location. The integrated dose to each item was determined by integrating the dose rate appropriate for the given item ovnr the !
tirae period that it is required to be available to perform its safety function.
The post-accident integrated doses inside containment are calculated using the methodology cf Appendix D of NUREG-0588, and Appendix B of IF Bulletin 79-01B (References 5,-5A, SB, SC).
A technical review of the radiation environment methodology used in this report determined that the methodology used is equivalent to er exceeds the criteria of NUREG-0538 and its appendices.
1.3.4 Chemical Spray Environment The chemical spray environment anticipated within containment during the injection / spray phase Post-LOCA is determined by analyzing the drawdova. of the Refueling Water Storage Tank (RWST) and Sodium Hydroxide Storage Tank (SHST) to develop the concentration of sodium hydroxide in the spray header. The analysis .
' b s./ is performed for the range of sodium hydroxide concentrations required by the Tech Specs for sodium hydroxide in the SHST in conjunction with the design, normal, and two single failure eperating modes.
The results of the analysis developed a representative spray pH of 9.5 for a
. 65 minute operating time which is the most severe environment and envelopes the pH of each case analyzed.
The chemical spray environment anticipated within containment during the recirculation phase Post-LOCA is determined by analyzing the reactor building sump water following the injection / spray phase co-incident with a LOCA.
The results of this analysis developed a representative spray pH of 8.7 for extended operation of the spray pumps following the switchover from injection phase to recirculation phase.
/~T .
U 1.3-4 Revision 3
e The spray system will operate in the injection / spray mode until the RWST level reaches the Lo-Lt level at wnich time switchover to reactor building sump suction occurs. The operating time for the spray system Post-LOCA is two hours minimum as per the response to FSAR question 311.33.
1.3.5 Submergence The methodology used in the calculation of the maximum water level in the reactor building is defined in FSAR Section 6.3.2.2.7 for both a large break LOCA and a double ended main steam line break. The results of the calculations predict the following maximum water levels:
- a. LOCA 418'-6"
- b. Main Steam Line Eieak 417'-7" Flooding in areas other than the Reactor Building was examined and det rmined to be insignificant. The maximum flood level in any other location containing Class IE equipment was found to be below curb height.
g 1.3.6 Dust Enviranment Dust is an environmental parameter not generally applicable to the Virgil C.
Summer Nuclear Station. The site environs are unlike those of arid western sitings of some power stations in that vegetation, forests, and water areas bound the site. Hence, airborne dust is not chronic. Nor is industrial pollution, per EIS paragraph 2.3.3, a significant contributor of airborne particulates. A final paving and landscaping of the site will alleviate dust. South Carolina Electric and Gas is committed to a preventative maintenance program, as well as regular maintenance and testing of equipmera.. Before fuel loading, SCE&G will, as standard good housekeeping, thoroughly clean up to minimize potential airborne radioactive cont..nination. Further, protective coatings have been specified to ease cleaning and negate concrete dusting. All incoming air is filtered to areas containing Class 1E equipment. Combustion air for the diesel generator is drawn directly from outside the diesel building, not from the building itself. Based on the aforementioned, there is reasonable assurance that the equipment can perform its intended function within the expected dust environment.
1.3-5 Revision 3
- t
(~ ) 1.4 AGING PROGRAM V
s Motors and motor operated valve operators were qualified in accordance with IEEE standard 334-1971 and 382-1972, respectively, and were reviewed against the NUREG 0588 Category I criteria. In addition, a large portion of the BOP equipment has been qualified to IEEE standard 323-1974, or related daughter sttadards such as IEEE 383-1974. As a result, the concern for the effects of aging and a determination of qualified life has been addressed. For the remaining equipment, a program of monitoring and failure analysis is being established within the plant maintenance group. In addition, SCE&G Co. is participating with various owners groups to develop aging programs for specific equipment such as the diesel generators, and will have personnel assigned to the responsibility of monitoring industry progress and state-of-the-art to acquire any other information on aging mechanisms or equipment susceptible to degradation which may be developed. SCE&G is developing a ccaponent maintenance and/or replacement program which includes consideration of these specific aging characteristics of component mater als. Also, an ongoing program to review surveillance and maintenance records to assure that equipment which is showing
() age related degradation will be identified and replaced as necessary.
\_-
1.4-1 Revision 3 l
1.5 EQUIPMENT MAINTENANCE AND REPLACEMENT PROGRAM The Virgil C. Summer Nuclear Station Maintenance Program provides for control, testing, failure evaluation, trending and programmed replacement of environmentally qualified Class 1E equipment through the activities described in Sections 1.5.1 through 1.5.5.
1.5.1 Procurement and Materials Control The Virgil C. Summer Nuclear Station Procurement and Materials Control Program provides for the following:
- a. Control of procurements of Class IE pcrts and components to insure appropriate qualification and technical requirements are identified and reviewed by Technical and QA disciplines.
- b. Qualification of suppliers through independent QA and Engineering audit to assure that part or component procurement requirements are met and documented.
- c. Controlled storage, handling and issue of parts or components.
- d. Documenad traceability from origination to installation.
- e. Identification of shelf life and maintenance requirements while the part or component is in storage.
Additional effort is under way to perform the following:
l l f. Perform review of parts or components presently in storage tc determine the adequacy of qualifications.
l 1
- g. Review of Purchase Orders generated since May 23, 1980 to determine that correct qualification requirements have been applied and assign new requirements where required.
l 1.5-1 Revision 3
l
(~j h. -Develop .sn upgrade program for all Category 1E parts and components that l V
will assure NUREG 0588 requirements are met or provide justification for use without additional qualifications.
These activities require the joint participation of both the Technical and Quality Assurance organizations. This joint effort will assure that appropriate reviews, justifications and qualifications are made and documented.
1.5.2 Programmed Preventive Maintenance Vendor document packages, including qualification test reports and technical manuals, are presently being reviewed by Engineering and Maintenance personnel to identify all inspection, cleaning, testing and replacement requirer ats for individual components. As these requirements are identified, they are being entered into the computer-based history and scheduling program for that component. New procedures or procedure revisions will be generated to define and give step-by-step instructions for performance of these activities.
() Results of tests, inspections or replacement activities are routed for engineeries review when they do not conform to those acceptance criteria defined by the applicable procedure.
As new requirements are identified through Engineering evaluation, procurement, equipment operational nistory or changes to regulat. ry requirements, they are factored into the program through appropriate procedure revisions and computer data entry.
1.5.3 Corrective Maintenance, Maintenance performed as a result of part or component failure will be reviewed by Maintenance and Engineering to categorize the cause of the failure. Failures which occur as a result of environmental application, including aging, will be O
. 1.5-2 Revision 3
evaluated to determine wh.it, if any, preventive maintenance action may 'ae taken to protect from further failures. Examples of the evaluation methods to be used are:
- a. An ensite program of review to categorize cause of failure and establish a data base for trending purposes.
- b. Participation in industry wide data gathering programs such as NPRDS for purposes of identifying generic or common mode failures.
- c. Utilization of the LER program to provide additional information relating to recurring failurcs throughout the industry.
Results of these evaluations will be factored into the preventive maintenance program through appropriate procedure revisions and computer data entry.
Equipment upgrade requirements resulting from these evaluations shall be factored into procurement documents through the design change program.
1.5.4 Personnel Training Maintenance personnel will receive training to assure their awareness of specific requirements relating to inspection, cleaning, testing and replacement of Class 1E, environmentally qualified eouipment. This training will include requirements for verification of equivalency of replacement parts and components througn part number comparison and physical comparison, ensuring that replacement parts and components are installed in the correct physical configuration in the system or parent component, and that appropriate supervisory and engineering
- personnel are notified where initial investigation shows the cause of failure to be environmentally induced or where inspec'. ion or test results are not within acceptance limits.
l O
1.5-3 Revision 3
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/^Y 1.5.5 Document Review
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Documents pertaining to procurement, inspection, testing, repair or replacement of Class IE environmentally qualified equipment are reviewed to assure that:
- a. .All data is correct and correctly entered.
- b. Special requirements for replacement, testing or inspection are identified.
- c. Abnormalities relating to part equivalency, i.e., replacement versus installed physical conformity and configuration, are identified.
- d. Causes of failures of tests or of parts and comp nents in use are identified and acted upon.
- e. Overall program is in support of regulatory requirements and correctly maintains the cquipment.
() Each of the different aspects of the Maintenance Program are in place either in whole or in part. Where these programs are not completa, activites are ongoing to assure they are completed in a time frame that will be supportive of regulatory requirements and plant schedule.
4
'(
1.5-4 Revision 3
. - . _ _ - . - -., _ , . - - - ~ , _ ,
1.6 EVALUATION AND CONCLUSIONS The qualification of each type and application of equipment has been evaluated on a case by case basis. NSSS qualification documentation was reviewed in accordance with the plan included as Appendix I. B0P qualification documentation was reviewed in accordance with the plan and procedure included as Appendices I and II. The results of the independent review of Class 1E equipment are summarized on Tables W-0 through W-31 and B-0: through B-218.
Particular attention was given to the existence of margins between the postulated environmental conditions and the conditions used for qualification. For equipment reviewed against the criteria of Category I of NUREG 0588, the recommended margins of IEEE standard 323-1974 were used as a basis of review.
For equipment reviewed against the criteria of Category II of NUREG 0588, margins l
for pressure, temperature and operating time were required as a minimum. The adequacy of the margins was judged on a case by case basis and detailed reports were written to evaluate any cases where the available margins did not meet the criteria of NUREG 0588. g In a number of cases special analyses were performed to refine the postulated environments for specific equipment locations. For equipment outside of containment, the total radiation dosage was calculated on an individual basis accounting for both normal exposure for a 40 year life and for the exposure possible during a LOCA from specific equipment and piping sources. In addition, a special analysis was performed to determine the radiation exposure for Triaxial Cable for the power range nuclear instrument detectors. These cables are located in conduits which are imbedded in the reactor primary shield concrete. Another special analysis was made for the radiation exposure to the reactor building sump level transmitters which will be submerged in the event of a LOCA.
l Another area of the review which received special attention was the need for acceptance and/or failure criteria. Typically, vendor prepared qualification documentation does not include a clear statement of the acceptance and/or failure criteria. As a result, the individual reviewer has been obligated to evaluate the test data against the functional requirements for the equipment in the plant l specific application. The emphasis was placed on the functional aspects with a 1.6-1 Revision 3.
l
recognition that some of the data included in many reports is provided for
(~J) diagnostic purposes. For example, power cable must be functionally capable of carrying rated current while maintaining insulation integrity for the system rated voltage. Insulation resistance readings and high potential tests provide information on the degree of margin of failure.
The review of qualification documentation with respect to synergistic effects was handled on a generic basis. NUREG 0588 paragraph 4.(3), Category I, states that synergistic effects should be considered in the accelerated aging programs.
Although some qualification programs included simultaneous exposure to certain testing variables, noce were tested to determine the existance of synergistic effects. As noted in the letter from the IEEE Nuclear Power Engineering Committee by Mr. J. T. Boettger to Mr. A. J. Szukiewicz of March 18, 1980, "the state-of-the-art in aging to a single environmental stress is rudimentary at best," and " required experimental studies of combined effects exceeds the existing technology." South Carolina Electric and Gas has not performed an independent literature search to determine if synergistic effects have been identified for specific types of equipment. However, equipment qualification for A
4
(_,/ the Virgil C. Summer Nuclear Station Unit 1 is consistent with the
~
state-of-the-art, and as such, the omission of synergistic effects does not compromise the validity of results. -
In a few cases, some of the questions resulting from the review of qualification documentation to the criteria of NURTG-0588 have not been resolved. These items are listed in Tables 1.6-1 and 1.6-2 with a brief description of the concerns and the plan for obtaining satisfactory resolution.
Table 1.6-3 identifies NSSS equipment being replaced as a result of this study.
No equipment required replacement as a direct result of the review of equipment qualification.
v 1.6-2 Revision 3 .
r
1.7 REFERENCES
(1) Letter of September 13, 1976 from Darrel G. Eisenhut of the USNRC to all operating nuclear power plants, " Followup Actions Resulting From the NRC Staff Reviews Regarding the Three Mile Island Unit 2 Accident,"
(2) Letter of October 30, 1979 from Harold R. Denton to all operating nuclear power plants, " Discussion of Lessons Learned Short-Term Requirements."
(3) Letter of September 5,1980 from Darrel G. Eisenhut to All Licensees of Operating Plants and Applicants for Operating Licenses and Holders of Construction Permits, " Preliminary Clarification of TMI Action Plan Requirements," NUREG-0660.
(4) Letter of October 31, 1980 from Darrel G. Eisenhut to All Licnesees of Operating Plants and Applicants for Operating Licenses and Holders of Construction Permits, " Post TMI Requirements," NUREG-0737.
g (5) IEB Bulletin No.79-01B, " Environmental Qualification of Class 1E Equipment." January 14, 1980.
(Sa) IEB Supplement No. I to Bulletin 79-01B.
(5b) IEB Supplement No. 2 to Bulletin 79-01B. September 30, 1980.
(Sc) IEB Supplement No. 3 to Bulletin 79-01B. October 24, 1980.
(6) Virgil C. Summer Tinal Safety Analysis Report.
O 1.7-1 Revision 3 l
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G \ .J TABLE 1.2-1 clAs3 It agpigMrgI ,
.1 SUsJECT TO NLRSN ENVIROl833rfAL NIT!all$ '
rurchase safety Function, ggy Order Reference FSAR Igwirment System Egulpment Description . Ihmber Menu f acturer Type. Model Ibseher Catemory (2) g3)
Secttos EscatIan Time f aa Desubgr AC 6" Motor Operated Cate valve - q279358 sotorb 14NAl al s! 9.%.7.3 Rsa (4a) EVC7502 Operator al,a2 9.4.7.3 Rsa (4a) IVC 7503 l AC 6" Motor Operated Cate valve - Q279'58 Rotork 14NA2 a2 9.4.7.3 Era (4a)' KYC7501
. Operstar a2 9.4.7.3 tra (La) IsC7504' '
AN Damper Actuatar Solenoid Valve IO!!! ASCO 206-381 7F 6.2.2 al Rae (44) EDr0ll0A for Reactor Building Cooling at 6.2.2 Rae (4a) EDrollos Unit ifEPA trease Damper al 6.2.2 Ree (4a) XDr0 Illa al 6.2,2 age , (4a) EDP0llis AM Solenold Valve for 36" rurge 10181 ASCO Nr 8316 al,a2 6. 2.4, 9.4,8 RBe (4a) E9300018 Line Isolation valve al a2 6.2.4, 9.4.8 pse (4a) sys00023 (15) 6.2.4. 9.4.8 rs (4a) gvpOOOlA (15) 6.2.4, 9.4.8 Fs (4a) 2VB0002A All Solenald Valves for Air 10188 ASCO 8320 e2 9.4 Asb (4a) 3pr0012A Dampers c2 9.4 Asb (4a) gpr00823 AM Limit Switches for Beactor 10111 NAMCO EA-180 bl 6.2.2 Rae (4a) RDroll0A autiding Cooling Unit MErA (q247857) bl 6. 2. 2 R3e (4a) XDr0ll0s Filter sypass Dampers bl 6.2.2 Rae (4a) 3prol!!A bl 6.2.2 Rae (4a) 3prollis AM l.init Switch for 36" rurge 10181 NAMCO EA-190 bl,b2 6. 2.4, 9,4.8 R5e (4a) XVs0001B Line Isolation valve (q247857) bl b2 6.2.4, 9.4.8 Rae (4a) IVg0002s
!!5) 6. 2.4. 9.4.8 ra (4a) xys000la
, (15) 6.2.4, 9.4.8 rs (4e) Kys0002A AH Llett Switch for Air Damper 10188 NAMCD EA-180 c2 9.4 ABb (4a) - Ipr 0012A (Q?47857) c2 9.4 Ash (4a) KDr00128 c2 9.4 Aab (4a) KDr0013A c2 9.4 Asb (4a) EDr0013S AH .esctor BuildinR Crusting Unit 10l81 pellence 5003UCZ al,a2 6.2.2 pse (4e) NFN0097A Fan s=cetency Histor al,a2 6.2.2 Rae (4a) MFN00918 I
st a2 6.2.2 Rae (4a) MFN0097C al a2 6.2.2 Rae (4a) MF N0097D 20 La O ;Y
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parchase Safety Function.
Order Reference FSAR Etelement Sv~ tem III Eesstement peectlptton membe r Manuf acturer Type, tbdel member gelegory(2) Section tscatlonIII Time Tan pseber CD 3" Air Operated Cate Valve - 10l09 ASCO MP 8316 a2 6.2.4, 10.4.0 wra (4a) IVC 583A Solenold a2 6.2.4, 10.4.8 gra (4a) IVC 5038 a2
- 6.2.4, 10.4.0 tra (4a) ITC503C BD 3" Air Operated Cata Valve a 10109 NAMCO EA-ISO m2 6.2.4, 10.4.8 wra (4a) IVC 503A Limit Switch (Q2478571 a2 6.2.4, 10.4.8 tra (4a) airC503s a2 6.2.4, 10.4.8 gra (4a) ryC503c CC 8" setor Operated Cate valve - 10109 Limitorque SMs-BOO-5 al,a2 6.2.4, 9.2.2 pad (4a) KVC9605 Operator CC 4" Air Operated Cate Valve - 10109 ASCO NP 8316 a2 9.2.2 IBa (4a) IVC 9627A Solemeld a2 9.2.2 Ita (4a) KvC96273 CC 8" Notar operated Cate valve - 10109 Limitorque SMB-005 a2 6.2.4, 9. 2.2 grb (4a) IVC 7568 operator a2 6. 2.4. 9.2.2 wrb (4a) RVC9606 CC 3" pote. C.wrated Cate valve - 10109 1.lmitorque $Ma-000-2 a2 6.2.4. 9.2.2 Erb (4a) KvC9600 Ope ra' er CC 8* Mrror Operat ed Cate Valve - 10809 Limitorp e setn-000-5 c2 9.2.2 ARb (4a) IVC 9625 fterat$r c2 9.2.2 ABb (4a) 4VC9626 CC 16" petor Operated Butterfly 10200 Limit or que SMB0005/N25C a2 9.2.2 IBa (4a) gyg95268 Valve - Op rator y a2 9.2.2 Isa (La) XVB96873 a2 9. 2. 2 Isf (4a) gy39526A a2 9.2.2 ter (4a) IVs9687A CC .hr* Motor Operated Butterfly 10200 Limitorque SPs0005/H2BC c2 9.2.2 ABb (4a) IVB9503A valve - fterator c2 9.2.2 ASd (4 a) gyg9503s rc 16" Peter Operated Butterfly 10200 Limitorque SMn0005/H2BC c2 9.2.2 A8b (4a) gyg9524A Valve - Operator c2 9.2.2 AF,b (4a) Iy395243 c2 9.2.2 Aab (4a) Iv39525A c2 9.2.2 Anb (4a) XV395253 CC Ca=fonent rooting water Ptmep - 10142 Westinalw*use IAA Pw/3840 Irame m2 9. 2. 2 Isa (4a) Mrre001A fMtor a2 9.2.2 Isa (4a) MPP00015 a2 9.2.2 Isa (4a) MPf000lc O O O
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TABIA l.2-1 CIJdiS IE EEAll4 SUSlECT TO MAR $N ENVIINuesNTAL CGIstTiots Purchase Safety runction, 4gg Order Reference FSAR Egelpment System Eqsitament Gescription .. lhamber Manufacturer IZEe. Iedel stumber Catemory(2) Section tseat ion (3g Time Tas Number CC Component Cooting Water Flow 10240 Rosemount li3)DA4 cl c2 Table 7.5-2, Red (4a) - IFT7263A to Reactor Coolant rump 9.2.2.5.4 4 searings cl c2 Table 7.5-2, Red (4a) IrT7263s 9.2.2.5.4 CC Camponent CnoIIng Water riow 10240 Rosemount il53DA4 cl c2 Table 7.5-2, Erb (4a) IFT7273A to peactor Cooling rump 9.2.2.5.4 Thermal Barriers cl r2 Table 7.5-2 Erb (4a) trT7273s 9.2.2.5.4 CC 4* Air Operated Cate Valve - 10109 NAMCO FA-180 a2 9.2.2 Isa (4a) XVC9627A Limit Suitet, (q247857) a2 9.2.2 laa (4a) XVC96273 Cl RTD, Reacter ButIdtng 10231 ryeo 122-1010 al,a2 7.5 Table 7.5-1 Rae (4a) 17E9201 Temperature al,a2 7.5, Table 7.5-1 ane (4a) ITE9203 al,a2 7.5 Table 7.5-1 ase (4a) ITE9203A CS 2" Clobe Valve - Motor 10001 Limitor.pe Ste-00-10 al*,c2 6.3 Age (46) 8104 Operator ate.c3 6.3 A8a (4b) 8109A
- a l *,e 2 6.3 Asa (4b) 81098 al*,c2 6.3 Ata (4b) 8809C
- f c2 6.3 Wra (4b) 8100 CS 4" Cate Valve - petor 10001 Limitorque S8-00 al*,e2 6.3 Ast (4b) trV-Il5C Operator al*,c2 6.3 48f (4b) IEV-IISE CS 8" Cate valve - Motor local Limitorque 58-00 al *, c 2 6.3 Asa operator (4b) IIV-IISS al*,c2 6.3 ABa (4b) 14V-Il50 CS l-1/2" Clube valve - Motor 10001 Limitorque Sps-00-10 al*,c2 6.3
- Wra (4b) 8102A Operator al*,c2 6.3 Era (4b) 81025 al*,c2 6.3 Era *
(4b) 8102C CS 8" Cate Valve - Hotor 10001 Limitorque SB-00 al*,e2 6.3 Asa Sl30A operator (4b) al*,c2 6.3 Ana (4b) PI30s al*,c2 6.3 Ass (4b) 813tA al *,c 2 6.3
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_SUBJFCT TO NARSH ENVIRt]IMFNTAL CtMITTIONS rurchase safety Functlam, g Order Reference FSAS Sy tem gyg gyg E9ellement F eil r'anen t I>scription kanbe r Maevefecturer Iype. Model Ntamber Catemorv Section W atton Time 1st leseher CS 4" Cate Valve - Pk> tor 10001 Limitorgse 5b-00 al*,c2 6.3 Ana (45) 8132A operator al*s.c2 6.3 ABa (4t) 81323 ale.c2 6.3 ABa (46) 8133A al *,c 2 6.3 Ane (4b) Sil3s ci 3* Care valve - Motor 10001 Limi torque SB-00 al*,c2 6. 2, 6. 3 A8f (4b) 8106 Operator al*,a2 6.2, 6.3 Wre (4b) 8107 al*,a2 6. 2, 6.3 Wra (4b) 8108 CS 2" Clobe valve - Motor 10001 Limitortee SMB-00-to al e2 6.2, Asa (4b) 8112 Operator CS 3* Clobe Valve ASCO 8316 al*,c2 6.2 Wra (4e) 8152 CS 2" Clobe valve - Solenoid 10001 ASCO 8316 al.c2 6.2 asa 8141 (4b) al.c2 6.2 Rsa (4b) 81494 al.c2 6.2 kna (4b) 81493 al.c2 6.2 R8a (4b) 8149C CS 1" Clube valve - Solenoid 10001 ASCO 8316 al.c2 6.2 ase (4b) 8153 9
al.c2 6.2 38c (4b) 8154 CS 3" Clube valve - Solenold 10001 ASCO 6316 cl a2 6.2 RRc (4b) 1.CV-460 cl.a2 6.2 Rsc (',b ) 14v-459 CS Stese Moeented I.imit Ser.tch NAPMX) FA-180 al*,c2 6.2 Wra (4b) 8152 CS 2* Clobe valve - L!mit Switch 10001 NAMCO EA-180 al.c2 Latch-In RS4 8149A (g247857) (4b) al.c2 Latch-in Ram (4b) 8149s al.c2 let ch-in R5a (4b) 8149C CS 3** Clobe Valve - Limit Switch 10001 NAMCO EA-180 al.c2 8.atch-in Rsc (4b) 14y-459 (Q2 ',78 5 7 ) al.c2 latch-in Rsc (4b) lxy-460 s
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TASIE 1.2-1 S1455 lE E WirtstNT SUBJECT TO HA8Sil DIV!Rologerr4L CCIIDIT10lg . ,
Purchase Safety Function, Order Reference FSAR Equipment g 4 System Eoiloment Description Isiamber Manu f acturer 12lrf. Model Ilum yb (stemory _ Section _
Tisse Tat W CS Charging Pump teter 10001 Westinghousa 6809 al*,c2 6.3 Al (4b) ipr 004 3A ,
cl*,c2 6.3 At (4b) dry 0043s al*,c2 6.3 J (4b) Irr0043C CS Safety injection rump 10207 Terac Could HPL-C c2 8.3.1.8.1 A (4e) XET2002C Tranafar Switch EF 6" IWtor Operated Cate Valee - 10109 Limitorque SMs-00-5 a2 10.4.9 les IVC 100lA operator a2 10.4.9 Isa IVClodlB .
EF 8" tktor Operated Cate Vales - 10109 Limitore=se SPS-000-5 a2 10.4.9 laa XVC1002 Operator a2 10.4.9 laa XVC1008 a2 10.4.9 laa XVC1037A a2 10.4.9 laa , XVC10373 EF Emergency Feedwater rump 10175 ASCO WP-HVA-206-38). a2 10.4.9 Isa (4a) IFV3511 Flow Control Valve - Solenoid 3RVU a2 10.4.9 Ita (4a) IFV15%
a2 10.4.9 IBa (4a) IFV3541 a2 10.4.9 Isa (4a) IFV3546 a2 10.4.9 laa (4a) IFV 3551 62 10.4.9 Isa (4a) IFv3556 EF 4" Swing t$ieck Valve - 10209 ASCO 206-381-3F a2 6.2.4, 10.4.9 wrb (4a) Ivcl009A Solenoid a2 a2 6.2.4, 10.4.9 6.2.4, 10.4.9 Erb Erb
^ (4a)
(4a)
KYC1009B IVC 1009C EF Emergency Feedwater rimnp 10162 General Electric E Hortmantal m2 10.4.9 laa (4a) Mrron2th Frame 8311Z a2 10.4.9 Ita (La) M,=00218 Notor 5K83tl55C7 5E831155C8
. s EF Hotor Driven Emergency 10240 Rosemount il53DA5 a2 10.4.9.5 Isa (4a) IFT3535 Feedwater risap Discharge a2 10.4.9.5 Isa (4a) IFT3551 Header Flow a2 10.4.9.5 Era (4a) IfT3541' EF Emergency Feedwater to Steam 10240 Rosemount Il53DA4 a2 7.5, Table 7.5-1, wra (",a) IFT3561 Cenerator Flow 10.4.9.5 a2 7.5. Table 7.5-1, Era (4a) - IFT3571 10.4.9.5 m2 7.5, Table 7.5-1, Era (4a) IFT3581 10.4.9.5 IK3 to (D D'
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- IRrol01s ES Electrical renetration 10249 D. C. O'Brien Law Voltage al,a2 3.8.1.1.2.2 KBe (4a) XRrC007 rower /Dont rol al,a2 3.8.1.1.2.2 RBe (4a) 3Rr0010 al,a2 3.8.1.1.2.2 BBe (4a) IRrooll al,a2 3.8.1.1.2.2 BBe (4a) IRrool4 al a2 3.8.I.1.2.2 RBe (4a) Isr0017 al a2 3.8.1.1.2.2 Rae (4 e) XRr0028 al,a2 3.8.1.1.2.2 RBb (4a) IR POnl0 ES Electrical Penetration 10249 D. C. O'Brien lastriementation el,e2 3.8.1.1.2.2 R8e (4a) IRro035 al,a2 3.5.1.1.2.2 RBh (4a) IRr0016 al a2 3.8.1.1. 2. 2 R&a (4a) IRr004) al a2 3.8.1.1.2.2 R8a (4a) XRrUG44 al s2 3. 8.1.1. 2. 2 RBh (4a) 1Rroo45 al a2 3.8.l.l.2.2 RBa (4a) IRroo46 al,a2 3.8.1.1.2.2 RBa (4a) IR r00'e 8 al,a2 3.8.1.1.2.2 REE (4a) Kar0051 WI' 4
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Catenery(2) locat taa(3) Time Tea Dimber System Eestpoemt Descrietten J eber Manu f ac t urer Type. Model Ihaber Sectice ES Electrical renetration 10249 D. C. O' Bries Trias Connector c2 3.8.3.1.2.2 tsa (4e) 3a7004)
Trias connectore c2 3.8.1.1.2.2 Rsa (4a) Mar 0044 c2 3.8. l .1. 2. 2 kab (4a) Kare045 c2 3.8.1.1.2.2 maa (4a) Rap 0046 E3 reuer Transfer and Motor W4 riald Fabricated (7) c2 8.3 Asa (4a) grue040 Control ramal for Charging Pump C Analliaries ET laolation ruses and ruse 10!59 Could/Shaumut MA a2 (8) Ash (4a) 3rul005.
l Blocks in peat Tracing ramela fuses; phenolic a2 (8) Aab (4a) Erul006 type fuse block a2 (8) Asb (4a) Iru2007 a2 (8) Asb (4a) Eru2006 a2 (8) Ash (4a) ErW2009 a2 (8) Ash (4a) IPN2010 rs 4" Motor operated Cate Valve - 10109 Limitornfue SMs-000-5 a2 6.2.4. 9.5.1 Wrb (4a) KVC6797 Operator ru reeduater Flow Dr Transmitter 10001 Barton 752 c2 7.2 Wrb (4a) trT0476 c2 7.2 Wrb (48)- ISTD477
. c2 7.2 Inf (4a) trTO484 c2 7.2 -1st I4s) 'trT0487 c2 7.2 Inf (4a) trT0496-c2 7.2 Inf (4a) Ir70497 tv I" Air Operated Clobe Valve - 10109 ASCO pr 8316 a2 6.2.4. 10.4.7.2 urg (4a) KVT1678A Solenoid a2 6.2.4, 10.4.7.2 Erb (4a) .IrT16783 a2 6.2.4. 10.4.7.2 Erb (4a) KVTl67DC FW 1-l/2" Hotor Operated Valve - 10172 Limitorque SHS-00 m2 6. 2.4 wrb (4a) XVT1613A operator a2 6.2.4 Erb (4a) XVTl633s a2 6.2.4 Erb (4a) XYT1633C FW 18" Air-Hydraulle Globe 10?O9 ASUD 206-38 5-3r a2 6.2.4. 10.4.7.2 W rb (4a) rycl6tIA Valve - Solenoid a2 6.2.4. 10.4.7.2 Erb (4a) XYCl611a a2 6.2.4. 10.4.7.2 Erb ,
(4a) Ivcl635C FW 3* Air operated Clohe Valve - 10109 NAHOD EA-180 a2 6.2.4. 10.4.7.2 w rb (4a) Irfl678A l.imit nuttch (q?47P57) a2 6.2.4. 10.4.7.2 Erb (4a) KVil678s a2 6.2.4. 10.4.7.2 Erb (4a) IVT167BC pc to
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System gg Equipment licacription . Minnber Manufacturer. Type. Model Nieyd gatemory(2) Section M atton W Time fag lpmbeg fW IS" Atr-Hydraulle Globe 10209 NAMCO EA-180 m2 6.2.4, 10.4.7.2 Wrb (4a) XVCI6tlA Valve - Limit Switch (q247857) a7 6.2.4, 10.4.7.2 Erb (4a) KVC16 t ta .-
a2 6.2.4, 10.4.7.2 Erb (4a) EYCl611C til Hydrogen Rectumbiner 10(M)1 Westinghouse Electric Type al.c2 6.2 Rev (4h) IHRfM4feA al.c2 6.2 RBe (4b) E!!K00043 Hk Hydrogen Recombiner Control 10001 Westinghouse -
c2 6.2 ABb (4b) IrtF1049A ranels and Power Supply c2 6.2 Aab (4b) grlers9s c2 6.2 Ash (4b) KPN005aa c2 6.2 Ash (4b) IPN00503 Ita 6" Air Operated Cate valve - 10109 ASCO . ar 8316 al,a2 6.2.4, 6.2 .a pse (4a) XVC6056 Solenoid HR 6" Furge Isolation Valve - 10109 ASCO Nr 8316 al.s2 6.2.4 Rue (4a) 3VC6066 Solenoid al s2 6.2.4 Wre (4a) IVC 6067 lin Post Accident Ilydrogen 10482 Valcor V526-5292-20 al 6.2.5 Rae (4a) xvx6050A Removal System Isolation al 6.2.5 RBe (48) IV160)O5 Solenoid valves at 6.2.5 Rae (4s) KVI6051A al 6. 2. 5 Rae (4a) XVI60515 at 6.2.5 Rpe (48) XVX4051C b2 6.2.5 Wrc (48) KVX6052A b2 6.2.5 Wrc (4a) IV16053A b2 6.2.5 Wrc (4a) IVI6054 ItR Reactor Building Wide Range 10240 Rosemount Il52APF cl.e2 7.5. Table 7.5- 8 Wre (4a) IPT0954 A rressure (14) 7.5. Table 7.5-1 re (4a) Irt11954a HR Marrow Range Containment 10001 Ba rt on 752 c2 7.1 krc (4a) IIT950 Pressure Transmitter c2 7.3 Erb (4a) IPT953 (14) 7.3 FB Ir195I (14) 7.3 FB frT952 9 ,
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. location faa Number n2 6" Air Operated Cate valve = 10109 NAMCO EA-180 al,a2 6.2.4, 6.2.5 ase (4a)~ XVs6056 Limit switch (q247857)
HR 6* Furge Isolation valve - 10109 NAMco EA-180 al,a2 6.2.4 Rae (4a) IVC 60 H -
1.5mit Switch e 747857) al a2 6.2.4 Wre (4a) IVC 6067 Ita Beactor nullding Hydrogen A262584 cuestp, Ime. Elll e2 6.2.5 Ash (4a) IPN7215A Analyzer Panel est Remote (15) 6.2.5 re (4a) IrelF215s -
Control Panel e2 6.2.5 Asb (4a) 3y117254A c2 6.2.5 Aab (4a) . I1117258s lA 6" Air Operated Clobe valve - 40139 ASCO NP 8316 al,a2 6.2.4. 9.3.1 anb (4a) IVT2662s Solenoid a2 6. 2.4, 9. 3.1 Wra (4a) XVT2% 24 14 2* Att operated Clobe Valve - 10172 ASCO NP 8323 a2 6. 2.4. 9.3.1 Wrb Solenote (4a) . XVT240 1A 6" Air Operated Clobe Valve - 10109 NAMCO EA-180 al a2 6.2.4, 9.3.1 RBb (4a) IVT2H 2s Limit Switch (q247857) a2 6.2.4, 9.3.1 WPa (4a) IvT7H2A IA 2" Air operated Globe Valve - I-:472 NAMCO EA-180 6.2.4, 9.3.1 m2 Wrb (4a) IVT7%0 Limit Switch (q247857)
LD Electronic Tranemitter, 10240 Rosamount 01153-0022-0001 al,a2 7.5 Table 7.5-1 tab (4a) ILTl969 Reactor autiding RHR al,a2 7.5. Table *,.5-1 Rab (4a) II.71970 Sump IAvel ID Electronte Transmitter, 10240 Rosemount 01153-0022-0001 al,a2 7.5 Table 7.5-1 asb -(4a) ILT1975 Reactor nestldtog Level al,a2 7.5, Table 7.5-1 hab (4a) ILTl976 Ms Steam Cenerator Level 10001 sarton [ J' al,"I 20) 7.2, 7.3, 7.5 Rae (46) Itt0474 al, UIa2 0) 7.2, 7.3, 7.5 asa (4b~t ILT0475 al, OIa2 OI 7.2, 7.3, 7.5 pse (4b) ILT0476 a t , OI a2I 'I 7.2, 7.3, 7.5 pse (4b) ILT0484 PO f.4
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Order Refetoace FSAR S r t ens E ee,l onent Description . ptunber Equipmant Manufacturer Type. Hndet 16stig Catezorv(2) Section lpestion flee Irg_Isuyest>e Ol power Range Neutron Detector 10001 West ingtsouse Dual section cl c2 7.2 Ra, apV (4b) MC-41 f eelsation chamber cl.c2 7. 2 38. RFV - (4b) MC-42 cl.c2 7.2 Ra, Rrv (4b) NC-43 cl c2 7.2 Ra, ppV (46) leC-44 G::: Narrow Range Resistance 10001 Rosemount Teenperature Detector
[ ] s2.el 7.5 RSc bypass (4b) ITE0412A loop a 2,c l 7.5 Rae, bypass (46) ITE04123 loop a2,el 7.5 Rae, bypass (4b) ITE0412C loop a 2,c l 7.5 Rac, bypass s'u
- ITE04120 toop OC Narr<ne Range Resistance 10001 Rosemount Temperature Detector
[ ] a2.cl 7.5 Rac, bypass (4b) ITE0422A loop a2,cl 7.5 Rae, bypeas (4b) ITE04228 loon a2.c l 7,5 Rae, bypass (4b) ITEn4 22'c loop a 2.< ' 7.5 Rae, bypass (4b) ITE04220 I*0p a2.cl 7.5 Rae, bypass (4b) ITE0432A loop
- af.cl 7.5 Rac, bypass (4b) ITp:04323 luop a2,el 7.5 Rae, bypass (4b) ITE04 32C toop a2 cl 7.5 Rae, bypass (4b) ITE0432D toop RC Wide RanRe Resistance Tsuperature Detector 10231 ryco '22-3006 al.IU a2I 'I 7.5 Rae, RCS (4a) ITE0410/
loop 0410A al,III a2I 'I 7.5 Rec, RCS (4a) ITE04t3/
loop 0413A al I'I a2I 'I 7.5 Rae, Rcs (4a) ITE0420/
loop 0420A al, a2I 'I 7 .1 Rae, RCS (4a) ITE0423/
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Sv*te=III Egutgenent Desertotion Mr Manufacturer Type. Sepdel Imamber Catemorv section location Time faa gumber RC Reactor Coolant Flow DF 10001 parton 752 cl.c2 7.2 ase (4b) IFT0414 -
Transmitter cl,c2 7.2 see (4b) IFTn415 cl .c 2 7.2 Bae (46) IrT0416 cl.c2 7.2 asa (4b) - 1F10424
. el.c2 7.2 asa (4b) IFT0425 cl.c2 7.2 asa (4b) IFT0426 cl.c2 7.2 asb (4b) IFT0434 cl c2 7.2 ash (4's ) IFT0435 cl.c2 7.2 sob (4b) IFT0436 BC Fressurtser Pressure P Inn 01 Barton al,a2 7.2 Rad (4b) IPT0A55 Transmitter al,a2 7.2 Red (4b) IPT0456 al,a2 7.2 asd (4b) trT0457 RC Pressurtzer 1svel DP 10001 sarton al,('I a2I 'I ~ 7.2, 7.3, 7.5 med '
(4b) ILT0459' Transmitter al,I'I a2I *I 7.2, 7.3, 7.5 pad (4b) ILT0460 al I'I a2I 'I 7.2, 7.3, 7.5 and (4b) ILT0461 RC teactor coolant System 10001 Barton et,OI a2I 'I 7.5 Rec (4b). IFT0402 rressure Wide Range P Transmitter al,OIa2 OI 7.% ase (4b) trt0403 RC I" Diaphrages Valve - Limit 10001 NAMCO EA ISO al.c2 Latch-in Ram (4b) 8047 Switch (g247857)
RC 1" Diarhaagm Valve - 10001
- ASCO 8316 al.c2 6.2 maa (4b) 8047 Solenoid f>Igleraum Valve- Solenold RC 10:10 1 ASOR 8316 (14) 6.2 F8 80 i FB
- 9028 (14) 6.2 BC 2" tbtor operated Clebe Q245435 Limitorgae SMB-00 al,a2 5.5.15 RSe (4a) IVT8095A valve - tWrator al.a2 5.5.15 ase (4a) IvT8095s al a2 5.5.15 ase (4a) XVT8096A p3 tn al,a2 5.5.15 Rs* (4a) IVT80%s Q[ RC stern n =nted I.sett sus tris l(NMll RWuu yg.lm3 (I4) Latch-in Fs - 803)
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- FLT445A FCV4435 R.3 8" cate Valve - Motor 10001 Limitorque $3-00 al*,c2 6.3 Anb (4b) 8706A operator ale e2 6.3 Asb (4b) 87063 r,:3 2" clobe Valve - tutor 10001 Limitorque SMB-00-lo al*,c2 6. 3 ' ABa (4b) FCV-602A (43erator ele.c2 6.1 A6a (46) FCV-6025 R3 8* Cate Valve - Motor 10005 Limitorque SB-2 al*,c2 6.3 ABa (4b) 8809A operator al*,c2 6.3 ABa (4b) 88093 RH 12" Cate Valve - Operator 10001 Limitorque SB-2 al.c2 6.2 Rah (4b) 8 70l A al .c 2 6.2 Rae (4b) 8701.1 al.c2 6.2 R8c (4b) 8702A al .c 2 6.2 R3e (4b) 87023 Ett RHR rimp Motor 10001 Westinghouse 5008 al *,c 2 6.3 ABa (4b) XPr003I A al*,c2 6.3 Asa (4b) grr0031s Rtt stem Haunted Limit Switch NAMCO EA-180 a l*,c 2 6.3 Aab (4b) 8706A al*,c2 6.3 Asb (4b) 87063 al*,c2 6.3 Asa (4b) 8809A al*,c2 6.3 Asa (4b) 38098 EH 12" Cate Valve - Limit Switch 10001 NAMCO EA-180 al.c2 Latch-in RBa (4b) 8701B (4247857) al.c2 Latch-in R8c (4b) 8702A RH Containment High Range Area y259443 Victoreen 8 71- I al.bl 12.I.4 RBe (%a) IPMG) DIS Mrmitor Detector SR 3* C.ite valve - Motor 10001 Limitorque $3-00 al*,c2 6.2 WPs (4b) 8884 (We rat or 5
al*,c2 6.2 Wra (4b) 8885 al*,c? 6.2 Wra (4b) 8886 st 14" cate Valve - n> tor 10rmt Lins t errree SB-2 ale c2 6.3 Asa (4b) Salla operator al*,c2 6.3 Ata (4b) 88118 al*,c2 6.3 A8a (4b) 8812A el*,c2 6.3 Ana (4b) 88128 a l *, c 2 6.3 ABa (4b) 880')A al*,c2 6.3 Asa (4b) 88098 O O O
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rurchase Safety ruection, Order Reference FSAR Egstyment Sys t eenIII tesisment Desertation _ lhamber Manufacturer Twee. Itsdel Ilumber Catemorv(2) _ g.,gg , g,,,g g,,(3) - Time Tom Bomber
$1 10" Cate Valve - ptotor 10001 Limitarve S B- 1 al*,c2 6.3 Wra (4b) '4887A operator a l *,e 2 6. 3 - Wra (46) : 8847s SI 10" Cate Valve - Motor 10001 Limitorpe SBD-3 al*,c2 6.3 Wra operator' (4b) 8888A al *, c2 6.3 tra (4b) 8088s al*,c2 6.3 Wre (4b) 8489 SR 1* Cate valve - Motor operated 10001 Limitergue 59-00 (14) 6.3 rs 8801A (14) 6.3 FB 88013 (14) 6.3 FS 8801A (14) 6.3 rs . Se03s SI 3/4" clobe Valve - Solenoid 10001 ASCO 8316 al.c2 6.2 Rab (4b) 8871 St I" Clobe Valve ASCO 8316 al*,c2 6.2 Wra (46) 8080 al *,c 2 6.2 Wra
$1 3/4" Clobe Valve 8316 (4b) 8860 ASCO al*,c2 6.2 Wra (4b) 8961 SI stem nsanted L!ait Switch IIAMCO 13-180 al*,c2 6.2 Wra !4b) 4000 al*,c2 6.2 Wra .(4b) Sn60 al*,e2 6.2 Wra .(4b) 8961 SI 1* Clobe Valve - Solomold 10001 ASCO 8316 .al.c2 6.2 anb (4b) 88754 al.c2 6.2 pas (4b) 88755 al.c2 6.2 Rae (4b) 8875C (14) 6.2 rs 89454 (14) 6.2 FS 89458 (14) 6.2 FB 8942 St I* Clobe Valve - Limit Sultch 10001 NMND EA-180 (14) Latch-in FB 8945A (14) Latch-in et 8945s (14) Latcle-in FB 8942 SR 3/4" Clobe Valve - Limit Switch 1000I NAMCO EA-180 al .c 2 Latch-in Rab (q247857) (4b) 8871 Sr 10" Motor Operated Cate Valve - 10109 Lim! torque SMB-00-15 a2 6.2.2.2, S.2.4 Wre operator (La) IWC3003A a2 6.2.2.2, 6.2.6 WFe (4a) IVC 3003s Sr 12* Mitor (Terated Cate Valve - 10109 Limitoryse SMB-005-10 c2 6.2.2.2 Ana (4a) IVC 3001A Operator e2 6.2.2.2 Ana (4a) tyc3colg k e$ SF 3" retor operated Cate Velve - 10109 Limitorpe SMB-000-2 c2 6.2.2.2 A8a (4a) , ivc 1802A Pd- (D sycrator to rr c2 6.2.2.2 Ata (4a) IVC 30023
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D Ut Sr 12" tetor operated Cate Valve -
Operstar 10109 Limitorpe SMB-00-5 al a2 6. 2. 2. 2, 6. 2.4 Asa (4a) IVC 30rnA al a2 6.2.2.2, 6.2.6 Ana (4a) IWC3804s e2 6. 2. 2. 2 (4a)
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rurchase III Order Safety Function, Srstem Equipment Description munbe r Reference FSAR Manu f ac t u re r TYPE. Model maaltcy Egelpment CateRorT( SecttOn 1pcation( }
sr geactor Benfiding spray 10162
, Time Tag Samby rump Motor Ceneral Electric K Nortaontal c2 6.2.2 Frame 8210s Ala (4a) c2 6.2.2 Mrt0038A ABa 5K821055c44 (4a) MPlH038B Sr Reactor svildtag Spray 10240 Rosemount rump Discharge Flow Il53DA4 c2 6.2.2.5, 7.5, Asa Tabla 7.5-1 (La) IFT7368 c2 6.2.2.5, 7.5, Asa Table 7.5-1 (4a) IFT1378 ss !" Air Opeented Ball valve - 10229 ASCO solenoid Nr 8328A5E al,a2 6.2.4. 9.3.2 RBe (ba) al,a2 6.2.4, 9. 3.2 IVA9311A Ese (4a) a2 6. 2.4, 9. 3.2 IVA9312A Wre (4a) a2 6.2.4, 9. 3.2
- XYA93Elt ss Wrc (4a) maclear Samptles Systee 10482 valcor XVA93123 loolation Solenoid valves V526-5293-6 al 9.3.2 maa al 9.3.2 (4a) KVI9356A Esa (4a) al 9.3.2 Rad IVI9356s al 9.3.2 (4a) ITI9339 Rab al 9.3.2 (4a) ITx9364s tsa (As) b2 9.3.2 IVI9364C Wrts ita) 62 9.3.2 IYt9357 SS Wra (4a) meclear $smeling System zvx9365s 10482 Valcor V526-5295-6 b2 faolation Solenoid valves 9.3.2 Era b2 9.3.2 (4a) KVX9365C Wra (4a) b2 9.3.2 XVK9187 Wrs (4a) b2 9.3.2 avr1398A Era (4a) b2 9.3.2 KVI93983 ss tra (4a)
I" Air iterated Ball valve - 10229 ttAMCO EA-180 IVI1398C Liett switch (q247857) al a2 6.2.4, 9. 3.2 RB al a2 6. 2.4, 9. L 2 (4a) XV49311A RS a2
- 6. 2.4. 9. 3. 2 (4a) IVA9312A FRa a2 6.2.4, 9. 3.2 (4a) AvA93113 SW 16" Motor Operated Cate ras (4a) 10109 XTA9312s valve - Operator Limitergse SMB-00-l$ b2 6.2.4 Wrc a2 9.2.1 (4a) XYC3103A SW Wre (4a) 12" Mastor operated Cate valve
- 10109 Limitorque ivc 3107A Eyerator SMS-00-10 m2 9.2.1 Wrc (4a) a2 9.2.1 XVC3111A SW Wre (4a) 16" Motor Operated Cate Valve - 10109 Lieltorque XVC3112A operator SMB-00-15 (14) 9.2.1 FR (14) 9.2.1 (4a) KVC34038 SW FS (4a) 12" Peter (Wrated Gave Valve 10I09 Limitorge IVC 31073 SMD-00-10 (14) 9.2.1 FS (14) 9.2.1 Fa (4a) IVC 3llit (4a) ivc 31126 e O *
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Purchase Safety Function -
g . Order beforence FSAR tystyment Systee Equipment Description Ihambe r flanufacturer Type teodel leumber Categorv Section locatten Time Tea member SW 2" Air operated clobe Velve - 10172 ASCO tere 323 el.a2 9.2.1 Ree (4a) Iv73164 Solenald al a2 9.2.1 age (4a) IVT3165 al,e2 9.2.1 Ree (4a) XVT3I69 SW 16" pecor Operated Butterfly 10200 Limitorque Spe002/N2hc a2 6.2.4, 9.2.1 WFb (4a) IVs3106A Valve - Operator '
SW 12" Motor operated Butterfly 10200 Limitorque 5Me0002/tenec a2 6.2.4. 9. 2.1 WPb (4a) IVB3tt0A valve - Operator SW Service Water Booster rump 10039 1 suis Allie COC58/449fS frame c2 9.2.1 ' Isa (4a) perp0045A Motor c2 9.2.1 Ita (4a) perF00453 SW RTD, Service Water Temperature 10231 ryco 122-4030 b2 7.5, Table 7.5-1, Wre (4a) 17:4467 out of teactor avliding 9.2.1.5.6 Cooling Unite SW Servire Water Booster Ftsmp 10240 Rosemount il53DA4 c2 7.5, Table 7.5-1, WFb (4a) ' IFT4466 Discharge Flow 9.2.1.5.6 c2 7.5 Table 7.5-1, WFb (4a) - IFT44C i 9.2.1.5.6 SW 2" Air Operated Globe Valve - 10172 NAMCO EA-180 al,a2 9.2.1 RSe (4a) IVT3164 Lielt Switch (Q247857) al,a2 9.2.1 Rae -(4a) 3773165 al,a2 9.2.1 ase (4a) ' AVT3169 VL Faergency Feedwater rump 10222 Rettance TF.A0 c2 9.4 184 (4a) IFN0083A Area Cwling Unit Fan tenter c2 9.4 Ild (4a) 1FN00838 VL Service Water Booster pump 10222 Reliance TEA 0 c2 9.4 Igo (4a) KFHOOGIA Area Coollag Unit Fan c2 9.4 lse (4a) 3Funosts VL RIIR/ Spray rump Rcuss 10222 pellance TEAO b2 9.4 ABa (4a) 3FunO49A Conting Unit ran Motor . b2 9.4 Asa (4a) XFWOO498 VL Charstes rump Room Cooling 10222 Rettence TEA 0 b2 9.4 Asa (4s) Xfis0046A Unit Fan Motor b2 9.4 Asa IFIgnO463 (4a) b2 9.4 ABa (4a) If1s0047 VL Austliary tutiding Motor 10222 Reliance TEAO c2 9.4 A8d IFH0132 Control Center and Switchgear (4a)
Air limmtling tlutt Fan Peter M C/3 m D*
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Furchase Saf ety Funca ten, order Reference FSAR Equipment Syste*III Ee t rument Desertption feiamber Manufacturer _ Type. Model thamber Categorv III Section Locatice II Tiene gpy t' L 3* Clobe Valve - Solemote 10001 ASCO 63no al.c2 6.2 Rsa (4b) ICV-1003 Sil6 (14) 6.2 pg ylg tL 3/4* Clobe valve = solenoid 10001 ASCO 8316 al.c2 6.2 33a (4b) 7126 (14) 6.2 y, ;:5g WL 3/4" Clobe valve - Liest 10001 NAMt0 EA-180 al.c2 lateb-tm R8a (4b) 2126 Switch (14) La t ch-in r3 2130 wl. 3" Clube Valve - Limit Switch 10001 RAMID EA-180 (14) Latch-tm yg yg g
- 600 volt Control Cable 10146 Kerste FR-FR al,a2.bl b2 8.3.1.4.3 va rt oins (4a) EK-st(IO) 600 volt rower Cable 10147 Kerite ItT-FR al,a2,bl.b2 8.3.1.4.3 Vartaue (4a) EK-A24I8I (4a) Er-A1(IO)
Instrument Cable 10150 Sannel Moore Ertm - Repalon et.a? bl b2 8.3.1.4.3 various (4a) Eg-Cl(10)
- 8 kV rower Cable 101 % okoette EPR - Hypalom af,b2 8.3.1.4.3 tbtstJe R3 (4a) tr-AIO8)
- Cable Tray OII 10169 T. J. Cope Co. (12) al a2 3.10.2.1.1 Various (4a) -
Triastal cable 10184 soston tasolated ILFE-Tefsel cl.c2 7.2.1 vartaus (4a) EE-C2a(10)
Wi re ILrt-typalon cl.c2 7.2.1 Various (4s) FK-C2bO8)
- Switchboard Wire 10474 Rockbestos Firewall SIS al,af,bl,b2 8.3.1.4.3 Various (4a) EE-J9 IW
= 2/C #18 Twines cable 10174 Rockbestos RSS-6-ll2 al,a2 5.6.2-c (flow Inside Es (4 a) EK-J9(c)(IO) indication)
Switchhoard Wire 10727 Ra yc hen Flantrol al,a2,bl b2 8. 3.1.4. 3 various (4s) Ex-J200)
- Trey Supports and Conduit HA Shop 6 fleid (12) al,a2 8.10.2.1.1 Var toa s (4a) -
Supporte fabricated
- Miscellanenus Connectore 10249 D. C. O' Bries C39r0001-col al a2 bl b2 (1) Various (6a) EL-44.a(10)
C39rl01-Cn1 al,a2 bl,b2 (5) Various (4a) EL-44aa(10) tew Volt efte rower Terminat ions 10146 twtaide Reactor Building Tape Bislapp St-Scal 3 b 2,c 2 (13) theside R3 (4a) FEt6aOO)
Tape scrite Friction b2 c2 03) owtelde as (4 a) Fr:4a(10)
Tape 3M Scotch No. 83 vinyl b2.c2 (13) Outside 33 (4a) E315bII8I srlicing Ceecat Kerite Nome aestgmed b2,c2 (13) (htside R3 (4a) Ett4c(10)
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CIASS IE EGitPPENT jit3LIECT TO MARSH ENVIR00sENTAL CEMIDITI(DIS Purchase Safety Function, order lysten Refer nee FSAR squiement
_ Equipment Description _lhmber Manu f acturer Catcaprv(2)
Type. Mmlal Number Section IAcetton II Time lagjpuebog
= low voltage rouer Terminatione 10146 Inside Reactor But tding Tape Recite Type I Tape al,al.bl b2 (13) Rs various (4a) ggt 4g(IO)
Eearney Airaeal al a!,bl,b2 (13) Rs Various (4a) EstFa(10) 8 kV Cable Terminations 10464 Teraleast Insulating Material Insulatins Tape okontre T95 a2 (13) netside Rs Jacketing Tape Ukomite T35 (4a) EKt3aO8) a2 (13) estside as Cement Okontte 604-45-8804 (4a) Est3 BOO) a2 (13) outalde Re (La) Ext 3 COO) 8 kV Cable Terminations 10465 For Component Cooling Raychem Therenfit NYT-CsN a2 Nater Pump Motor (13) Isa (4a) Egg 2e(10)
For Charging rump Motor Raychem Thereofit ItVT-CBN b2 and Transfer Switch (13) ABa (4a) EK12e OI For Emergency Feedwter Pimp Raychem Thermaftt HVT-CsN a2 (13) Isa (4a) EKt2aII8)
For Spray Pimp Motor Raychem Thermofit NVT-CsN c2 (13) Asa (4a) EKt2a O'*l Control Cable Terminations 1G%7 tmtside Reactor sutIdina Tape Kertte Type I a2,b2 Tape (13) outalde Re (4a) EKt4 BOO)
Kerite Friction a2 b2 Tape (13) miteide Re (4a) eel 4aOO) 3M Scotch No. 33 Vlayl a2,b2 _(13)
Tape Outelde RB (4s) (13 )
3M Scotch No. SS Vinyl a2,b2 Splicing cement (13) Oitaida 83 (4a) EK15 BOO)
Eertte None assigned a2,b2 (13) notaide Ra (4a) Egi4 COO)
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[k CIASS IE Ect'IPMENT tJ St'53ECT TO flAR$lt ENvlRONENTAI. CtWDITIONS PJ purchase Safety Function, Order Reference FSAR Eges t pment SysteisO) Equipment Description Number Manu f ac tu re r EstemoryIII Type. Model thunher Section Iscation UI Time Tag Ik h Control Cable Terminations 10467 Inside Reactor Building Splicing Sleeve Raychem WCSF al a2 bl.b2 (13) RB various gKt9aOO)
Cable greakout (4a)
Raychean 302A812 al,a2,bl.b2 (13) Ra various (4s) EKt9b00)
Anatrument Cable Terminations IC467 Sleeve Raychem WCSF al,s2.bl.b2 (13) Rs various Ha) grigeOO) s
_ NOTE:
- l. System designettons are as follows:
AC - CR11H Cooling ES - Electrical System 9tl - ilsta Steen SS - Seelear Sae911ag AH - Air Handling ET - Heat Tracing ND = Esclear Plant Drains 3D - Steam Cenerator glowdown SW = Service Water FS - Fire service N1 - meclear lastrumentation Vh = local ventilation CC - Component cooling Water FW - Feedwater RC - Reactor Coolant Wi. - Radweste Liquid Handling Cl - Industrial Cooling Water tit - Post Accident H2 Removal RH - Residual Heat Removal - - None Assigned CS - Chemical 6 volume control I A - Instnament Air St - Safety injection FF = Fmergency Feedwater LD - Leak Detection SF - Reactor Building Spray
- 2. Definitions of categories are as follows:
at - Equipment that could esperience the environmental conditions of design baste (1/ICA) accidents for which it enest function to mitigate said accidente and that is gesatified to damonstrate operability in the accident envirovement for the time required for accident mitigation with safety margin to failure.
a2 - Equipment that could experience the envirormnental conditions of design baste lane break accidents, including main steam line break and other If ne breaks, for which it must function to mitigate said accidents and that is qualified to desmonstrate operability in the accident envirosament for the time required for accident mitigation with safety margin to failure, al* = Equipment that could experience radia:lon exposure during post-141CA recirculation.
bl - Equipment that could experience environmental conditions of design basis (IACA) accidents through which it need not fanction for mitigation of said accidente, but through which it unast not fall in a manner detrimental to plant safety or accident mitigation, and that la qualified to dennonstrate the capability to withstand any accident envirossment for the tiene during which it enest not fall with safety margin to f ailure, b2 -E$1pment th.et could experience envirurumental conditions of design basis line* break accidents, including main steam line break and other line breaks throuth which it need not function for mitigation of salJ accidente, but through which it enast not f a!! in a manner detrimental to plant safety or accident mitigation, and that is spealified to demonstrate the capability to withstand any accident envirorument for the time during which it maest not f all with safety margin to failuce.
ble - Equipament that could experience radiation exposure during post-accident recircuP .*on.
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TABt21aI*I CIASS lE EGJIFIEIIT SUBJECT To luSSit SIIVinutteElffAL Ct41DITIngl5 IIFTES (Continued):
el - Eerstroent that could emperience environmental conditions of destEn beste (tsCA) aceteents through which it need not function for mitteation of sold accidente, and ediese fat ture (in any mode) la deemed not detrimental to plant safety or acctJent mitigation, and need not be apsaltfled for any accident environment, but to gealtited for the monaccident service enetrosament.
c2 - Eipsipment that could experience envirorumental conditions of design basto line break accidente, including main steam line break and otIner line breaks, through which f a need not function for mitigation of said accidente, and whose failure (in asey mode) to deessed not detrimental to plant safety or accident mitigation, and mese Nt 8e geallfled for any accident environment, best to giallfled for the nonaccident service envirosmient.
(
Reference:
FSAR Section 3.11.1)
- 3. 1, atione are me follows:
Rsa - seactor Dutiding - Elev. 412'-0" (poone 12-01 m 12-08 IIE, 12-01 SE, 12 02)
Rab - Reactor Dutiding - Elev. 412'-0" (Room 12-01 SW)
Rec - Reactor Dutiding - Elev. 412'-tr' (Roemas 12-03 through 12-08)
Rad - Reactor testiding - Elev. 436'-0*
BBe - Reactor mutiding - Elev. 463*=0" Ita - Intermediate sullding - Elev. 412'-0* (except Rousse 12-03 through 12 00 and 12-12 through 12-15)
IBh - Intermediate Building - Elev. 412'-0" (Roosne 12-03 through 12-08, only) lac - Intermediate tutiding - Elev. 412-0" (Roome 12-12 through 12-15) led - Intermediate Building - Elev. 423'-0" (Roosne 23-01 and 23-02)
IBe - laterusediate butiding - Elev. 426'-0" (Roome 26-01 and 26-02) ta f - Interusedtete Butidtag - Elev. 436'-0" (except Roome 36-01 and 36-03 through 36-07) lag - Inte: mediate Buildtag - Elev. 4360* (Roome 36-01 and 36-03 through 36-07, only)
IBh - Intermediate Bat tdtng - Elev. 451'-0" (pocens 51-01 and 51-02) 181 - Interisediate Butiding - Elev. 451'-0" (moome $1-03 and 51 a%)
IB) - Intermediate Butiding - Elev. 463'-0*
WFa - West Penetration Access Area - Elev. 412'-O" Wrb - West renetretton Access Area
- Elev. 436'-0" Wie - West renetration Accese area - Elev. 463'-0" Era - East Penetret ton Acces* Area - Elev. 4128-0" Erb - East Penetration Access Area - Elev. 436'-0*
FB - Fuel ttandling Lutiding - all elevattoes Asa - Auntilary autiding - Elev. 374'-0", 388 '-0", 19 7'-tr*, 400'-0*
Akb - Austilary Dutiding - Elev. 412'-0", 426'-0", 436'-0", 448'-0", 443'-0" (except Roome 12-28, 26-02, 36-13, 63-01)
Asc - Austilary Building - Elev. 463'-0" (Room 63-01)
ABd - Auxiliary Building - Elev. 412'-0* (Ronse 12-28)
ABc - Austliary Building - Eley, 436'-0" (Roose 36-13) .
Asf - Austilary Butiding - Elev. 426*-0" (Roome 26-02, two locations)
TS - Turbine Building - Elev. 436'=0*
4a. See pares B-0 through n-73.
- c (n 4h. See pages W-0 through W-21.
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SUBJECT TO HARSil ENVIRfMFNTAL CIMITIONS ElJTF (Cont isnseJ):
- 5. Refer to response to unc q>estion 031.46 in FSAR.
- 6. Valees are located inside containment isolation valve containers to satisfy the requirements of CDC56. These valves could be esposed to IECA/ mala stems break in the highly untately event of fatture of the ASME Code boundary.
- 7. Cneronents were purchased as spares for Square D sootor control centers.
- 8. See FSAR ApPendlE 3A Regulatory Culde 1.75, paragraph 2.d.
- 9. rest accident ani.itoring only.
!!. stil of material number.
- 11. Cable tray, tray supports, and conduit supports are seismic Category I and have been structurally qualif ted as described in FSAR Section 3.10.2.1.1. Houever, they are not Class it and therefore no specific environnental quattitcation has been perforused.
- 12. Custom designed equipment without type or model deatsnation.
- 13. Safety function is malatenance of insulation integrity.
- 14. narsh environment consists of 100 to 10 RADS during fuel drop accident, equipment is spealified for operation in the normal or abnormal environment.
0
- 15. Harsh environment consists of approximately 10I RADS during LOCA and%10 to 10 RADS during f asel drop accident; equipment la qualtfled for operatico in the normal or at normal environment.
16 Harsh environment consists of 1.2 m 106RADS during LOCA; equipment is qualif ted for operation in the normal or abnormal envirosmient.
- 17. Close at rectreulation.
18 Field purchase.
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( .
TABLE 1.2-2 SYSTEMS REQUIRED FOR ACCIDENT MITIGATION AND COLD SHUTDOWN Accident Cold System Mitigation Shutdown
- 1. Reactor Triy X X
- 2. Reactor Coolant X X
- 3. Main Steam (to isolation valves) X X
- 4. Emergency Feedwater X X
- 5. Chemical and Volume Control (except letdown) X X
- 6. Residual Heat Removal X X
- 7. Component Cooling (safety grade portions) X X
- 8. Service Water X X
- 9. Chilled Water X X
- 10. Certain Heating, ventilating, and Air Conditioning X X
- 11. Diesel-Generator / Engine (and auxiliaries) X X U 12. Class IE Electrical (Emergency AC'& DC Power) X X
- 13. Main Feedwater (to isolation valves) X X
- 14. Safety Injection X
- 15. Hydrogen Control X
- 16. Containment Spray X
- 17. Containment Isolation X
- 18. Engineered t afety Features Actuation System X D
0 Shant 1 of 1 Revision 3
TABLE 1.2-3 h INSTRUME~t!2ATiON FIQU!fM FOt .tCCIDENT MITIGATION AND COLD SHUTDOWN I. 'Weactor Trip System Instrumentation
- a. Nuclear Instrumentation (Power, Intermediate, Source Range)
- b. RCS Temperature (Narrow Range)
- c. Pressurizer Pressure
- d. Pressurizer Level
- e. RCC Coolant Flow
- f. Reactor Coolant Pump Undervoltage*
- g. Reactor Coolant Pump Underfrequency*
h, Feedwater Flow
- i. Steam Generator Level (Narrow Range)
- Not required for high energy line breake. Ref. FSAR Table 15.4-21.
II. Engineered Safety Features Instrumentation
- a. Reactor Building Pressure
- b. Pressurizer Pressure
- c. Main Steam Line Pressure
- d. Steam Generator Level
- e. RCS Temperature
- f. Main Steam Flow III. Safety Related Display Instrumentation i
- a. Wide Range T and T hot eold I
- b. Pressurizer Water Level
- c. Reactor Coolant System Wide Range Pressure l
- d. Reactor Building Pressure (1) Narrow Rant,c (2) Wide Rauge 91 Sheet 1 of 2 Revision 3 l
. 1
l l
TABLE 1.2-3 (Cont'd)
- e. Steam Line Pressure
- f. . Steam Generator Water Level (narrow or wide range)
- g. Refueling Water Storage Tank Level
- h. Boric Acid Tank Level (2 tanks)
- 1. Reactor Building Spray Pump Discharge Flow
-j . Reactor Building Temperature
- k. Reactor Building Residual Heat Removal Pump Sump Level
- 1. Reactor Building Level
- m. Condensate Storage Tank Level
- n. Energency Feedwater Flow
- o. Reactor Building Cooling Unit Service Water Flow
- p. Service Water Temperature into a-' out of Reactor Building Cooling Unit
- q. Sodium Hydroxide Storage Tank Level
- r. Hydrogen Concentration
- s. Reactor Vessel Level O
Sheet 2 of 2 Revision 3
F$ TABLE 1.2-4 12 E" ITEMS EXEMPT FROM QUALIFICATION 9~
m System (1) Equipment Description P.O. No. Manufacturer Type /Model Tag No. Justification AH Solenoid Valves for 10188 ASCO 8320 XDP0012A DR 64, Item 6 Air Dampers XDP0012B All Limit Switch for Air Q247857 NAMCO EA180 XDP0012A DR 66, Item 8 Dampers XDP0012B XDP0013A XDP0013B CC 8" Motor Operated 10109 Limitorque SMB-000-5 XVG9625 DR 61, Item 7 Cate Valve - Operator XVG9626 CC 20" Motor Operated 10200 Limitorque SMB0005/II2BC XVB9503A DR 61, Item 7 Butterfly Valve - XVB9503B Operator CC 16" Motor Operated 10200 Limitorque SMB0005/H2BC XVB9524A DR 61, Item 7 Butterfly Valve - XVB9524B Operator XVB9525A XVB9525B CC Component Cooling 10240 Rosemount 1153DA4 IFT7263A DR 47, Item 8 Water Flow to IFT7263B Reactor Coolant Pump Bearings CC Component Cooling 10240 Rosemount 1153DA4 IFT7273A DR 49, Item 8 Water Flow to IFT7273B Reactor Coolant Pump Thermal Barriers O O O
l O O O TABLE 1.2-4 (Continued) -
System (I) Equipment Description P.O. No. Manufacturer Type /Model Tag No. Justification CS Safety Injection Pump 10207 Terac Gould FPL-C XET2002C DR 18, Item 7 Transfer Switch ES Motor Control Center 10198 Square D Model 4 XMCIDA2Y DR 34, Item 9 ES Electrical Penetration 10249 D.G. O' Brian Triax XRP0043 DR 30, Ites 11 Triax Connectors Connector XRP0044 XRP0045 XRP0046 ES Power Transfer and NA Field Components XPN0040 DR 17, Item 5 Motor Control Panel fabricated were purchased for Charging Pump C as spares from Auxiliaries Square D MCC FW Feedwater Flow 10001 Barton 752 IFT0476 DR 7W, Item Id DP Transmitters IFT0477 IFT0486 IFT0487 IFT0496 IFT0497 HR Reactor Building Q262584 Consip, Inc. X-III XPN7215A DR 69, Item '.
Hydrogen Analyzer XPN7258A ,
Panel and Remote XPN7258B Control Panel ff HR Hydrogen Recombiners 10001 Westinghouse N/A XPN0049A DR 8W, Item I ga Control Panel / Power XPN0049B gg Supply XPN0049C o XPN0049D o
wm
- os HR Narrow Range 10001 Barton 752 IPT-950 DR 10W, Item 1 Containment Pressure IPT-951 Transmitters IPT-952 IPT-953 s
- c en QT TABLE 1.2-4 (Continued)
CS .
Ei w "n System (1) Equipment Description P.O. No. Manufacturer Type /Model Tag No. Justification Y**
IIR Reactor Building Wide 10240 Rosemount 1152AP7 IPT0954A DR 58, Item 9 Range Pressure IPT0954B CR 57, Item 8 HS First Stage turbine 10001 Barton 752 PT-446 DR 7W, Item Ic Pressure Transmitters PT-447 MS Steam Flow DP
- 10001 Barton IFT0474 DR 2W, Item 7 Transmitters IFT0475 IFT0484 IFT0485 IFT0494 IFT0495 NI Power Range 10001 Westinghouse Dual Section NC-41 DR 3W, Item 1 Neutron Detectors Ionization NC-42 Chamber NC-43 NC-44 RC Reactor Coolant Flow 10001 Bartoe 752 IFT0414 DR 7W, Item la DP Transmitters IFT0415 IFT0416 IFT0424 IFT0425
- IFT0426 IFT0434 '
IFT0435 IFT0436 RC Air Operated Valves - 10001 ASCO 8316 8033 DR 10W, Item 1 Solenoid 8028 RC etem Mounted Limit 10001 NAMCO EA-180 8033 DR 10W, Item 1 Switch 8028 O O O
p ,
O O O
' TABLE 1.2-4 (Continued) -
System (I) Equipment Description P.O. No. Manufacturer Type /Model Tag No. Justificatdon SI 12" Motor Operated 10001 Limitorque SBD 8808A DR SW, Item 7
' Gate Valve - Operator 8808B 8808C SI 3" Motor Operated 10001 Limitorque SB-00 8801A DR 10W, Item 1 Cate Valve - Operator 8801B E803A 8803B SI Diaphragm Valve - 10001 ASCO 8316 8945A DR 10W, Item 1 Solenoid 8945B 8942 SI Stem Mounted Limit 10001 NAMCO EA-180 8945A DR 10W, Item 1 Switch ~
8945B 8942 SP 12" Motor Operated 10109 Limitorque SMB-005-10 XVG3001A DR 61, Item 7 Gate Valve - Operator XVG3001B SP 3" Motor Operated 10109 Limitorque SMB-000-2 XVG3002A DR 61- Item 6 Cate Valve - Operator XVG3002B SP 12" Motor Operated 10109 Limitorque SMB-00-5 XVG3005A DR 61, Item 6 Gate Valve - Operator XVG3005B SP Reactor Building Spray 10162 General K Horizontal / MPP0038A DR 41, Item 3 Ef y Pump Motor . Electric 8210S frame MPP0038B 5.2 E." SP Reactor Building Spray 10240 Rosemount 1153DA4 IFT7368 DR 49, Item 8
@ *' Pump Discharge Flow IFT7378 w&
. os i
i
EE TABLE 1.2-4 (Continued)
$. 0 I Tag No.
System Equipment Description P.O. No. Mancfacturer _ Type /Model Justification
-
- SP 8 kV Cable Termina- 10465 Raychem Thermofit EK-i2a DR 41, Item 3 tions for Spray Pump IIVT-N Note 2 Motor
.9W Service Water Booster 10240 Rosemount ll53DA4 IFT4466 DR 49, Item 8 Pump Discharge Flow IFT4496 SW Service Water Booster 10039 Louis Allis COG 5B/449TS MPP0045A DR 39, Item 2 Pump Motor MPP0045B VL Auxiliary Bldg. Motor 10222 Reliance TEA 0 XFN0132 DR 50, Item 1 Control Center and Switchgear Air llandling Unit Fan Motors a
WL Diaphragm Valve - 10001 ASCO 8316 7136 DR 10W, Item 1 Solenoid 7150 WL Stem Mounted Limit 10001 NAMCO EA-180 7136 DR 10W, Item 1 Switch 7150 Triaxial Cable 10184 Boston XLPE-Tefzel EK-C2a DR 33, Item 9 Insulated XLPE-Ilypalon EK-C2b Wire O O O
O. O Q ,
TABLE 1.2-4 (Continued)
.e w -
Systeel *l Equipment Description P.O. No. Henufacturer Type /Nodel Tag No. - Justification j -
Low Voltage Power 10146 Terminations
- Outside Reactor Building Tape Bishop Bi-Seal 3 EK-i6a DR 39, Item 2 Tape Kerite Friction EK-i4a Note 2 Tape
~
3M Scotch No. 88 Vinyl FK-i5b Splicing Cement Kerite hone assigned EK-i4c t
NOTES:
- 1. -System designations are as follows:
AH - Air Handling KR - Post Accident H Removal 2
CC - Component Cooling Water SP - Reactor Building Spray CS - Chemical and Volume Control VL - Local Ventilation ES - Electrical System
- 2. These terminations are qualified for accident conditions, but are exempt for specific applications where the associated motors are exempt from harsh environment qualification. ;
YE 1%
an -
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. a,
TABLE 1.6-1 h NSSS QUALIFICATION CONCERNS Component Concern Action Plan
- 1. H2 Recombiner Qualificatio.2 grogram did not Issue to become part of consider aging, and no qualified ongoing plant aging life is provided. program.
- 2. Barton a. Qualification program did Issue to become part of Transmitters not consider aging, and no ongoing plant aging (Lot 2) qualified life was provided. program.
- b. Chemical spray concentration Equipment materials did not envelop plant spray exposed to chemical spray parameters, will be reviewed further to determine suscepti-bility to chemical attack.
- c. A temperature compensation Westinghouse to issue problem resulted in test WCAP 9385 resolving anomaly. concern. Resolution expected prior to August 1981.
- 3. Veritrak Qualification documentation is (;ualified Barton (Lot 2)
O Transmitters not available for review. presently inatalled.
Veritrak to be installed prior to Power Operations to provide independent diverse interlocks.
- 4. Neutron Qualification program did Issu. to become part of Detectors not consider aging, and no ongoing plant aging qualified life was provided. program.
- 5. Rosemount RTD Qualification program did not Issue to become part of consider aging (other than ongoing plant aging for radiation). program.
ongoing plant aging program.
- 7. Valve Motor a. Phenolic switch material Additional radiation level Operators may not withstand high analysis will be performed; radiation during post-LOCA and, if problem still recirculation (for out-of- exists, switches will be containment qualified replaced with radiation actuators). resistant materials prior to power operation. g Sheet 1 of 2 Revision 3.
TABLE 1.6-1 (Continued)
NSSS QUALIFICATION CONCERNS Component Concern Action Plan
- b. Mounting configuration to Problem is under study.
prevent free ingress of If special requirements chemical spray to the are needed, they will be actuator may be required. performed prior to power operations.
- 8. Barton Aging qualification documen- Issue to become part of Transmitters tation is not available for ongoing plant aging (Model 752) review. program.
- 9. Acoustic Qualification documentation is Qualification proposals Critical Leak not available for review. are being developed by Monitoring Westinghouse (CGWS-P-269, System dated 2/5/80). Resolution (Pressurizer expected prior to power Safety Valve operation.
Position Indication) n 10. Oder Documentation of radiation Complete documentation of V Lubricants qualification for plant specific qualification by power lubricants is under development. operation.
L l
V
! Sheet 2 of 2
! Revision 3 .
i
TABLE 1.6-2 O
B0P QUALIFICATION CONCERNS Component Concern Action Plan
- 1. Kerite 600 Qualification report did not Problem is being Volt Power completely explain certain discussed with Kerite.
Cable failures and the aging time Resolution is expected and temperature were not prior to full power fully justified. operation.
- 2. Kerite 600 Qualification report did not Problems are being Volt Control completely explain certain discussed with Kerite.
Cable failures and the aging time Resolution is expected and temperature were not prior to full power fully justified. operation.
- 3. Kerite Cable Qualification report specified Problem is being Splicing materials somewhat different discussed with Kerite.
Materials from those recommended for use Resolution is expected (Including by Kerite. Also, certain prior to full power Kearney Air failures in the available operation.
Seal & Scotch documentation are not Brand Tapch) completely explained.
lll
- 4. Limitorque a. Qualification documentation Lette.rs concerning the Valve Motor does not clearly specify problem have been Operators whether vent / drain valves written to Limitorque.
are required. Responses with suitable documentation are expected prior to fuel loading.
- b. Mounting configurations to Problem is under =tady.
prevent free ingress of If special installation chemical spray to the requirements are needed, actuator may be required. they will be performed prior to power operation.
- 5. Service Water Qualification documentation did A purchase order for Booster Pump not address radiation resistance providing necessary Motor and did not provide sufficient information has been information concerning operation issued. Resolution of for under extremes of voltage of these problems is and frequency. expected prior to full power operation.
O Sheet 1 of 5 Sheet 1 of 5 Revision 3 . Revision 3
(s,) TABLE 1.6-2 (Continued)
~
Component Concern Action Plan
- 6. Electrical Qualification was started late. A letter has been written Penetration Qualification report dated to D. G. O'Brien Triax 2/11/81 has been received. concerning ais problem.
Connector Minor cosevnts concerning this Response is expected report must be resolved. ,
prior to fuel loading.
- 7. Okonite Aging time and temperature A letter is being written Tapes cannot be related to to Okonite requesting the definitive qualified life. necessary information.
- 8. Rosemount Qualification report does not This will be addressed in Pressure address aging, the plant aging rrogram.
Transmitters
- 9. ASCO Solenoid Qualification files are Complete the qualification Valves for currently being prepared to files and update applicable the following cover replacement solenoid BOP foldout pages and DRIs.
Westinghouse valves. See Table 1.6-3 for supplied air replacement schedule.
operated valves p
( XVT-8149A-CS XVT-8149B-CS XVT-8149C-CS '
XVT-8154-Cd XVT-8153-CS LCV-459-CS LCV-460-CS XVT-8145-CS XVD-8047-RC XVT-8875A-SI XVT-8875B-SI ..
XVT-8875C-SI XVT-8871-SI LCV-1003-WP XVD-7126-WL XVT-8152-CS XVT-8880-SI XVT-8860-SI XVT-8961-SI PCV-444B PCV-445A PCV-445B Sheet 2 of 5 Revision 3 .
1 TABLE 1.6-2 (Continued) lh Component Concern Action Plan
- 10. ASCO Solenoid Chemical spray degraded a Solenoid valve functions Valves solenoid coil during will be reviewed to qualification testing for in determine if valves fail containment use. to safe position. If any solenoid must remain energized to accomplish safety function, a sealed solenoid enclosure will be required. Resolution of this concern will be accomplished prior to power operation.
- 11. ASCO Solenoid Solenoid valve is required to GAI is obtaining additional Valve on be energized in the accident test data from Asco.
Valves environment; however, the Asco XVT-2662B-IA report does not qualify solenoid XVT-9627A-CC valves to this condition.
XVT-9627B-CC IFV-3531-EF IFV-3541-EF g IFV-3551-EF W IFV-3536-EF IFV-3546-EF IFV-3556-EF
- 12. Hydrogen Qualification repert review Complete review.
Analyzer and not complete.
Analyzer Remote Control Panels
- 13. High Range Qualification report review Complete review.
Radiation not complete.
Monitor
- 14. PYC0 RTDs a. RID joints may require Vendor will be contacted sealant to prevent chemical to determine need for a spray ingress. suitable sealant.
Resolution is scheduled prior to fuel load,
- b. Vendor stated qualified Extended replacement period life is 2-1/2 years. will be determined by the Extended replacement plant aging program.
period is desired.
O Sheet 3 of 5 Revision 3 .
h TABLE 1.6-2 (Continued)
Component Concern Action Plan
- 15. D. G. O'Brien a. The duration and pH of the A letter is being written Electrical spray used in the LOCA to D. G. O'Brien concerning Penetrations simulation is not defined this problem. Resolution in the qualification is expected prior to full documentation. power operation,
- b. Verification of Documentation is being applicability of report assembled. Resolution is to installed equipment scheduled prior to fuel is required, load.
- c. Thermal limitg may be Additional analysis of exceeded by I R heating this concern is under way.
resulting from submerged Resolution is expected cables. prior to power operation.
- 16. Solenoid corroded D. G. O'Brien Evaluation in progress to Valve connectors found in installed be resolved prior to power units at site. operation.
- 17. NAMCO Limit a. Qualified life is not 'Ihis will be addressed in Switches clearly specified. the plant aging program.
- b. Scaled electrical Field verification confirms connections are not problem. Required sealed installed on switches that connections to be installed must function post - DBE prior to full power in the reactor building. operation.
- 18. NAMCO Limit Certificate of compliance to Vendor has agreed to Switches for verify qualification report resolve. Completion of Air Duct applies to equipment that has this item is expected by Dampers not been received. fuel load.
- 19. Component Motor reinsulated with polyester Westinghouse requested to Cooling Pump based varnish. Certification to provide backup documentation Motor A environmental requirements and certification.
outstanding. Resolution to be obtained prior to fuel load.
- 20. Rotork Valve Qualification report review not Review of report is Motor Operator complete, underway. Completion of review is expected prior to fuel load.
O L'
Sheet 4 of 5 Revision 3 .
TABLE 1.6-2 (Continued) lll Component Concern Action Plan
- 21. Harsh Verification of harsh radiation Review in progress to Radiation dose calculations not complete. verify calculations.
Environment Scheduled for completion Analysis / prior to September, 1981.
Calculations
- 22. Average Verification of average Review in progress to Temperatures temperatures not complete. verify calculations.
Presently under review.
- 23. Reliance Fan Proprietary data at Reliance Data will be audited prior Motors for has not been audited. to fuel load.
Auxiliary Buildings
- 24. Reliance Fan Proprietary data at Reliance Data will be audited prior Motors for has not been audited. to fuel load.
Reactor Building Cooling Units
- 25. Raychem WCSF A qualified life has not been Raychem is being contacted g and Breakouts established. for assistance. W
- 26. Isolation a. A qualified life has not This issue will be addressed Fuses in Heat been established, in the plant aging program.
Tracing Panels
- b. Post Accident Operability Problem is being studied and Requirement has not been Post Accident Operability Time determined. will be established.
- 27. Odor Documentation of radiation Complete documentation of Lubricants qualification for plant specific qualification by power lubricants is under developnent. operation.
- 28. Operability Several Components do not ,how Provide calculations to Demonstre.ted enough post accident time in extend the qualified post Tine operability demonstrated column accident time demonstrated to envelope the post accident to exceed the post accident time required. time required.
O Sheet 5 of 5 Revision 3 .
l
~
(v ') TABLE 1.6-3 LIST OF EQUIPMENT SCHEDULED FOR REPLACEMENT Item Replacement Reason for Replacement Status and Scheduled Wide Range Wide Range Additional element Detectors placed in RTD; RTDS (Pyco, required for CRE Panel storage to prevent (Rosemount) Model 22-3006) and Tech. Support Center. being damaged during construction.
Scheduled to be replaced prior to fuel load.
Reactor Veritrak To provide independent Barton qualified Coolant diverse interlock for model presently System Wide RHR Isolation Valves. installed. Scheduled Range to be replaced prior Pressure to Fuel Load.
Transmitters Barton.Model ASCO Solenoids ASCO Qualification not Bill of Material 8149 A, B,&C (Qualified) required when Scheduled to be 8154 originally purchased. issued by 1 August, s 8153 1981. Scheduled to s) 8145 8047 be replaced prior to Power Operations.
8175,A,B,&C 8871 LCV-1003 7126 PCV-444B PCV-445A PCV-445B LCV-459, 460 XVT-8152-CS XVT-8880-SI XVT-8860-SI XVT-8961-SI Sheet 1 of 2 Revision 3 . ,
l
TABLE 1.6-3 h LIST OF EQUIPMENT SCHEDULED FOR REPLACEMENT Item Replacement Reason far Replacement Status and Scheduled Stem Mounted NAMCO Type NAMCO Type EA-170 not Presently being Limit Switches EA-180 properly qualified under replaced. Scheduled (NAMCO EA-170) QA program to be replaced prior 7126 to fuel load.
8701:
8702A 8047 8149A,B&C LCV-459, 460 8871 PCV 444B PCV 445A PCV 445B XVT-8152-CS XVT-8880-SI XVT-8860-SI XVT-8961-SI XVG-8809A-SI XVG-8809B-SI XVG-8706A-RH XVG-8706B-RH l
O Sheet 2 of 2 Sheet 2 of 2 Revision 3 Revision 3 .
1 i
e O
Westinghouse Supplied Safety Related Electrical Equipment
~ .
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4 c 's ! l NOTES FOR-WESTINGHOUSE SAFETY RELATED
. ELECTRICAL EQUIPMENT
.(1 ) Pressurizer level has been deleted as a safety -related trip function.
-(2)
Note'2 is not applicable. (3) The recombiners are qualified to 309'F per the NRC acceptance
- letter dated 6/22/78 (4) Designed to [ ] a,b,c.
(5) The reactor coolcnt flow transmitter is only required to perform a safety function for contained faults. There are no adverse environments present when-this instrument must perform its safety function. (6) The accuracies are changes in the transmitter accuracy due to
- severe environments. The error during normal and abnormal conditions is 11% of span. These errors do not include the channel inaccuracies. ,
f- The 11% accuracy is the instrument error during normal and (j) (7) abnormal conditions. _(8) The +0.2% accuracy is the calibrated accuracy of the Resistance Temperature Detector (RTD) under normal, abnormal, DBE or post-DBE conditions. (9) Harsh environment consists of the radiation environment following a fuel drop accident. (10) Note 10 is not applicable. (11) Note 11 is not applicable. (12) Note 12 is not applicable. (13) Fidure and table references in parentheses are from the qualification reference and give the temperature and/or pressure profile. (14) In general the parameters listed under qualified environment are ~ actual test conditions which may exceed the testing requirements. W-20
,-~ Revision 3
(_)- i m.-
O (15) Equipment that could experience environmental conditions of design basis accident (SLB or LOCA), through which it need not function for. mitigation of accidents, and whose failure is not detrimental to plant safety or accident mitigation, and need not be qualified for any accident environment, but is qualified for non accident service environment. See table 3 11 3 of FSAR for ~ normal environment. (16) For 65 minutes at 40*F to 120*F the spray consists of demineralized water containing 1950 ppm to 4000 ppm' boron in the form of boric acid (H B0 3
)3and NaOH ( .68% by weight) at a pH of 9 50. ..
(17) For the next 6 hours at 240*F the spray consists of demineralized water contain 1730 ppm to 3500 ppm boron in the form of H 3B03 and NaOH (0.23% by weight) at a pH of 8.7 (18) For the next 24 hours at 190*F, the spray has the same constituents as described in 17, above. (19) Virgil Summer identification number. (20) Refer to Table 3 11-3 for associated postulated environmental conditions. (21) Post accident monitoring only. (22) The insulation systems tested in.WCAP-8754 are representative of the insulation systems supplied for these motors. (23) The time to full speed is required at the minimum speciff.ed voltage and frequency condition. W-21 Revision 3 g
L
- ks C')
DR-1W , Narrow Range RTD's Rosemount: (1)' NUREG-0588,: Item 2.2(8) states that caustic spray should be incorporated during sinulated event testing with a proper concentration. Chemical spray concentration in the test did
.not envelope plant specific concentration. Westinghouse simulated, as part of the high energy line break testing of RTD's, a chemical spray ' concentration of 1.146 weight percent boric acid and 0.17 weight percent so.dium hydroxide dissolved in water, starting at time zero and terminating after 24 hours. This chemical spray concentration corresponds to a pH of 8 5, which is representative of the range of sump pH values permitted long-term by technical specification. This concentration of chemicals does not envelope plant specific RB spray chemical concentrations which have a pH in the range of 10.0 to 10.7 for the first 47 minutes followed by a drop in pH to 8 7 for the next 32 hours. An analysis was performed to determine the effects of increased chemical concentration on the materials of.the RTD which will be contacted by the RB spray. The RTD materials which can be exposed to chemical spray are 1) the stainless steel housing, 2) the silicone rubber insulated instrument leads with stainless armor braid, and 3) the epoxy housing seal material. The instrument leads are connected to instrument cable by means of Raychem splices enclosed in a junction box. All of the RTD materials exposed
[,s'~J= to chemical-spray are highly resistant to caustic solutions. Therefore, the increased in pH of the RB spray system above the pH level applied during testing will not have a significant effect on post-accident performance of the RTD's. (2) NUREG-0588, Item 2.2 (10), Category II identifies that expected extremes in voltage and frequency should be applied during testing. Westinghouse stated that Westinghouse does not require that power supply voltage and frequency be varied during the HELB simulation. The RTD's are supplied power from a stabilized power supply. As a consequence, the range of electrical parameters employed is extremely small and variations within the permitted range are considered insignificant. . W-22 Revision 3 - V
m - L Barton Transmitters (Lot 2) (1) NUREG-0588, Item 2.2.(8), Category II stated that caustic spray should be incorporated during simulated event testing with a proper concentration. Chemical spray concentration did not envelope plant spray parameters. Westinghouse simulates, as part of the high energy line break testing of this equipment, a chemical spray conventration of 1.146 weight percent boric acid and 0.17 weight percent sodium hydroxide dicaolved in water, starting at time zero and terminating after 24 hours. This chemical spray concentration corresponds to a pH of 8 5, which is representative of the range of sump pH values parmitted long-term by technical specification. This is an open qualification concern. (2) NUP.EG-0588, Item 2.2(10), Category II identifies that expected extremes in voltage and frequency should be applied during testing. Westinghouse generic position statea that Westinghouse does not require that power supply voltage and frequency be varied during the EELB simulation. Most of the Class 1E equipment to be qualified in Westinghouse scope is supplied by a guaranteed stabilized power supply and power supplies installed at V. C. Summer Nuclear Station provide high precision regulation, tierefore, voltage variation are negligible. Based ca the above, this omission is acceptable. (3) NUREG-0588, Item 3.(4) stated that for equipment required to O perform its function within a short period of time, (i.e., seconds or minutes), the equipment is required to remsin functional for a period of at least one hour in excess of the time assumed in the accident analysis. In the test report, the test conditions envelope the required combined profile throughout the test. However, the most severe environment lasts for only twenty minutes. Teat temperature at one hour beyond time to function is 318'F, which is 6* below the peak temperature ; however, sufficient temperature margin exists earlier in the test to justify a one hour margin at the peak temperature. , (4) NUREG-0588, Item 3. (4), Category II stated that for equipment other than for short time function, 10% time margin may be used. Time margin was not applied to post-accident operability. However, the temperature margin available during testing can be applied to post-accident operating time margins. 'he test report calculated the 4 month operability time basem an an accelerated time calculation using the Arrheniuc echod. The temperature margin between the test profile and the plant temperature profile for the RB corresponds to well in excess of 10% time margin for post-accident operability using the same Arrhenius relation. W-23 Revision 3
i [') DR-2W (5). NUREG-0588, Item 4.2 requires that the effects of aging.should
-be considered. The qualification program for the transmitters did not address aging, nor did it assign a qualified life to them._ These issues will be. addressed in the plant aging program.
(6) NUREG-0588, Item 2.2(3), Category II identifies that test procedures should conform to the guidelines in paragraph 5 2 of IEEE 323-71. Paragraphs 5 2 3 7 and 5 2 3 8_ require equipment mounting and cable connection ~ relevant to qualification. The Barton test report does not address mounting or cable connections used. Westinghouse letter CGWS-1163 stated that mounting and wiring of equipment in the - test was consistent with the requirements defined in the instruction manual. (7) NUREG-0588, Item 2.1(3)(c) states that the bases should be provided for concluding that the failure of equipment in any mode.is not deemed detrimental to plant safety. The transmitters used to determine steam line flow can be subjected to the environmental conditions resulting from a postulated LOCA or-MSLB in the RB. However, the safety function of these transmitters (which is closure of main steam isolation valves (MSIV) on a high steam flow signal) is not (~)
'~'
required to mitigate a LOCA. Following a MSLB in the RB, the transmitters may or may not function, depending on the location of the steam line break, and the safety function of MSIV closure is accomplished by redundant containment pressure transmitters. In addition, the steam flow transmitters are not required to function to conduct a safe plant shutdown. Therefore the steam flow transmitters are exempt from qualification for pipe breaks in the RB. However, the available qualification data indicates these transmit.ters are qualified to function in the postulated MSLB environment thereby providing additional plant safety margin. W-23
.r'S Revision 3 U l
V
) ' DR-37 Power Range Neutron Detectors (1 ) NUREG 0588, Item 2.1(3)(c) states that equipment that need1not function to mitigate any accident and can fail in any mode vitb ,'. affecting plant safety need only be qualified for. the
.stmal environment. The power range neutron detectors may be subjected to the effects of HELB's in containment. FSAR Tables 7 3-4 and 7 3-5 identify instrumentation required for large sand small breaks in primary and secondary piping systems. The neutron detectors are not required to -function t-o mitigate these. postulated events. For the postulated rod ejection accident, for which the neutron detectors initiate.a-reactor trip, the trip function is performed before harsh environmental conditions can develop in the RB. Therefore,
-based on the above discussion, the power range neutron detectors are exempt from qualification for harsh
-environmental service conditions.
The effects of aging induced by radiation and other normal service conditions. and the determination of qualified life of the detectors will be addressed in the plant aging program. ns-W-24 Revision 3
f~ Hydrogen Recombiners DR-4W g (1 ) NUREG-0588, Item 2 3(a) states that equipment that must function in order to mitigate any accident should be qualified by test to demonstrate its operability for the time required in the environmental condition resulting from the accident. WCAP-7709, supplement 5 simulated post-LOCA temperature and pressure transient plus eleven (11) months service under long term post LOCA containment environmental conditions. Failure at the end of 11 months is not considered to be significant due to minimal hydrogen generation from either zinc-water reaction or radiolytic decomposition of water at that time after the LOCA. (2) NUREG-0588, Item 2.2(4) stated that for equipment inside containment, it is preferred that a single profile to be used that envelopes the environmental conditions resulting from any design basis event. The hydrogen recombiner is required to function following LOCA environment. Therefore, the test profile envelopes the LOCA profile only. (3) NUREG-0588, Item 3.4 stated that for equipment which performs its safety function within a long time period, a 10% time margin may be used. Margin was not required in IEEE 323-71 and failur e of heaters at the end of eleven months is not considered to be significant due to minimal hydrogen generation from the zinc-water reaction or radiolytic ll) decomposition of water. Therefore, omission of this item is acceptable. (4) NUREG-0588, Item 2.2(4) stated + hat qualification programs should address aging. Westinghouse has completed later testing of the recombiner to IEEE 323-74 which considers aging. This issue will be aldressed further in the plant aging program. (5) NUREG-0588, Item 4. (9) stated that qualified life of the equipment should be defined. This issue will be addressed in the plant aging program. W-25 Revision 3 4 k!h
y -
~
p. i _ S ) % () Limitorque Valve Operators'Inside RB (NSSS Supply) DR-5W (1 ) - 'NUBEG 0588 paragraph 2.2~(3), Category II, specifies that the test procedure should conform to the guidelines in Section 5 2 of IEEE Std. 323-1971. Paragraph 5.2 requires that the test data accuracy must be specified. The Limitorque qualification report 600456 does not specify'the accuracy for the test data, but it does specify that the test equipment has been calibrated by standards which require periodic calibration.
.Therefore, since adequate conservatism (margin) does exist in the test results, the omission of the test data accuracies is acceptable. Also IEEE-323-74, 6 3 2(5) requires equipment to be subjected to in-service mechanical _ vibration as part of the test sequence. Limitorque operators have been tested for seismic events per IEEE-344-75 Non-seismic vibration is not addressed in the test reports because of Limitorque experience that in-service vibration is 'not a qualification concern.
(2) NUREG 0588 paragraph 2.2 (10), Category II, identifies that the expected extremes in voltage and frequency should be applied during testing. Limitorque tested the valve operators to a voltage extreme only. Since this equipment is not expected to see significant freque=cy changes in its installed service, testing to a fixed frequency is acceptable. () (3) NUREG 0588 Section 4, Category I applies to this equipment. Aging performed on Class B insulated motors and actuators is described in B0058, Section 3 0. Of the aging condition described, synergistic effects of service conditions were not considered. However, aging of the actuator was performed by simultaneous application of elevated temperature, 100% relative humidity, and mechanical aging for 200 hours. The simultaneous application of these conditions had no detrimental effect on the aging procedure or the following test sequence. In addition, for radiation aging, the report states (in Section 2.2 4) that experience shows that, for Limitorque actuators, there is no difference on the equipment as a result of where irradiation occurs in the aging sequence. (4) Identified margins available above specific plant conditions are: Temperature > 48*F (LOCA) Mechanical cycles >100% (above 382-72) - Pressure > 50 psig Two HELB transients Radiation 74% (in RB) fs
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W-26 Revision 3 ; l
1 l DR-5W ll) (5) NUREG-0588 Item 2.2(2) states that testing should demonstrate that equipment can perform its furiction for all services conditions with margin. The plant MSLB profile exceeds the 600456 test temperature by 9'F for approximately 25 seconds. However, limitorque report B0027 "Superheat Temperature Test" demonstrates by test and analysis that the heat sink properties of the actuator materials prevent internal temperatures from rising above 315*F (the 600456 test peak temperature) for the case of a superheated steam environment of 492*F for up to 17 minutes. Therefore, the small, short duration MSLB, peak temperature spike above 315'F is adequately enveloped by the B0027 test results. (6) NUREG-0588 Item 2.2(2) states that testing should demonstrate that equipmen* can perform its function for all service conditions with margin. The plant specific chemical spray consists of (worst case) a pH from 10.0 - 10.7 for 47 minutes followed by a srop in pH to 8 7 for the next 32 hours. The test chemical spray was applied per IEEE-382-72, Part III Table 1: pH of 10 5 to 11.1 (by sample) for a duration of 24 hours. Although the test spray duration did not match or exceed worst case plant spray duration the high caustic concentration was applied during the entire test spray period. In addition, the test spray was applied at much higher ambient pressures (70 psig) than the highest plant specific post-accident containment pressure (47 1 psig). Based on this (l) discussion the discrepancy between actual plant spray conditions and test conditions is not considered to constitute a significant qualification concern. (7) NUREG-0588, Item 2.1(3)(c) states that the bases should be provided for concluding that the failure of equipment is not deemed detrimental to plant safety. The SI accumulator isolation valves are located in the RB and may be subjected to harsh environmental conditions resulting from postulated pipe breaks in the RB. However, during normal plant operations, these valves are open, with power locked-out to the operators, and are not required to function to mitigate postulated pipe breaks in the RB. Because these motor operators fail as is and power is normally removed, the only failure mode of the valves is in the open position required for performance of their safety function. Therefore, the accumulator isolation valve motor operators are exempt from qualification for pipe breaks in the RB. However, the available qualification data indicates that these operators are qualified to function during and after postulated pipe breaks in the RB thereby providing additional plant safety margin. W-26 Revision 3
- h. DR-6W RHR and Charging Pump Motors (1 ) NUREG-0588, Item 2 3(a) states that equipment that must function in order to mitigate any accident should be qualified by_ test to demonstrate its operability for the time required in the environmental conditions resulting from the accident.
Westinghouse did not perforn steam or chemical spray tests on these motors because'they are located outside containment. However, the plant HELB analysis shows that service conditions of 118'F, 0.1 psig, 100% relative humidity can occur post-SLB; and also high radiation levels can exist during containment sump recirculation. The radiation levels w during testing, and the test levels (2 x 10greRAD) considered exceed calculated levels at the motors. The HELB pressure and humidity conditions are adequately covered by the testin reported in WCAP 7829 and by immersion tests conducted (gin fresh and salt water). The HELL temperature condition of 118*F (peak) exceeds the normal temperature in the rooms where the punpa are located which is 65*-104*F for a period not greater than 30 minutes (FSAR Table 3.11-3) during the event. Assuming that the ambient temperature remaining at 104*F (40*C), the motors are qualified for forty (40) years at continuous operation (WCAP 9745). This situation would not ("') adequately accommodate a DBE in the final years of qualified life. However, the pumps are standby equipment; and are not in continuous use.during normal plant operation. Even though the CCP's will be used routinely for charging, the expected operating time at the end of forty years would be-less than twenty years for each of the three motors. (The two RER motors would be operated very much loss than this.) Based on expected use of the motors, even assuming the worst case ambient temperature prevails continuously, sufficient insulation life exists, at the expected duty cycle of the motors, to support a forty year qualified life followed by a SLB event which raises local temperatures to 118*F for thirty minutes with margin. See analysis below: ANALYSIS l Given: 1. The insulation thermal aging characteristics provided in WCAP - 875459 follow the 10*C
" rule". -
- 2. Motor operates 150% of the design life of forty years.
(~S W-27 k/ Revision 3
DR-6W ggg Given that qualified life is forty years at 105'C total temperature (40*C ambient + 65*C rise), what is the qualified life at 50*C total temperature (10*C added for motor space heaters)? (T3 - Tp) T2=T2 to T 1 =350,400 hr (40 yrs.) Tj = 105'C T2 = 50*C T2 =350,400 x 2(5 5)=15 8 x 106 hr.=1810 yr assuming the motor is not operated at all, at 50*C total temperature qualified life is approximately 1800 years. Using the 10*C relation and the items given above, the following projected qualification life of the motor is developed:
+4 A 113*C for 30 105'C ,, min.
ss 50*C (Motor run 50% DBE Total of time) Temp. (Motor idle 50% of time) Time 0 yr. 20 yr. 40 yr[ 41 yr. gg) Remaining M y / \
- Qualified 1800 yr 1780 yrs at 50*C 19 3 yrs at 105*C 19 3 yrs Life at 50"C or 39 3 yrs at 105 c or 11.1 yrs at 113 c at 105 *C
*113*C for 30 min. has a negligible effect on life
(<1hr) r In consideration of motor operating voltage extremes, the nameplate data on the motors indicates that, at a 1.15 service factor, the rise temperature is 90*C. Assuming that this condition (90*C rise) prevails .throughout the entire post-DBE period starting at year 40, the projected SLB + 90* rise q)ualified life at a total is approximately temperature two years of 138'C (48' which provides approximately one year of margin on post-DBE operating time. _ W-27 Revision 3
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~l DR-6W (2) NUREG-0588,. Item 4 (1) states that qualification programs committed to IEEE-334-1971 for motors should consider the effects of aging. The test program, described in the reports, subjects the materials in the insulation. system to several aging mechanisms including combined thermal and radiation aging. The testing aad thermal aging analysis demonstrate adequately.that the insulation materiale can perform their safety function during the installation life of the motors.
Synergistic effects of the environmental conditions of humidity and radiation need not be considered because the effects of HELB's outside containment are not associated with the high radiation levels which result from DBE's inside containment. (3) .NUREG-0588, Item 2.2(1 ) . requires failure criteria to be established prior to testing. For the RHR and charging pump motors, failure criteria, per se, were not defined prior to testing; however, all testing was directed towards the electrical insulation performance, and it was understood that the failure mode was loss of dielectric strength of the insulation. (4) NUREG-0588, Item 3. (1) states that quantified margins should
,, be applied to design parameters during testing.
(' ') Margins demonstrated during testing were: Temperature: >100% (WCAP 7829 57) Pressure: >100% (WCAP 7829 5 7) Radiation: >100% (WCAP 8754 57) Voltage: None Frequency: None Time: Margin exists (see Item (1) above) Vibration: Standard IEEE - 275 vibration procedure Humidity: None (100% R.H. ) s- W-27 (~) Revision 3
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T Barton-Transmitters Model (752) DR-7W
-(1) NUREG-0588, . Item 2.1(3)(c) states that equipment that need not function in order to mitigate any accident and whose failure
-in any mode in -any accident environment is not detrimental to plant safety-need only be qualified-for its non-accident service environment.: Where Westinghouse supplies an item of safety-related equipment that is located in an area where it can-experience the environment resulting from a high energy
-line break, but is not required to perform any safety-function, Westinghouse has verified that any consequential failure of such equipment, due to the adverse environment, does not prejudice the safety related functions of other equipment claimed in the accident analys{s.
Transmitters in this. category are further discussed below: ( a) Reactor Coolant System Flow Transmitter
- Transmitters are subject to MSLB and LOCA ea>ironments in
-the RB. However, they are not required to #anction to mitigate these events; and after these accidents, they may fail in-any mode with no adverse effects on safe shutdown or accident mitigation. The safety function of the transmibters is to initate a reactor trip on low RCS N
flow to prevent loss of adequate core temperature
-(~} margins. The qualified life of the transmitters under normal environmental conditions will be determined under the plant aging program.
(b). Narrow Range RB Pressure Transmitters The four transmitters are-located outside containment. Two are in the Fuel Building where they will experience no harsh environmental conditions. Two are in separate containment penetration rooms where the effects of MSLB's and other-HELB's may be experienced. However, the transmitters are designed to sense and mitigate HELB's in the containment and are not needed to mitigate HELB's outside containment. Also, the safety related display instrumentation function performed by the narrow range transmitters will still be unaffected by pipe break conditions outside the RB because 1) a postulated pipe break could affect only one of the four transmitters and
- 2) backup _ display information is provided by the wide ,
range Reactor Building pressure transmittero. The - l qualified life of the transmitters under normal ; penetration room and Fuel Building environments will be l determined under the plant aging program.
~I-jo)
A_ W-28 Revision 3
(c) ist Stage Turbine Pressure Transmitter The two 1st stage pressure transmitters are located in the Turbine Building where they can experience the effects of several main steam and other high energy line breaks. However, the safety function of the transmitters, which is to provide input to reactor trip blocking circuits at low plant power, does not involve any function associated with HELB mitigation or safe shutdown of the plant following HELB's in the Turbine Building. The qualified life of the transmitters under normal Turbine Building environmental conditions will be determined in the plant aging program. . (d) Feedwater Flow Transmitters The six feed flow trancmitters provide input into the reactor trip system te shutdown the reactor on low feed flow in anticipation of loss of the reactor coolant system heat sink. The transmitters are in the penetration rooms and Intermediate Building where harsh environments can develop following certain pipe breaks. However, the transmitters are not required to function to mitigate pipe breaks or*to conduct a safe plant shutdown. The qualified life of the transmitters under normal environmental conditions will be determined under the plant aging program. (l) W-28 Revision 3 ggg
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~' . Hydrogen Recombiner Control Panel / Power Supply DR-8W (1) NUREG-0588, Item 2.1(3)(c) states that equipment that need not'
-func' tion in order to' mitigate any accident and whose failure in any ~ mode in any accident environment is not detrimental to plant safety need only be qualified for its non-accident service environment. The hydrogen recombiner control panel and power supply are located in the Auxiliary Building where they could-be subjected to the environmental conditions resulting from'a postulated CVCS letdown line pipe break.
However, .this equipment is not required to function to mitigate pipe breaks outside containment and.is, therefore, exempt from qualification to harsh environmental conditions. The qualified life of the equipment under normal conditions - will be addressed in the plant aging program.
/^i V
I~ l p) s_ W-29 Revision 3
[' - t DR-9W-Limitorque Valve Operators Outside RB (NSSS Supply) (1 ) NUREG_0588 paragraph 2.2 (3), Category II,' specifies that the test-procedure should conform to the guidelines in Section 5 2 cf IEEE Std. 323-1971. Paragraph 5 2 requires that the test-data accuracy must be specified. The Limitorque qualification report B0003 does not specify the accuracy for the test data, but it does specify that the test equipment has been calibrated by standards which require periodical calibration. Therefore, since adequate conservatism (margin) does exist in the test results, the omission of the test data accuracies is acceptable. Also IEEE-323-74, 6 3 2(5) requires equipment to be subjected to in-service mechanical vibration as part of the test sequence. Limitorque operators have been tested for seismic events per IEEE-344-75 Non-seismic vibration is not addressed in the test reports because of Limitorque experience that in-service vibration is not a qualification concern. (2) NUREG 0588 paragraph 2.2 (10), Category II, identifies that the expected extremes in voltage and frequency should be applied during testing. Limitorque tested the valve operators to a voltage extreme only. Since this equipment is not - expected to see significant frequency changes in its installed service, testing to a fixed frequency is acceptable. ( ) (3) NUREG 0588 Section 4, Category I applies to this equipment. Aging performed on Class B insulated motors and actuators is described in B0058, Section 3 0. Of the aging condition described, synergistic effects of service conditions were not considered. However, aging of the actuator was performed by simultaneous application of elevated temperature, 100% relative humidity, and mechanical aging for 200 hours. The simultaneous application of these conditions had no detrimental effect on the aging procedure or the following test sequence. In addition, for radiation aging, the report states (in Section 2.2 4) that experience shows that, for Limitorque actuators, there is no difference on the equipment as a result of where irradiation occurs in the aging sequence. (4) Identified margins available above specific plant conditions are: Temperature > 30*F Mechanical cycles >100% (above 382-72) Pressure > 20 psig Two HELB transients W-30 I (,,) Revision 3 ) DR-9W (g) (5) The listed valve actuators are Category "C" equipment (definition in NUREG-0588, App. E, Section 2) for the high temperat'ure, pressure, and humidity environments resulting from high energy line breaks in their vicinity. Although they might be subjected to these conditions, they need not function to mitigate them. However, the actuators are Category "a" with respect to the high radiation conditions durin6 Jost-LOCA containmeat sump recirculation. (6) NUREG-0588, Item 2.2(2) requires that test results should demonstrate that equipment can perform its required function for all postulated service conditions. The phenolic limit - switch materials used in the valve actuators for out-of-containment use has not been demonstrated to be capable of accommodating the increased radiation levels that may result during post-LOCA recirculation. The actuators have been tested to 2 x 107 RAD, but radiation levels during recirculation can reach 4 x 107 RAD in plant areas where some of the actuators are located. This is an open qualification concern. O W-30 m Revision 3 W
hi l
.1 DR-10W l i )
N' Equipment Sublected to the Radiation Environment Following a Fuel Handling Accid.ent l lNUREG-0588, Item 2.1(3)(c)' states that the bases should be provided
'for concluding -that the failure of equipment in any mode is not deemed detrimental to plant' safety. .The Class 1E equipment under-
-Westinghouse scope of supply, listed below is' located in the Fuel Handling Building-(FB) and may be subjected to.the radiation conditions resulting from a postulated fuel handling accident-in the FB.
XVG-8801A,B-SI BIT Outlet Valve Operator
- XVG-8803A,B-SI BIT Inlet Valve Operator
-XVD-8033-RC PRT Vent RB Isolation Valve Solenoid and Limit Switch
~XVD-80e8-RC PRT Spray RB Isolation Valve Solenoid and Limit Switch z XVT-8945A,B-SI, BIT Recirculation Isolation XVT-8942-SI Valve Solenoid and Limit Switch q'- XYD-7136-WL RCDT Liquid RB Isolation
. Valve Solenoid and Limit Switch XVD-7150-WL' RCDT Gas RB Isolation Valve Solenoid and Limit Switch IPT-951, 952-HR Narrow Range RB Pressure Transmitter However, none of this equipment provides a mitigating function for a postulated fuel handling. accident, nor is it required to function to conduct a safe plant shutdown should a shutdown be conducted following the accident. In addition, failure of the equipment in the postulated radiation environment will not degrade plant safety nor mislead an operator. Therefore, the equipment is exempt from qualification for~ postulated fuel handling accidents in the FB.
/~N W-31 A) s Revision 3
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y - I' O 4
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Balance of Plant !~ Safety Related Electrical Equipment ! O-1 i i i Legend: TID values expressed in exponential equivalents, 4
- e. g. 1 + 4 = 1 x 104 3.47 + 5 = 3.47 x 105
- Detailed Report (DR-xx), shown ander column heading Qualification Report and Method, contains additional information for the type of equipment addressed.
(k - B-0 Revision 3 l h
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rs NOTES TO TABLES ON PAGES B- l THROUGH B-54 Li
- 1. Deleted.
- 2. Equipment is not required to enerate during abnormal temperature or oressure conditions and failure in any mode during these conditions is not detrimental to plant safety or accident mitigation. However, equipment may be required to operate during radiation conditions caused by a LOCA or accident located elsewhere in the plant. The Radiation exposure (TID) data represents a conservative total of the integrated doses received under LOCA and 40-year normal operating conditions.
- 3. Deleted.
- 4. Deleted.
- 5. Deleted.
(t 6. Qualified life not determined by equipment vendor. This item will be addressed in the plant aging program.
- 7. Deleted.
- 8. Deleted.
- 9. Deleted.
- 10. Deleted.
- 11. Deleted.
l
- 12. Operating time is insignificant compared to total response time of the system.
! 13. Deleted. (') B-55 Revision 3.
- 14. Deleted. *jlh
- 15. Cable tray, tray supports, and conduit supports are Seismic Category I and have been structurally qualified as described in FSAR Paragraph 3.10.2.1.1. However, they are not Class lE, and therefore no specific environmental qualificacion has been performed.
- 16. Deleted.
- 17. Deleted.
- 18. Deleted.
- 19. Equipment not required for design basis line breaks accidents but qualified for environmental conditions of fuel cask drop accidents.
- 20. Deleted.
- 21. Deleted.
- 22. Deleted.
- 23. Deleted.
- 24. Deleted.
- 25. Deleted.
- 26. Deleted.
- 27. Deleted.
- 28. Deleted.
l l ! 29. Deleted.
~
- 30. Deleted.
B-56 Revision 3.
,- 31. Deleted.
~ 'q) ,g ;
32.- Deleted..
- 33. Deleted.
- 34. Deleted.
- 35. Deleted.
- 36. -Deleted.
- 37. Deleted. -
- 38. Deleted.
- 39. Deleted.
() 40. Deleted. .l
- 41. Deleted.
~
- 42. Some of this cable is located below the 418'-6" level of the reactor building where there is potential flooding. The circuits required j post LOCA have been determined, and these cables have been relocated to above flood level, i
4
- 43. The space inside each valve container guard pipe enclosure is sealed ;
from the containment atmosphere by a welded cover plate between the process pipe and the guard pipe. Therefore, valves 8811 A and B and 3004 A and B will not be submerged following an accident inside containment, and these valves are not required to be qualified for submergence conditions.
- 44. Deleted. !
B-57 Revision 3. 1
i l 1 l 1
- 45. Conduits for triaxial cable embedded in floor slabs are subject to llh standing war.er.
- 46. Maximum temperature occurs on loss of non-Class lE HVAC system; other conditions listed are for normal design conditions.
- 47. Deleted.
- 48. The sump level transmitters were qualified by a combination of analysis and test. The analysis performed demonstrates that the Rosemount model
#1153-002-0001 is similar to the previously qualified Rosemount model
#1153DA4. A prototype 1153-0022-0001 transmitter was tested for leak tightness and function during a seven-day simulated submergency test.
At the end of the seven days, no leakage was detected, and the transmitter remained functional.
- 49. Deleted.
- 50. Qualified life is based on periodic replacement of equipment components.
- 51. Qualified life is based on material and component life test data.
- 52. The radiation exposure (TID) data represents a conservative total of the integrated doses recaived under LOCA and 40-year normal operating conditions.
- 53. Deleted.
- 54. Deleted.
- 55. Deleted.
- 56. Deleted.
. 57. Deleted. O
- 58. Deleted.
B-58 Revision 3.
- .-. . . . . . - . . - - . . - . . . . - . . - . . . . . . . ~ . . -
i e 3 - -
'59. Deleted.. ,
t
- 60. Deleted.
I ! 4
- 61. Deleted.
! 62. Deleted. J l
- 63. Deleted.
l
- 64. Currently on open item list, Table 1.6-2 of this report. ,
i 1'
- 65. Deleted.
- 66. Deleted.
- 67. Deleted.
!O < 68. Deleted. , ? 6 1 l
- 69. Deleced.
I 4 Deleted. j i 70. ' i i 4 i i i-i i, B-59 j Revision 3. I 1
- l
. l t-i. 4 I 4 ,
. _ - _ . . . . . . . . - . _ . _ - _ _ . - - , - . . . . . . . . _ - , . _ . . . _ . . ~ . . , . _ _ _ _ _ _ , . . - , . , . , _ _ , _ . . - . . _ . , _ . _ _ . - . - _ - , . . . . ,
._ _., .-a .._ . ., .- .
~ - .._.-.. - .--.-. - . . . . . . . . . .- . . - . . . - . - - ..
y-r l i, ,3
- r. t l
1 t l i -
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l i I e f i 4 l-i 2 ; I i DETAILED REPORTS (DR-xx) 4 5 1 i )
! l
$ I e, i 1 . t 4 i I
; i 1
7
- i -
i , 1 e I .. i k NOTE: Reference to DR's may be found on the Balance of Plant table,
~
i , , .. Qualification Report and Method column. l L@
- - i -
!: B-75 Revision 3 :
- j. !
l ., l f I f.
DETAILED REPORT (DR) INDEX DR No. Title Page No. 01 Pyco RTD's - Outside Containment B-77 02 Rockbestos Switchboard Wire B-79 03 Raychem WCSF and Breakouts B-82 04 Deleted 05 Okonite Tapes B-88 06 Raychem Switchboard Wire B-90 07 Samuel Moore Instrument Cable B-93 08 Valcor Solenoid Valves B-96 09 Valcor Solenoid Valves B-98 10 Deleted 11 Reliance Motor - RB Cooling Unit B-101 12 Deleted 13 Reliance Fan Motors B-103 14 Deleted gg 15 Deleted 16 Limitorque Valve Operator - In Containment B-107 17 Field Fabricated Panels B-108 18 7200 Volt Speed and Transfer Switches B-109 19 Iso Fuses for Heat Trace B-110 20 Deleted 21 Deleted 22 Raychem IIVT-CBN B-114 23 Deleted 24 Kerite 600 V Control Cable / Splicing Tapes and Cement B-120 25 Deleted 26 Deleted 27 Deleted 28 Deleted 29 Deleted 30 D. G. O'Brien B-133 O B-76 Revision 3 .
i ( ,) DETAILED REPORT (DR) INDEX (Cont'd) DR No. Title Page No. 31 Rockbestos Twinax Cable B-135 f;2 8 kV Power Cable B-136 33 Triax Cable B-138 34 MCC's' B-140 35 Deleted 36 Deleted 37 Deleted 38 Deleted 39 Service Water Booster Pump Motors B-158 40 Emergency Feedwater Pump Motor B-160 41 Reactor Building Spray Pump Motors B-162 42 Deleted 43 600 Volt Po<ier Cable B-167 44 Component Cooling Pump Motor B-171 45 Low Voltage Tapes B-173 46 Pyco RTD's - Inside Containment B-174 47 Rosemount - CC Flow to RCP's B-177 48 Reactor Builidag Sump Level Transmitters B-179 49 Rosemount B-183 50 Reliance Fan Motor, Auxiliary Building B-185 51 Deleted 52 Deleted 33 Deleted 54 Deleted 55 Limitorque Valve Operators - Outside Containment B-192 56 Deleted 57 Rosemount B-195 58 Rosemount B-197 59 NAMCO Limit Switches B-199 60 ASCO Solenoid Valves B-201 B-76a Revision 3 i
DETAILED REPORT (DR) INDEX (Cont'd) DR No. Title Page No. 61 Limitorque Valve Operators - Outside Containment, B-203 Category C 62 Deleted 63 Deleted 64 ASCO Solenoid Valves for FH Building B-208 Exhaust Fan Inlet Isolation Dampers 65 Deleted 66 Deleted 67 Deleted 68 Atwood-Morrill 32" Air Operated Solenoid Valve B-216 69 Hydrogen Analyzer and Remote Control Panel B-217 70 Containment High Range Radiation Monitor B-218 O O B-76b Revision 3 .
DR-01 y Pyco RTD's - Outside Containment (1) NUREG 0588, para 2raph 2.2 (3), Category I, specifies that the guidelines of paragraph 6.3 of IEEE Standard 323-1974 should be followed. Paragraph 6.3.1.1 (7) requires that test equipment requirements, including accuracies,. be included in the qualification test plan. The Pyco test plan does not identify test equipment accuracies. This omission is considered acceptable , since the qualification report (Appendix 5) identifies the test equipment used by'Isomedix Inc., during the testing program. The equipment list identifies span, calibration frequency, manufacturer, and Isomedix 4 identification number. The identification number can be traced to the
, ' manufacturer's data. -
(2) NUREG 0588, paragraph 2.2 (3), Category I, specifies that the requirements ; of paragraph 6.3 of IEEE Standard 323-1974, should be followed. Paragraph 6.3.2 (1) identifies that inspection may be performed to assure thac a test unit has not been damaged due to handling. The Pyco report does not identify that this inspection was performed. This omission is acceptable l since pretest data taken before the thermal aging of the equipment demonstrated that the equipment functioned properly. (3) NUREG 0588, paragraph 2.2 (3), Category I, speciff a that the requirements of paragraph 6.3 of IEEE Standard 323-1974, should be used as a guide. Paragraph 6.3.7 requires that upon completion of type testing, the equ: pment shall be dismantled and the condition of components recorded. The Pyco report does not identify that dismantling was performed and conditions
/"'N recorded. This omission is acceptable since post-test data demonstrates V. that the equipment functioned as designed after completion of the accident test.
4 (4) NUREG 0588, paragraph 2.2 (6), Category I, specifies that when the equipment is exposed to the simulated accident environment,'the temperature should be defined by thermocouple readings on or as close as practical to the surface of component being' qualified. The location of the thermocouple u.-d during the test was not identified in the report. Due te the long periods of time I which were used to holding times, temperatures withia the test chamber would have reached steady-state conditions prior to each step drop in temperature. Since the critical function is that the equipment be qualified to a temperature which exceeds the expected accident temperature (which has been demonstrated) and since the temperature reached a steady-state condition, the omission of the thermoccuple locaticn is acceptable. l (5) NUREG 0538, paragraph 2.2 (10), Category I, specifies th:L the expected extremes of voltage and frequency in power supply should be applied during testing. The characteristics of an RTD are not dependent on voltage or frequency. Therefore, testing to voltage and frequency extiemes is not applicable. Electrical characteristic tests which included element l resistance and insulation resistance at 500 volts were conducted during the qualification test. (6) NUREG 0588, paragraph 4 (4), Category I, specifies accelerated aging methods other than the Arrhenius methodology may be acceptable if it can ae supported by type tests. B-77 Revision 3 .
l l DR-01 The degree of aging chosen was based on what is considered adequate for < cable (IEE 383-1974). It is to be realized the materials used in the equipment are completely inorganic with the exception of the silicor.a pot seal and short lengths of insulating sleeving which are provided primarily to improve handling characteristics of the assemblies. The parameters for sging were selected on the basis of consistancy with the qualification of electric cable (reference: IEEE 383-1974) as a means of comparison between element components and not as a means of simulating an extended period of time by accelerated aging techniques. The justification for this approach is contained in the position statement to IEEE 323A-1974 as well as the philosophy and intent of IEEE 381-1977 in that aging was conridered as an operational parameter and its effect on performance was determined not to result in age-related failure mechanisms unlike vibratory motion which could degrade the safety function performance of the assemblies. It is further to be understood that routine in-service testing of elements may readily be performed to detect performance outside the design range specification which would allow replacement of degraded elements and thereby extend the qualified life of the assemblies. Application. of the "10*C" rule for accelerated aginE to the Thermal Aging conditions performed during the qualification test, namely 7 days at 121*C based on an ambient temperature envircnment of 50*C, results in an estimation of installed life as being 2 1/2 years. A replacement period greater than the vendor stated 2 1/2 years is desired. This issue will be addressed in the p19nt aging program. (7) The RTDs successfully perforuled their intended function throaghout the various phases of the test program, ex,.ept as follows:
- a. Short circuiting of element number 1B following the LOCA simulation and intermittent shorting of element SB also after the LOCA simuletion.
The cause for this is chought to be a result of moisture, either condensate or spray solution, entering the unit head.
- b. Evilence of performance of Units 1 and 5 outside the acceptable limits of operation was recorued during the LOCA simulation prior to the post-12CA calibration.
- c. Test Unit 3 was determined to have ceased operation during the IUA simulation end the subsequent calibration verified this observation.
The vendor recommendation to preclude the observed shorting is to seal the th:eaded connections to prevent the ingress of condensate or spray solutions. O B-78 Revision 3 .
DR-02 Rockbestos Switchboard Wire (1) NUREG 0588, Section 2.2, paragraph (1), Category I, as well as IEEE 323-1974,' Section 6.3.1.1, ites (9), states that performance limits or fail-re criteria should be established prior to testing. The Rockbestos Company did not specifically establish failure criteria before performing 1 the loss of coolant accident (LOCA) simulation and the post LOCA simulation tests. The results of these tests, however, indicate that the cable j insulation had maintained its functional integrity and that conductors i l~ _ maintained their ability to carry rated load currents throughout the 30-day ; duration of the LOCA test. (2) NUREG 0588, Section 2.2, paragraph (3), Category I, states that
.IEEE 323-1974, Section 6.3, is an acceptable guideline for establishing test procedures; IEEE 323-1974, Section 6.3.1.1, states that a test plan which i provides an auditable link between the specifications and the test results ,
should be included in the qualification report. Although a test plan is not
.!ncorporated into the report, most of the information required by Section 6.3.1.1, items (1) through (12), is given in the body of the report.
Since the cable was qualified in accordance with IEEE 383-1974, " Standard for Type Test of Class IE Electric Cables, Field Splices, and Connections
- for Nuclear Power Generating Stations," the procedure followed was the most appropriate. Therefore, the intent of Section 6.3.1.1 has been satisfied.
i' (3) NUREG 0588, Section 2.2, paragraph 3, Category I, states that IEEE 323-1974, Section 6.3, is an acceptable guideline for establishing test procedures; O 'riz 323-1974. secti 6 3 2 2. it - (3). a t= ta t th t t 91 - include mounting and connection requirements. Similarly, Section 6.3.1.2 2 states that the equipment should be mounted in a manner and position that simulates its expected installation. There is no data in the report that explicitly gives the details of the mounting and connection of the cable. Howew r, it can be implicitly detere'ned from the report that the cablen 4 were wrapped on a mandrel, installed in a pressure vessel, brought out a throush pressure-:ealing glands and electrically loaded during the LOCA 4 simulation. Since this is tie method required by IEEE 383-1974, the
, mounting requirements have been fulfilled.
(4) NUREG 0588, Section 2.2, paragraph 3, Categorv !, states that IEEE 323-1974; Section 6.3, is a. acceptable guideline for establishing test procedures; IEEE 323-1974, Section 6.3.1.1, item (6), states thst the performance and environmental variables to be measured should be listed in a test plan. A list of variables ti. be measured is not included in the report. The l variables that were mi saured were those usually measured during the type
- testing of cable; that is, temperature, pressure, current, voltage, and radiation level, Therefore, the failure of the report to address in a test plan performacce and environmental variables to be measured is acceptable.
(5) NUREG 0588, Section 2.2, paragraph (3), Category I, states that IEEE 323-1974, Section 6.3, is an acceptable guideline for establishing test procedures; IEEE 323-1974, Section 6.3.1.1, item (7), states that the test , equipment requirements, including accuracies, should be included in a test plan. Similacly, Section 6.3.1.4, states that environmental and electrical variables should be monitored using test equipment whose calibration can be B-79 c Revision 3 L .- ,, -
DR-02 traced to auditable calibration standards. In addition, NUREG 0588, Section 5, item (2), Category I, states that the guidelin o for docunmntation in IEEE 323-1974 (which is Section 8) are acceptable when fully implemented; IEEE 323-1974, Section 8.3, item (4)(c), states that a description of the test facility and instrumentation used, including calibration records of reference, should be documented in the report. The report does not include information on test equipment, accuracies, or calibratton; however, Rockbestos should maintain this information in their quality assurance records. The omission of this data does not invalidate the qualification, and therefore the report is acceptable. (6, NUREG 0588, Sectf on 2.2, paragraph (10), Category I, as well as IEEE 323-1974, Section 6.3.1.5, item (5), states that equipment should be subjected to variations in the nominal frequency during testing. The range of frequency this cable is expected to experience is not more than tS% of 60 Hz. Since variations of this insignificant degree have no effect on cable, testing at the nominal frequency of 60 Hz is adequate. (7) NUREG 0588, Section 2.2, paragraph (3), Category I, states that IEEE 323-1974, Section 6.3, is an acceptable guideline for establishing test procedures; IEEE 323-1974, Section 6.3.2, states that the test sequence used should be justified as the most severe for the item being tested. No justification, ar such, exists in the qualification report; however, the cable was qualified in accordance with IEEE 383-1974. The test sequence given thereia was taken as the most appropriate and severe for cable. (8) NUREG 0588, Section 2.2, item (6), Category I, states that the LOCA test temperature should be defined by thermocouple readings on or as close as practical to the surface of the equipment being qualified. The report does not describe the method or location of temperature measurement. However, there is sufficient margin be ween the test temperature and the required temperature, so that the omission of this data from the report does not detract from the acceptability of the qualification. (9) NUREG 0588, Section 2.2, item (7), Category I, states that performance characteristics should be monitored before, during and after testing. Specific performance characteristics were not monitored throughout the test program; however, the report states that the cables were energized throughout the LOCA test and that they passed a post LOCA mandrel bend test and a water immersion / voltage withstand test. (10) NUREG 0588, Section 2.2, paragraph (9), Category I, states that the l operability status of the equipment should be monitored during testing. Although the qualification report maires no reference to monitoring the operability of the equipment, the report does state that the cable was energized with rated voltage and current throughout the test. It can therefore be inferred that the conductors maintained their continuity and that the insulation maintained its dielectric properties throughout the test. (11) NUREG 0588, Section 4, paragraph (5), Catego y I, states that known material phase changes and reactions should be defined for the accelerated aging g program to ensure that no known changes occur within the extrapolat. ion W B-80 Revision 3
DR-02 (_) limits. The Rockbestos Company knew of no phase changes or reactions associated with the Firewall III switchboard wire when they performed the accelerated aging tests and constructed the Arrtenius plots. Therefore, phase changes and reactions have not been sddressed by the qualification report. (12) NUREG 0588, Section 5, paragraph (2), Category I, states that the guidelines for documentation in IEEE 323-1974 (which is Section 8) are acceptable when fully implemented; IEEE 323-1974, Section 8.3, item (2), states that the specific features to be demonstrated by the test should be identified. No identification of such features appears in the report. The requirements of any cable, however, are to maintain continuity of the conductors atJ insulation resistance of the insulacion. Since these requirements are universal to cabl , it was unnecessary to document them; therefore, the report's failure to mention these in acceptable. (13) NUREG 0588, Section 2.2, paragraph (4), Category I, states that the profile should envelope conditions produced by both a main steam line break (MSB) and a LOCA. NUREG 0588, Section 3, paragraph (1) states that quantified margins should be applied to test deaign parameters and paragraph (4) states that the margin should be the 10 per cent margin identified in Section 6.3.1.5 of IEEE 323-1974. The LOCA profile (page 8 of the qualification report) envelopes all necessary parameters with sufficient margins for both a LOCA and a MSB, except for length of exposure to pressures of between 0 and 5 psig. The LOCA test maintained pressure on the g_s cable for 4 days ranging between 28 psig and 113 psig. After the fourth day q,) pressure was reduced to O psig. After 4 days the expected pressure in the reactor building due to a LOCA is less than 5 psig. This low pressure is not expected to have any effect on the cable because of its ability to withstand much greater pressures. Therefore, the margin requirements of NUREG 0588 and IEEE 323-1974 are satisfied. A V B-81 Revision 3
l DR-03 Raychem WCSF and Breakouts (1) NUREG 0588, Section 2.2, paragraph (1), Category I, as well as IEEE 323-1974, Secticn 6.3.1.1, item (9), states that performance limits or failure criteria should be established prior to testing. Failure criteria were not established before performing the insulation resistance measurements, the electrical loading tests, or the mandrel wrap and high-potential withstand tests. The results of these tests, however, indicate that the splicing sleeves and breakouts maintained their functional integrity without apparent damage throughout the 30-day duration of the LOCA test. Therefore, the omission of establishing failure criteria prior to testing is acceptable. (2) NUREG 0588, Section 2.2, paragraph (3), Category I, states that IEEE 323-1974, Section 6.3, is an acceptable guideline for establishing test procedures; IEEE 323-1974, Section 6.3.1.1, states that a test plan should be included in the qualification program. The report does net include a test plan as described by Section 6.3.1.1. Since the splicing sleeves and breakouts were qualified to applicable portions of IEEE 383-1974, the test procedurs given therein was followed. Therefore, the formulation of a separate sest plan was considered unnecessary. In addition, most of the information required by Section 6.3.1.1 of IEEE 323-1974 is given in the body of the report. (3) NUREG 0588, Section 2.2, paragraph (3), Category I, states that IEEE 323-1974, Section 6.3, is an acceptable guideline for establishing test procedures; IEEE 323-1974, Section 6.3.1.1, item (7), states that test equipment requir9ments, including accuracies, should be included in a test h plan. The report does not address test equipment requirements and accuracies. However, the report does include a list of data acquisition instruments which gives the range and features of the equipment. From a review of the list, it is evident that the test instruments used were appropriate for the testing that was done. (4) NUREG 0588, Section 2.2, paragraph (3), Category I, states that IEEE 323-1974, Section 6.3, is an acceptable guideline for establishing test procedures; Section 6.3.1.4, of IEEE 323-1974 states that the test equipment shall be calibrated against auditable calibration standards and shall have documentation to support such calibration. In addition, NUREG 0588, Sectiot 5, item (2), Category I, states that the guidelines for documentation in IEEE 323-1974 (which is Section 8) are acceptable d en fully implemented. Similarly, IEEE 323-1974, Section 8.3, item 4.e states that the qualification report should include test data and accuracy (results). Although the report includes test data, it does not include documentatica of calibration or accuracies. The list of data acquisition instruments gives the date the equipment was calibrated, and it is reasonable to assume that the instruments provided reasonable accuracy and that the calibration was done to an acceptable standard. O B-82 Revision 3 .
DR-03 p d (5) NUREG 0588, Section 2.2, paragraph (3), Category I, states that IEEE 323-1974, Section 6.3, is an acceptable guideline for establishing test procedures; IEEE 323-1974, Section 6.3.1.4.1, states that temperature, pressure, moisture content, gas composition, vibration, and time should be measured variables. These variables were measured except vibration and gas composition, which are not applicable to cable, and the moisture content of the environment in the vessel during the LOCA simulation. However, the test vessel included an open, heated reservoir of spray solution at the bottom to ensure a saturated condition during the test. Thus, measurement of moisture content was unnecessary as saturated ccnditions were maintained. (6) NUREG 0588, Section 2.2, paragraph (3), Category I, states that IEEE 323-1974, Section 6.3, is an acceptable guideline for establishing test procedures; item (7) of J'ection 6.3.1.5 of IEEE 323-1974, states that the initial environmental transient and dwell at peak temperature of the LOCA test should be applied at least twice. Duri; che LOCA test, only a single transient was applied. However, the splicing sleeves and breakouts were qualified in accordance with IEEE 383-1974 which statea that "the port LOCA simulation test demonstrated an adequate margin of safety by requiriag mechanical durability (mandrel bend) following the environmental simulation, and is more severe than exposure to two cy:les of the environment." The splicing sleeves and breakouts successt'ully completed the post LOCA 40x mandrel bend test. Therefore, an adequate margin of safety has been established. (7) NUREG 0588, Section 2.2, paragraph (3), Category I, states that IEEE 323-1974, Section 6.3, is an acceptable guideline for establishing test procedures; IEEE 323-1974, Section 6.3.2, states that the test sequence used should be justified as the most severe for the item being tested. No justification exists in the qualification report; however, tbs splicine sleeves and breakouts were qualified in accordance with IEEE 383-1974. The test scquence given therein was taken as the most appropriate and severe for splicing sleeves and breakouts. (3) NUREG 0588, Section 2.2, paragraph (10), Category 1, as well as IEEE 323-1974, Section 6.3.1.5, item (5), states that equipment should be subjected to variations in the nominal frequency during testing. The expected range frequency is not more than tS% of 60 Hz. These frequency variations have no effect on splicing sleeves or cable breakouts; testing at the nominal frequency of 60 Hz is adequate. (9) NUREG 0588, Section 4, paragraph (4), Category I, identifies that in lieu of the Arrhenius methodology, other methods, supported by type test, can be applied in addressing accelerated aging. For the subject cable splicing sleeves and breakouts, the type test program performed by Franklin Institute Researyh Laboratories included thermal and radiation aging at 150* C and 5 x 10 Rads for 168 hours followed by simalated LOCA conditions (simultaneous expos'are to steam, chemical spray and gamma radiation). Although no Arrhenius data was available to justify this aging program, 150' C for 168 hours was standard throughout industry at the time of the test and conforms to the IPCEA aging recommendations. Raychem is being p) contacted to determined if this information or other available information g V can be used to determine c qualified life for the components. This information ' will be implemented in the component replacement program. B-83 Revision 3 .
DR-03 (10) NUREG 0588, Section 4, paragraph (5), Category I, states that known material phase changes and reactions should be defined for the accelerated aging program to ensure that no known changes occur within the extrapolation limits. The Franklin Institute Research Laboratory knew of no phase changes or reactions associated with the sleeves and breakouts when they performed the qualification tests. Therefore, phase changes and reactions have not been addressed by the qualification report. (11) NUREG 0588, Section 4, paragraph (10), Category I, specifies that the qualified life of the equipment should be established- The type test performed by the Franklin Institute Research Laboratories for the subject cable splicing sleeves and breakouts does not explicitly address the qualified life of the equipment. However,thete:tinginclugeda temperature and radiation aging program at 150' C and 5 x 10 Rads TID for 168 hours, followed by a simulated LOCA condition (with the total radiation dose equal to 200 MRads). Thermal aging at 150' C for 168 hours is consistent with criteria of IPCEA standards for the commercial qualification of insulatica materials. Raychem is being contacted to determire if this aging data, or other available data, can be used to establish a qualified life for the splicing sleeves and breakouts. (12) NUREG 0588, Introduction, states that specific equipment such as cable are to conform to daughter standards such as IEEE 383. IEEE 383-1974, paragraph 1.3.5.2, states that type testing should be performed on both aged and nonaged samples. All samples in the Raychem qualification for splicing sleeves and breakouts were aged. However, the type of degradation caused by elevated temperatures and radiation during preaging fs equivalent to the degradation caused by the elevated temperatures and radiation during a LOCA. Thus, unaged samples would have performed as well as, or better than, the aged samples. Therefore, the lack of unaged samples from the qualification program is acceptable. O B-84 Revision 3
i, DR-04 O 1 i I I (DELETED) i i i l i 4 O l 1 1 e i i F i O j B-85-87 Revision 3 i
l DR-05 I Okonite Tapes O (1) NUREG 0588, Section 2.2, paragraph (1), Categcry I, as well as IEEE 323-1974, Section 6.3.1.1, item (9), states that performance limits or failure criteria should be established prior to testing. Okonite did not specifically establish failure crit.eria before subjecting the cable and splice to the LOCA simulation, or before performing the insulation resistance measurements or the high-potential withstand test. The results of these tests, however, indicate that the cable insulation and splicing materials maintained their functional integrity without damage. Therefore, the omission of establishing future criteria prior to testing is acceptable. (2) NUREG 0588, Section 2.2, paragraph (3), Category I, states that IEEE 323-1974, Section 6.3, is an acceptable guideline for establishing test procedures; IEEE 323-1974, Section 6.3.1.1, states that a test plan should be included in the qualification program. The report does not include a test plan as described by Section 6.3.1.1. As stated in Section 6.3.1.1 of IEEE 323-1974, the test plan should describe the required tests and provide proof that the test method used was adequate. The Test Program portion of the report adequately describes the tests that were done. From a review of the postulated accident environments the tape may experience, it was determinei that the tests adequately simulated the accident conditions with considerable margin. Therefore, the failure of the report to include a test plan is considered inconsequential. In addition, most of the specific i.iformatica required by Section 6.3.1.1 of IEEE 323-1974 is given in the body of the report. (3) NUREG 0588, Section 2.2, paragraph (3), Category I, states that IEEE 323-1974, Section 6.3, is an acceptable guideline for establishing test procedures; IEEE 323-1974, Section 6.3.1.1, item (7), states that the test equipment requirements, including accuracies, should be included in a test plan. Similarly, Section 6.3.1.4 states that environmental and electrical variables should be monitored using test equipment whose calibration can be traced to auditable calibration standards. In addition, NUREG 0588, Section 5, item (2), Category I, states that the guidelines for documentation in IEEE 323-1974 (which is Section 8) are acceptable when fully implemented; IEEE 323-1974, Section 8.3, item (4), (c), states that a description of the test facility and instrumentation used, including calibration records reference, should be documented in the report. The report does act include information on test equipment, accuracies, u calibration. However, Okonite has a quality assurance program meeting the requirements of 10 CFR 50, Appendix B, which requires that, " measures shall be established to assure that tools, gages, instruments, and other measurint, and testing devices used in activities affecting quality are properly controlled, calibrated and adjusted at specific periods to maintain accuracy within necessary limits." Thus, omission of this data does not invalidate ! the qualification. l (4) NUREG 0588, Section 2.2, paragraph (10), Cstegory I, as well as IEEE 323-1974, Section 6.3.1.5, item (5), sta'.es that the equipment should be subjected to variations in the nominal 'reqtency during testing. The range of frequency this terminal insulating material is expected to experience is O B-88 Revision 3
DR-05 q V not more than 15% of 60 Hz. Since variations of this insignificant degree have no effect on insulating tape or cement, testing at the nominal frequency of 60 Hz is adequate. (5) NUREG 0588, Section 4, paragraph (4), Category I, identifies that in lieu of the Arrhenius methodology, other methods, supported by type test, can be applied when addressing accelerated aging. Furthermore, NUREG 0588, Section 4, paragraph (6), Category I, states that the accelerated aging rate used during qualf fication testing should be justified. The terminal insulating material was subjected to an aging program consisting of air oven aging for 168 hours at 121* C followed by igradiation from a Cobalt-60 source to a total integrated dose of 2 x 10 Rads. Data is being requested from Okonite to better establish a qualified life on this item. (6) NUREG 0588, Section 4, paragraph (5), Category I, states that known material phase changes and reactions should be defined for the accelerated aging program, to ensure that no known changes occur within the extrapolation limits. Okonite knew of no phase changes or reactions associated with the terminal insulating materials when they performed the accelerated aging tests. Therefore, phase changes and reactions have not been addressed by the qualification report. (7) NUREG 0588, Section 5, item (2), Category I, states that the guidelines for documentation in IEEE 323-1974 (which is Section 8) are acceptable when fully implemented; IEEE 323-1974, Section 8.3, item (1), states that the qualification report should include the equipment performance specification O per Section 6.2 of IEEE 323-1974. There are no equipment performance specifications given in the report. However, the performance requirements of terminal insul: ting materials are essentially those of cable insulation which are to provide a nonconductive barrier between conductors and between conductor and ground. Therefore, the failure of the report to provide explicit performance specifications does not detract from the adequacy of the qualification and therefore is acceptable. 4
, B-89 Revision 3
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DR-06 O Raychem Switchboard Wire (1) NUREG 0588, Section 2.2, para. (1), Category I, as well as IEEE 323-1974, Section 6.3.1.1, item (?), states that performance limits or failure criteria should be established prior to testing. The Franklin Institute Research Laboratory (FIRL) did not specifically establish failure criteria before Performing the insulation resistance seasurements, the electrical loading tests, or the mandrel wrap add jugh-potential withstand tests. The results of these tests, however, indicate that the insulation had maintained its functional integrity without apparent damage, and that the conductors maintained their ability to carry load currents throughout the 30-day duration of the LOCA test. (2) NUREG 0588, Section 2.2, para. (10), Category I, as well as IEEE 323-1974, Section 6.3.1.5, item (5), states that equipment should be subjected to variations in the nominal frequency during testing. The range of fre-quency this cable is expected to experience is not more than + 5% of 60 liz. Since variations of this insignificant degree have no effect on cable, testing at the nominal frequency of 6011z is adequate. (3) NUREG 0588, Section 2.2, para. (3), Category I, states that IEEE 323-1974, Section 6.3, is an acceptable guideline for establishing test procedures; IEEE 323-1974, Section 6.3.1, states that a test plan should be included in the qualification program. The report does not include a test plan as described by Section 6.3.1.1. Since the cable was qualified in accord-evice with IEEE 383-1974, " Standard for Type Test of Class 1E Electric Cablea, Field Splices, and Connections for Nuclear Prver Generating Stations," the test prodedure given therein was followed. Therefore, the formulation of a separate test plan was considered unnecessary. In addition, most of the information required by Section 6.3.1.1 of IEEE 323-1974 is given in the bcdy of the report. (4) NUREG 0588 Section 2.2, para. (3), Category I, states that IEEE 323-1974, Section 6.3, is an acceptable guideline for establishing test procedures; IEEE 323-1974, Section 6.3.1.1, item (3), requires that the test plan include mounting and connection requirements. There are no mounting and connection requirements given in a test plan since the cable was qualified in accordance with IEEE 383-1974 which does not address mounting and connections for type testing. Itawever, the report documents that the cable was mounted and connected in the usual manner which consisted of winding the specimens on two concentric mandrels and passing the ends through pressure-sealing glan&s in the vessel head so that electrical connections could be made to the cable during LOCA testing. (5) NUREG 0388, Section 2.2 para. (3), Category I, states that IEEE 323-1974, Section 6.3, is an ac.eptable guideline for establishing test procedures; IEEE 323-1674, Sect'.on 6.3.1.1, item (7) , states that test equipment requiremen's incl' ding accuracie:s ehould be included in a test plan. The qualificati<.,n report does not address test equipment requirements O B-90 Revision 3
1 l DR-06 a
.(/ and accuracies. However, the report does include a list of data acquisition instruments which gives the range and features of the test equipment. A
' review of this list indicates that the test instruments used were appropriate for the testing that was done.
'(6) NUREG 0588, Section 2.2, para. (3), Category I, states that IEEE 323-1974, Section 6.3, is an acceptable guideline for establishing test procedures; Section 6.3.1.4 of IEEE 323-1974 states that the test equipment shall be calibrated against auditable calibration standards and shall have documentation to support such calibration. Although the report does not include any documentation of calibration, the list of data acquisition instruments does give the date the equipment was calibrated. It is reasonably safe to assume that the calibration was done to an acceptable standard.
(7) NUREG 0588, Section 2.2, para. (3), Category I, states that IEEE 323-1974, Section 6.3, is an acceptable guideline for establishing test procedures; IEEE 323-1974, Section 6.3.1.4.1 states that temperature, pressure, moisture content, gas composition, vibration, and time should be measured variables. These variables were measured, except vibration and gas composition, which are not applicable to cable, and the moisture content of the environment in the vessel during the LOCA simulation. Hevever, the test vessel included an open, heated reservoir of spray solution at the bottom to ensure a saturated condition during the test; furthermore, in an independent test, the cable was subjected to a water immersion test with a 600V DC potential applied between the conductors and the water for 2-3/4 years. Based on this 3
' () testing, the report concludes that Raychem Flastrol insulation is stable during longtime water ' inersion at 75'C and maintains acceptable and constant properties in this environment. ;
(8) NUREG 0588, Section 2.2, para. (3), Category I, states that IEEE 323-1974, Section 6.3, is an acceptable guideline for establishing test procedures; 4-
-Item (7) of Section 6.3.1.5 of IEEE 323-1974 states that the initial i
. environmental transient and dwell at peak temperature of the LOCA test should be applied at least twice. During the LOCA test, only a single transient was applied. However, the cable was qualified in accordance with 6 4 IEEE 383-1974 which states that "the post LOCA simulation test demonstrates an adequate margin of safety by requiring mechanical durability (mandrel bend) following the environmental simulation and is more severe than exposure to two cycles of the environment." The cable successfully completed the post LOCA 40x mandrel bend test; therefore, an adequate margin of safety has been established. I~ (9) NUREG 0588, Section 2.2, para. (3), Category I, states that IEEE 323-1974, Section 6.3, is an acceptable guideline for establishing test procedures; IEEE 323-1974, Section 6.3.2, states that the test sequence used should be justified as the most severe for the item being tested. No justification, i exists in the qualification report; however, the cable was qualified in accordance with IEEE 383-1974. The test sequecce given therein was taken as the most appropriate and severe for cable.
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= _.- -_ . . . . . . - - - -,
--...-.--,1
1 l DR-06 (10) NUREG 0588, Section 5, item (2), Category I, states that the guidelines for documentation in IEEE 323-1974 (which is Section 8) are acceptable when fully implemented; IEEE 323-1974, Section 8.3, item (1), states that the qualification report should include the equipment performance specification per Section 6.2 of IEEE 323-1974. The qualification documentation references the procurement documents which implicitly provide the equipment performance specificatiori. The failure to provide explicit performance specifications does not detract from adequacy of the qualification and therefore is acceptable.
~
G O B-92 Revision 3
DR-07 l l Sam el' Moore Instrument Cable (1) NUREG 0588, Section 2.2, paragraph 3, Category I, states that IEEE 323-1974, Section 6.3 is an acceptable guideline for establishing test procedures; IEEE 323-1974, Section 6.3.1.1, states that a test plan should be included in the qualification program. The qualification report does not include a test plan as described by Section 6.3.1.1. However, it is evident from a , review of the report that the test procedure followed is similar to . IEEE 383-1974, " Standard for Type Test of Class IE Electrical Cables, Field Splices, and Connections for Nuclear Power Generating Stations," which is , the accepted standard for type test of cable. Therefore, the failure to : include a test plan in the qualification program is considered inconsequential. In addition, most of the information required by Section 6.3.1.1 of IEEE 323-1974 is given in the body of the report. , (2) NUREG 0588, Section 2.2, paragraph 3, Category I, states that IEEE 323-1974, Section 6.3 is an acceptable guideline for establishing test procedures; IEEE 323-1974, Section 6.3.1.1 (3), requires that the' test plan include mounting and connection requirements. There are no mounting and connection requirements given in the report since IEEE 383-1974 does not address , mounting and connections for type testing. However, the report documents
- that the cable was mounted in a usual manner which consisted of placing it on a perforated metal shelf which simulated a cable tray and passing the ends through pressure sealing glands so that electrical connections could be made to the cable during LOCA testing. Thus, the above omission from the test plan is acceptable. ;
'(3) NUREG 0588, Section 2.2, paragraph 3, Category I, states that IEEE 323-1974, Section 6.3 is an acceptable guideline for establishing test procedures; IEEE 323-1974, Section 6.3.1.1, item (7) states that the test plan should ;
include test equipment requirements including accuracies. The report does i not address test equipment requirements and accuracies. However, the report a does include a list of data acquisition instruments which gives the range ; and features of the test equipment. From a review of this list it is evident that the instruments that were used were appropriate for the testing that was done. (4) NUREG.0588, Section 2.2, paragraph 3, Category I, states that IEEE 323-1974, Section 6.3 is an acceptable guideline for establishing test procedures; IEEE 323-1974, Section 6.3.1.4, states that the test equipment shall be calibrated against auditable calibration standards and shall have documentation to support such calibration. Although the report does not include any documentation for calibration, the list of data acquisition 1 instruments does give the date the equipment was calibrated. It is reasonably safe to assume that the calibration was done to en acceptable standr A. t (5) NUREG 0588, Section 2.2, paragraph 3, Category I, states 'that IEEE 323-1974,
. Section 6.3 is an acceptable guideline for establishing test procedures; IEEE 323-1974, Section 6.3.1.4 states that temperature, pressure, moisture content, ' gas composition, vibration, and time should be measured variables.
These variables were measured, except vibration and gas composition, which ! O ; B-93 Revision 3 + l
DR-07 are not applicable to cable, and the moisture content of the environment in O the vessel during the LOCA simulation. However, saturated conditions were maintained throughout the test since each test temperature and associated pressure correspond to a point on a saturation curve. (6) NUREG 0588, Section 2.2, paragraph 10, Categery I, as well as IEEE 323-1974, Section 6.3.1.5 item (5) state that the equipment should be subjected to variations in the nominal frequency during testing. The range of frequency this cable is expected to experience is not more than 5% of 60 Hz. Since variations of this insignificant degree have no effect on cable, it is considered that testing at the nomiaal frequency of 60 Hz is adequate. (7) NUREG 0588, Section 2.2, pargraph 3, Category I, states that IEEE 323-1974, Section 6.3 is an acceptable guideline for establishing test procedures; IEEE 323-1974, Section 6.3.1.5, item (7), states that the initial environmental transient and dwell at peak temperature of the LOCA test should be applied at least twice. During the LOCA test only a single transient was applied. However, IEEE 383-1974 states that "the post LOCA simulation test demonstrates an adequate margin of safety by requiring mechanical durability (mandrel bend) following the environmental simulation and is more severe than exposure to two cycles of the environment." The cable successfully completed the post LOCA 40X mandrel bend test; therefore, an adequate margin of safety has been established. (8) NUREG 0588, Section 2.2, paragraph 3, Category I, states the IEEE 323-1974, Section 6.3 is an acceptable guideline for establishing test procedures; IEEE 323-1974, Section 6.3.2 states that the test sequence used should be g justified as the most severe for the item being tested. No justification, as such, exists in the qualification report; however, the procedure that was followed is similar to that outlined in the IEEE 383-1974. The principle difference is that IEEE 383-1974 specifies that both normal and accident radiation exposure be applied prior to the LOCA test; in the tests of instrument cable, one-half of the total radiation exposure was applied after the LOCA simulation but before the mandrel bend test. Since the bend test was applied after radiation exposure was completed, this sequence is considered equivalent to the IEEE 383-1974 sequence. (9) NUREG 0588, Section 2.2, paragraph 3, Category I, states that IEEE 323-1974, Section 6.3 is an acceptable guideline for establishing test procedures; IEEE 323-1974, Section 6.3.2, item (3) states that the equipment should be operated to the extremes of all electrical characteristics prior to the LOCA simulation. The cable was not subjected to extremes of voltage, current, or frequency prior to the test. However, this is acceptatle since the cable was subjected to maximum voltage during the test and since frequency is not expected to vary significantly. (10) NUREG 0588, Section 5, item (2), Category I, states that the guidelines for documentation in IEEE 323-1974 (which is Section 8) when fully implemented are acceptable. IEEE 323-1974, Section 8.3, item (H), states that the qualification report should include an approval signature and date. The report is dated November 1973; however, there is no signature of approval. O B-94 Revision 3
i l 1 DR-07
- ).
%/ -The cover letter that submitted the report mentions the purchase order number; therefore, it is evident that the report applies to the cable that was purchased, and the signature on the letter meets the intent of the requirement.
(11) NUREG 0588, Section 4, paragraph (5), category I, states that known material phase changes and reaction should be defined for the accelerated aging program to insure that no known changes occur within the extrapolation limits. The Franklin Institute Research Lab and Samuel Moore knew of no phase changes or reactions associated with the instrument cable when they performed the accelerated aging tests and constructed the Arrhenius equation. Therefore, phase changes and reactions have not been addressed by the qualification report. (12) NUREG 0588, Section 1.2, paragraph (6), Category I, states that the LOCA test temperature should be defined by thermocouple readings on or as close as practical to the surface of the component being qualified. Although the test temperatures were measured, their exact method and location of sensors cannot be determined from the qualification report. However, more than adequate margin exists between the test temperature and the expected accident condition, and the vessel contained no internal restrictions. Therefore, the failure of the report to detail the method of temperature measurement does not detract from the validity of the qualification. (13) NUREG 0588, Section 5, paragraph (1), Category I states that "The 73 qualification documentation shall verify that each type of electrical ( ,) equipment is qualified for its application and meets its specified performances requirements. Section 5 of the report concludel" that all of the samples demonstrated satisfactory performances during t'Ae exposures simulating conditions of normal service, LOCA and cooldown following LOCA". However, it was also shown that two of the cables failed in one conductor each during the high potential withstand test applied after the LOCA simulation. The failure of these 600 V rated cables occured at voltages of 1950 volts and 2000 volts, after 45 seconds. Based on the fact that these cables were withstanding voltages of at least three times rated value, it demonstrated that the cables retained a substantial margin of life following the simulated LOCA condition. 1 B-95 i Revision 3
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DR-08 Valcor Solenoid Valses (1) NUREG 0538 paragraph 2.2 (3), Category I, specifies that the test plan should conform to the guidelines in Section 6.3 of IEEE Std. 323-1974. Paragraph 6.3.1.1 (1&2) requires equipment descriptions and number of units being tested to be included in the test plan. The Valcor test plan does not include a description of the equipment to be tested and the test plan does not identify the quantity of units to be tested. The Valcor test report is a generic report which identifies the units tested and the quantity. Therefore, omission of this data from the test plan is acceptable. (2) NUREG 0588 paragraph 2.2 (3), Category I, specifies that the test plan should conform to the guidelines in Section 6.3 of IEEE Std. 323-1974. Paragraph 6.3.1.1 (3) requires mounting and connection requirements to be identified in the test plan. The Valcor test plan does not address mountings or connections of LOCA testing. Mounting of the equipment is critical for seismic qualification; however, since environmental conditions will not induce additional loads on the equipment, mounting during LOCA testing will not affect equipment qualification. The Valcor test report identifies that the LOCA test chamber set up was designed to prevent moisture from entering through the conduit connection. When installed in the plant, the valve conduit connection will be hermetically sealed using D. G. O'Brien connectors to prevent moisture from entering the solenoid cover. Therefore, omission of this information from the test plan is acceptable. (3) NUREG 0588 paragraph 2.2 (3), Category I, specifies that the test plan should conform to the guidelines in Section 6.3 of IEEE Std. 323-1974. h Paragraph 6.3.1.1 (7) requires test equipment requirements including accuracies to be identified in the test plan. The Valcor test plan does not identify test equipment accuracy requirements; however, the Valcor test report does include this information. Therefore, the omission of this information from the test plan is acceptable. (4) NUREG 0588 paragraph 2.2 (10), Category I, specifies that expected extremes in power supply voltage range and frequency should be applied during simulated event environmental testing. The Valcor valves were operated at minimum voltage during the LOCA test. Omission of test data regarding frequency is acceptable since the solenoids are designed for D. C. operation and frequency considerations are not applicable.
- 3) NUREG 0588 paragraph 3 (2), Category I, specifies that the margins indicated in IEEE Std. 323-1974 Section 6.3.1.5 should be used as a guide. The Valcor report does not address all margins used. Valcor qualification is based on
?neric testing rather than the specific Virgil C. Summer conditions. This
( 1eric testing included margin considerations as identified in Section 5.0
- o. 'alcor Qualification Report #QR-526. The acceptance of the Valcor qua 4.fication documentation is based on the review that the generic testing cond uiona envelope the V. C. Summer conditions with sufficient margins for the application's critical parameters.
O B-96 Revision 3 .
DR-08 7 (3j (6) NUREG 0588 paragraph 2.3, Category I, specifies that the test sequence should conform fully to the guidelines established in Section 6.3.2 of IEEE Std. 323-1974. Section 6.3.2 (1) suggests a pretest inspection should be performed. The Valcor report does not identify that a pretest inspection was performed. The omission of a pretest inspection is acceptable since the equipment tested was new and demonstrated to be functioning properly. (7) NUREG 0588 paragraph 2.2 (6), Category I, specifies that when the equipment is exposed to the simulated accident environment, the temperature should be defined by a thermocouple reading on or as close as practical to the surface of the component being qualified. The location of the thermocouples used during the test was not identified in the report. This omission is acceptable since the LOCA environment within the test chamber was monitored by five thermocouples at various locations. The use of multiple thermocouples ensures that the test chamber environment is homogeneous and is an accurate representation of the environment being simulated. (8) NUREG 0588 paragraph 4 (4), Category I, specifies accelerated aging methods other than the Arrhenius methodology may be acceptable if it can be supported by type tests. The accelerated aging program utilized is based on equations in draft IEEE Std. 101A, Appendix B; which concludes that for every 10*C rise in temperature above the normal operating temperature, the test time duration is halved. This is consistent with state of the art methods and, therefore, does not compromise the equipment qualification. In addition however, age related failures will be monitored by the plant aging i program. (9) NUREG 0588, paragraph 2.2 (4), Category I, specifies that a single profile that envelopes the environmental conditions resulting from a design basis event should be used as the test profile. Both the main steam line break and LOCA postulated profile have a quicker temperature rise than the tested profile. This deviation from the test envelope is acceptable, since the rate of temperature rise for the postulated profiles exceeds the test profile only for a period of seconds, after which the test profile temperatures during the test exceeded the postulated temperature. B-97 Revision 3 .
DR-09 O Valcor Solenoid Valves (1) NUREG 0588 paragraph 2.2 (3), Category I, specifies that the test plan should conform to the guidelines in Section 6.3 of IEEE Std. 323-1974. Paragraph 6.3.1.1 (1&2) requires equipment descriptions and number of units being tested to be included in the test plan. The Valcor test plan does not include a deceription of the equipment to be tested and the test plan does not identify the quantity of units to be tested. The Valcor test report is a generic report which identifies the units tested and the quantity. Therefore, omission of this data from the test plan is acceptable. (2) NUREG 0588 paragraph 2.2 (3), Category I, specifies that the test plan should conform to the guidelines in Section 6.3 of IEEE Std. 323-1974. Paragraph 6.3.1.1 (3) requires mounting and connection requirements to be identified in the test plan. The Valcor test plan does not address mountings or connections for LOCA testing. Mounting of the equipment is critical for seismic qualification; however, since environmental conditions will not induce additional loads on the equipment, mounting during LOCA testing will not affect equipment qualific.cion. The Valcor test report identifies that the LOCA test chamber setup was designed to prevent moisture from entering through the conduit connection. When g installed in the plant, the valve conduit connection will be hermetically W sealed using D. G. O'Brien connectors to prevent moisture from entering the solenoid cover. Therefore, omission of this information from-the test plan is acceptable. (3) NUREG 0588 paragraph 2.2 (3), Category I, specifies that the test plan should conform to the guidelines in Section 6.3 of IEEE Std. 323-1974. Paragraph 6.3.1.1 (7) requires test equipment requirements including accuracies to be identified in the test plan. The Valcor test plan does not identify test equipment accuracy requirements; however, the Valcor test report does include this information. Therefore, the omission of this information from the test plan is acceptable. (4) NUREG 0588 paragraph 2.2 (10), Category I, specifies that expected extremes in power supply voltage range and frequency should be applied during simulated event environmental testing. The Valcor valves were operated at minimum voltage during the LOCA test. Omission of test data regarding frequency is acceptable since the solenoids are designed for D. C. operation and frequency considerations are not applicable. (5) NUREG 0588 paragraph 2.3, Category I, specifies that the test sequence should conform fully to the guidelines established in Section 6.3.2 of IEEE Std. 323-1974. Section 6.3.2 (1) suggests a pretest inspection should be performed. The Valcor report does not identify that a pretest inspection was performed. The omission of a pretest inspection is acceptable since the equipment tested was new and demonstrated to be g functioning properly. W B-98 Revision 3
DR-09 l i e ! (6) NUREG 0588 paragraph 2.2 (6), Category I, specifies that when the equipment i is exposed to the simulated accident environment, the temperature should be I defined by a thermocouple reading on or as close as practical to the surface of the smponent being qualified. The location of the thermocouples used during the test was not identified in the report. This omission is acceptable since the LOCA environment within the test chamber was monitored , by five thermocouples at various locations. The use of multiple thermocouples ensures that the test chamber environment is homogeneous and is an accurate representation of the environment being simulated. (7) NUREG 0588 paragraph 4 (4), Category I, specifies accelerated aging methods other than the Arrhenius methodology may be acceptable if it can be supported by type tests. The accelerated aging program utilized is based on equations in draft IEEE Std.101A, Appendix B; which concludes that for every 10*C rise in temperature above the normal operating temperature, the test time duration is halved. This is consistent with state of the art methods and, therefore, does not compromise the equipment qualification. In addition however, age related failures will be monitored by the plant aging program. O O B-99 Revision 3 .
DR-10 O (DELETED) O l l l O. B-100 Revision 3 l
b DR-11
) Reliance Motor - RB Cooling Unit 1
(1) NUREG 0588, paragraph 2.2 (3) Category I specifies that the test procedure i should conform to'the guidelines in Section 6.3 of IEEE Std. 323-1974. Paragraph 8.3.4c requires' a description of the test facility (test setup), but since J0Y considers this information as proprietary, it was not indicated in the J0Y qualification report (X-604). However, the test facility was. reviewed during a meeting at the test facility on May 14 and 75, 1979, as documented by Gilbert Associates, Inc. letter CGGS-18446, dated May 21, 1979. Therefore omnision of this data from report X-604 is i
- . acceptable.
(2) NUREG 0588, paragraph 2.2(1) Category I idenct'ies that the expected extremes and voltage and frequency should be applied during testing. Reliance tested the motors to a voltage extreme only. Since in motors the effects of small frequency changes are the same as amall changes in voltage, the effect of the expected 15% variation in frequency is adequately addressed by the testing to the expected extremes of voltage. (3) NUREG 0583, paragraph 2.2 (3) Category I specifies that the test procedure should' conform to the guidelines in Section 6.3 of IEEE Std. 323-1974. Paragraph 6.3.1.7 requires that the accuracy of the test equipment requirements must be specified. The J0Y motor qualification report (X-604) does not specify the accuracies for the equipment requirements, but since the JOY report includes test information, the omission of test equipment requirement accuracies is acceptable. (4) NUREG 0588, paragraph 2.2 (3) Category I specifies that the test procedure should conform to the guidelines in Section 6.3 of IEEE Std. 323-1974. 1 Paragraph 6.3.1.4 requires that the test equipment shall be calibrated against auditable calibration standards and shall have documentation to support each calibration. JOY has identified that the data determined from the tests was conservative, thereforr r3tving the test parameters an additional safety margin. Since JF c.(s not specify calibration details, but testing procedures provide 09 sa .xtts safety margin which takes into consideration possible instrriet ze errors, the JOY qualification methods are considered acceptable. (5) NUREG 0588, paragraph 2.2 (3), Category I, identifies that the test procedure should conform to the guidelines in paragraph 6.3 of IEEE Standard 323-1974. Paragraphs 6.3.1.2 and 6.3.1.3 require that equipment mountings and cable connections be relevant to performance. The P.eliance report does not address the mountings or cable connections used fo; environmental qualification. Mounting of equipment is critical for sei2cic qualification; however, environmental conditions will not include detrimental loading at the equipment mounting location. The method used for electrical connections to the motor leads is not signifi_ ant, provided these connections are insulated to prevent short circuits. The installation in the Virgil C. Summer Nuclear Plant utilizes taped splices to the motor leads. The qualification of these taped splices is addressed elsewhere in this report under the title of Kerite low voltage tapes. g B-101 Revision 3 .
DR-12 O (DELETED) O i r B-102 Revision 3
n.~ . .. , -.. .- , . . . . . - . DR-13 M Reliance Fan Motors (1). .NUREG 0588 paragraph 1.5 (1) Category I requires that equipment located , outside containment that could be subjected to high-energy pipe breaks should be qualified to the conditions.resulting from the accident for the duration required. The Reliance qualification report (NUC-9) states that the maximum concinuous-operating temperature allowed within the fan motor 7. specified is 174.8' C for a 40 year life. The rated temperature rise is 90* C. Maximum allowed ambient temperature for a 40 year life is then ; 84.8' C or 184.6* F. NUC-9 states that the fan motor specified is also qualified to operate continuously ugder the following environmental conditions: . radiation up to 2 x 10 Rads (TID, 40 years); relative humidity
- of 100%; and atmospheric pressure. Since these conditions equal or in most cases ex eed the design basis accident environment, the environmental qualifications indicated in NUC-9 are considered to be adequate.
(2) NUREG 0588 paragraph 2.2 (1) Category I identifies that the expected extremes and voltage and frequency should be applied during testing. Reliance tested the motors to a voltage extreme only. Since in motors the l ~ effects of small frequency changes are the same as small changes in voltage, the effect of the expected 15% variation in frequency is adequately i addressed by the testing to the expected extremes of voltsge. I (3) N1JREG 0588, paragraph 2.2 (6) specifies that when the equipment is exposed 1 to the simulated (accident) environment, the temperature should be defined ' by thermocouple readings on or as close as practical to the surface of the O ceme t 6 1 8 e 11ried. rae tec tie cr the tem > erat re erv device (thermocouple not specified in Reliance report) used during the test was not ; identified in the report. Since Reliance holds parts of the qualification program as proprietory, the Reliance Certificate of Compliance to the test I envelope is sufficient. } L , (4) NUREG 0588 paragraph 2.2 (3), Category I, identifies that the test procedure should conform to the guidelines in paragraph 6.3 of IEEE Standard 323-1974. Paragraphs 6.3.1.2 and 6.3.1.3 require that equipment mountings and cable connections be relevant to performance. The Reliance report does not I address the mountings or cable connections used for environmental 7 qualification. Mounting of equipment is critical for seismic qualification; however, environmental conditions will not induce detrimental loading at the equipment mounting location. The method used for electrical connections to the motor leads is not significant, provided these connections are insulated
- to prevent short circuits. The installation in the Virgil C. Summer Nuclear l Plant utilizes taped splices to the motor leads. The qualification of these t
- taped splicet is addressed elsewhere in this report under the title of !
l 'Kerite low voltage tapes. ! r (5) NUREG 0588, paragraph 3 (2) Category I identifies that in lieu of other proposed margins that may be found acceptable, the suggested values ! indicated in IEEE Standard 323-1974, Section 6.3.1.5, should be used as a l I g guide. The Reliance qualification report includes a margin over the , Virgil C. Summer conditions; however, the factor on pressure and the number I of environmental transients recommended by Section 6.3.1.5 were not used. O : B-103 i Revisiou 3 . (
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DR-13 These factors are not considered applicable since the transient to which these motors are subjected is so minor that the transient conditions are enveloped by normal service conditions used to establish the 40 year qualified life. Therefore, the margins used for the Reliance qualification are considered acceptable. (6) NUREG 0588, paragraph 2.4 Category I specifies that the analysis or operating experience should conform to the guidelines of IEEE Std. 323-1974. Paragraph 8.5.2 indicates that the interface or boundary conditions of the equipment should be contained in the analysis. The Reliance qualification report specifies the environmental conditions, including extremes of temperature and humidity and the resulting failures The most vulnerable components are also specified, such as the insulation, bearings, lubricants, seals. Since these components are encased in a frame, boundary conditions other then environmental effects, temperature, and humidity are considered not to have a major effect on the equipment's opera
- ion.
(7) NUREG 0588, paragraph 2.4 Category I identifies that analysis or operating experience should follow the guidelines set by IEEE Standard 323-1974. Paragraph 8.4 (3,5) indicates that the specifications and the comparisions of previous and new specifications should be stated in the qualification report. The Reliance report utilizes its operating experience to verify the qualified life of specific components and/or prove that a limited life need not be consideration for these components. Consequently, the aging of these components will not affect motor operation. Since these components are standard with the motor, and the new motor is basically the same as the one from which the operating experience was recorded, comparision of the motors is not required. (8) NUREG 0588, paragraph 2.2 (3) Category I specifies that the test procedure should conform to the guidelines in Section 6.3 of IEEE Standard 323-1974. Paragraph 6.3.1.7 requires that the accuracy of the test equipment requirements must be specified. The Reliance motor qualification report does not specify the accuracies for the equipment requirements, but since the Reliance report includes the equipment information, the omission of test equipment accuracies is acceptable. (9) NUREG 0588, paragraph 2.2 (3) Category I identifies that the test procedure should conform to the guidelines in Section 6.3 of IEEE Standard 323-1974. Paragraph 6.3.1.1.1 requires the test plan to include equipment descriptions. The Reliance report identifies that test models (motorettes) were used for much of the testing. IEEE Standard 177-1974 allows the selection of a "motorette" test as the basis for thermal evaluation of Class H, Type RH insulation systems. The Reliance report also indicates the model number of the complete motor tested for radiation endurance. Equipment descriptions for this model number can be found in the instruction manual included with the report. Therefore, omission of the equipment descriptions is acceptable. (10) NUREG 0588, Section 2.2, paragraph (7), Category I, specifies that the performance characteristics of equipment should be verified before, af ter and periodically during testing throughout its range of required O B-104 Revision 3 .
DR-13
!g v
/ operability. Reliance Summary Report C -9 summarizes the results of testing performed but does not include periodic test data. Reliance i considers the test data proprietary and available for review only at its )
offices in Cleveland, Ohio. NUC-9 reports no failures associated with performance testing and it is considered reasonable to conclude that equipment performance was monitored before, during, and after testing throughout its range of required operability. (11) NUREG 0588, Section 5, paragraph (2), Category I, states that the guidelines i for documentation in IEEE Std. 323-1974 when fully implemented are acceptable. The documentation should include sufficient information to address the required information identified in NUREG 0588, Appendix E. Reliance Summary Report NUC-9 summarizes the results of testing performed but does not include actual test data. Reliance considers the actual qualification data proprietary and .vailable for review only at its offices in Cleveland, Ohio. Until these doen vnts are reviewed, it cannot be concluded that the documentation requirements of NUREG 0588 and IEEE-1974, Section 8.3, have been met. Data will be audited prior to fuel load. (12) NUREG 0588, Section 5, paragraph (2), Category I, states that a Certificate of Conformance (C0C) by itself is not acceptable unless it is accompanied by test data and information on the qualification program. A COC has been received from the vendor that certifies specific equipment to a quality assurance specification. Reliance considers this specification proprietary and available for review only at its offices in Cleveland, Ohio. Until the review is complete, it cannot be concluded that the C0C requirements of NUREG 0588 have been met. COL will be audited prior to fuel load. (O) l B-104a Revision 3 . t-
DR-14 l O (DELETED) i e O l l f 9 B-105 Revision 3
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l (DELETED) 1 l l 1 I l O I i l
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I J
DR-16 Limitorque Valve Operators - In Containment (1) NUREG 0588, paragraph 2.2 (3) Category II specifies that the test procedure should conform to the guidelines in Section 5.2 of IEEE Std. 323-1971. Paragraph 5.2 requires that the test data accuracy must be specified. The Limitorque qualification report 600456 does not specify the accuracy for the test data, but it does specify that the test equipment has been calibrated by standards which require periodical calibration. Therefore- since adequate conservatism (margins) does exist in test results, the omission of the test data accuracies is acceptable. (2) NUREG 0588, paragraph 2.2 (10), Category II, identifies that the expected extremes in voltage and frequency should be applied during testing. Limitorque tested the v31ve operators to a voltage extreme only. Since this equipment is not expectnd to see significant frequency changes in its installed service, testing to a fixed frequency is acceptable. (3) Deleted (4) Special mounting configuration to prevent free ingress of chemical spray into the actuator limit switch compartment is under consideration. If s';xial installation is determined to be required, it will be performed. O l l l O B-107 Revision 3 .
1 l DR-17 h- Field Fabricated Panels (1) . NUREG 0588, Section 2.1, Paragraph 3(c), Category I, states that although actual testing of a complete unit is preferred, other methods when justified , may be found acceptable. The components of XPK 0040 were analyzed per IEEE Standard 323-1974 on an individual component basis. It was considered appropriate to use component test data from WYLE report 43703-1 to achieve i qualification'of the ET-16 indicating lights. It was also considered appropriate to use the analysis qualification method and the est data available from the Square D motor control center report 108-1.02-61 to achieve qualification for all other components installed in XPN0040. Both the Square D Qualification program and the Wyle Qualification program establishes a qualified life for XPN0040 for 40 years when replacement interval scheduling is followed. This method assures equipment function and at the same time maximizes the life of all components within local panel XPN0040. l (2) NUREG 0588, Section 2.2, paragraph 10, Category I, as'well as IEEE 323-1974, Section 6.3.1.5, item (5) states that the equipment should be subjected to variations in the nominal frequency during testing. The postulated maximum range of frequency excursions is stated in the qualification documentation as 1 5% in agreement with IEEE 323-1974. Although the frequency extremes were not applied to panel XPN 0040 components during testing, it is , considered the results are valid since we know of no components that are ! particularly sensitive to frequency variations. A (3) NUREG 0588, Section 3, Paragraph 2, Category I states that IEEE 323-1974,
- (/ Section 6.3.1.5 is an acceptable guideline for establishing margins. IEEE i
323-1974 Section 6.3.1.5 subparagraph (4) requires that a voltage margin of at least i 10% shall be used. The Square D electrical endurance tests for certain size contactors and starters were conducted at greater margins of
+ 19.8*t, (575 volts) or -13.5% (415 volts) for other size contactors and s ta rters. Since all the contactors and starters are similarly constructed using similar materials, it is not considered necessary to test each contactor or starter at the plus and minus volt ge margin. As the tested i
contactor and starter construction and material of construction are similar _to the contactors and start.ers installed, we find the test is applicable to , and satisfies the requirements. Fuses, Fuse Holders, Indicating Lights, Terminal Blocks, and Control Transformers were not exposed to voltage margins during testing, but we know
- that they should not be sensitive to the limits specified in IEEE 323-1974.
- (4) NUREG 0588, Section 3, paragraph 3, Category I, states that IEEE 323-1974 l
section 6.3.1.5 is an acceptable guideline for establishing margins.
- - IEEE 323-1974, section 6.3.1.5 subparagraph I states that a temperature margin of 15'F-shall be used. Temperature conditions were XPN 0040 indicate that an average temperature of 93*F will be seen at the pane i location. i Components qualified by the SQD report 108-1.02-L1 have been analyzed to have at least a 10 year life at 95'F except for size 1 starter coils which are qualified for 8 years. Componer.ts have been analyzed up-to 104*F which meets the possible worst case temperature condition for that location.
l'; B-108 Revision 3 I ?. -
DR-17 Indicating lamp G.E. ET-16 has been qualified by the Wyle Laboratory report 43703-1 for a 100*F extreme. GAI Report 2138 has established the lamp to have a life time of a little over 20 years with respect to thermal aging at 93*F. During aging tests we have found the component to withstand 239'F so that the lamp assembly can easily withstand 104'F. Therefore, all components mentioned in the above statements meet our operating requirements but do not necessarily envelope requirements set by IEEE 323-1974. (5) NUREG 0588, Section 2.1, paragraph 3(c), Category I, states that equipment that need not function in order to mitigate any accident and whose failure in any mode in any accident environment is not detrimental to plant safety need only be qualified for its non-accident service envircament. Although actual type testing is preferred, other methods when justified may be found acceptable. The basis should be provided for concluding that such equipment is not required to function in order to mitigate any accident and that its failure in any mode in any accident environment is not detrimental to plant safety. Local panel XPN0040 located in the auxiliary building at the 388' level is in the category of this equipment. XPN0040 and XMCIDA2Y are subject to the environmental effects which result from some postulated small line breaks. None of the postulated line breaks will cause a plant trip or result in protection system action. However, if charging pump B is out for maintenance and channel B electrically supplies charging pump C, pump C could be lost because of the loss of XPN0040 during a steam line break. Similarly, charging pump A could be lost due to the environmental effects of XMCIDA2Y. Appendix 13 to branch technical position APCSB 3-1, in paragraph 11(b) states that " environmentally induced failures caused by a a leak or rupture of the pipe which would not of itself result in protective W action but does disable protective functions. In this regard, a loss of redundancy is permitted, but a loss of function is not permitted. For such situations, plant shutdown is required." Since XPN0040 is not required to mitigate the consequences of any of the postulated line breaks, and since no protective action will result, the criteria given above permits a loss of redundancy, so long as function is maintained. Since the train B equipment will normally be and remain operable during steam line breaks, function is maintaint . Therefore, XPN0040 is not required to function in order to miti:; ate any of the postulated line breaks and its failure in any mode is not detrimental to plant safety. (6) NUREG 0588, Section 2.2, paragraph 3, Category I, states that IEEE 323-1974, Section 6.3, is an acceptable guideline for establishing test procedures; IEEE 323-1974, Section 6.3.1.1, item (7), st tes that the test equipment requirements, including accuracies, should be included in a test plan. Similarly, Section 6.3.1.4, states that environmental and electrical variables should be monitored using test equipment whose calibration can be traced to auditable calibration standards. In addition, NUREG 0588, Section 5, item (2), Category I, states that the guidelines for documentation in IEEE 323-1974 (which is Section 8) are acceptable when fully implemented; IEEE 323-1974, Section 8.3, item (4) (c), states that a description of the test facility and instrumentation used, including calibration records reference, should be documented in the report. The SQD report 108-1.02-L1 and GAI Report 2138 does not include complete details on test equipment, accuracies or calibration, and sometimes merely references B-108a Revision 3
DR or summarizes tests in support 'of qualification by analysis. More complete
- and detailed information on test equipment, accuracies, and calibration can be found in the referenced test reports and test facility files.
(7) NUREG 0588, Section 2.4, Category I, states that qualification by analysis or operating experience shall be acceptable if implemented in accordance with IEEE 323-1974. .Section 6.4.2 of IEEE 323-1974 requires-that the documentation shall include physical locations and mounting arrangements of the equipment in the operating facilities, as well as a maintenance log and analysis of all failures. Square D used operating experience as the basis for qualification of certain components, but in some cases has not provided specific end detailed information as required by IEEE 323-1974. However, the opero. cg experience covers many years, and a large population of similar components, used z*. many varied locations and environments. Furthermore, Square D has used the operating experience approach for analysis of passive devices (bus bars, terminal blocks and fuses) where failures are unusual. The radiation environment of the Virgil C. Summer Plant is not included within the Square D operating experience; however, radiation affects were analyzed using published material property data. In conclusion, Square D has taken a conservative approach in estimating qualified life based on-operating experience data; therefore, we find using general operating experience data by Square D is acceptable. (8) NUREG 0588, Section 4, paragraph 4, Categort I, states that the Arrhenius methodology is considered an acceptable metcod of addressing accelerated aging. Other methods that ein be supported by type tests will be evaluated on a case-by-case basis. The following are justifications for aging methods
-O used other than the Arrhenius methodology.
i Motor Starters and Relays The thermal life of Class IE motor starters and relays is based on a review of the thermal aging of the insulation ma: ^ 2ials. Underwriters' Laboratories (UL) continually evaluates the long-term properties of electrical insulation materials. Using the procedures of UL-746B, the generic temperature indexes have been established and published in the UL Recognized Component Index. Temperature indexes are assigned by UL at an extrapolated life of 11 years. Square D motor starters and relays are UL listed in accordance with UL-508. At the anticipated environmental
-conditions and applied equipment rating, the starter and relay insulation materials will operate at temperatures below their temperature indexes.
Thus, the operation results in an insignificant amount cf change in the material properties during 10 years of service due to thermal aging effects. Therefore, Square D concludes that the Qualified Life of the motor starters and relays is 10 years with respect to thermal aging. Starter Coils Since coil thermal life is directly related to time and temperature, accelerated thermal aging tests were performed. The test data was plotted in accordance with chemical reaction rate theory based on the work of
-Arrhenius. The slope of the curves vary slightly for each type of coil, but .O p 1 B-108b Revision 3 .
y Q ; '.; . + f . i & . .; f y .; Q* Q. [: ~.4 ; y / y [.g .f y .} ; Q 3 y _[ , g_[ DR-17 correlate with the approximate "10'C rule" for insulation deterioration which states that the life of insulation is reduced one-half for each 10aC rise in temperature. The results of the tests lead Square D to recommend that coils of NEMA Size 1 starters be replaced after 8 years of service and coils of NEMA Size 2, 3, and 4 starters be replaced after 10 years of service. Control Transformers Square D takes the position $at no industry accepted thermal accelerated aging technique as yet exists which can be applied to control transformers and yield valid results to predict service !ife. Therefore, the effects of thermal aging on the qualification of contrR transformers for Class IE service is based on an insulation material review. Type E0 transformers are UL Recognized Components which meet UL 506 " Specialty Transformers" requirements. Temperature rise tests were performed on sample open type transformers at 75% of rated load with the primary voltage at 90, 100 and 105% of rated voltage. The coil temperature rises at 100% voltage were used for thermal life calculations since they best represent the average conditions during the service life. All of the materials used in the primary insulation cystem have temperature ratings of 130k or more. Electrical insulation materials used for transformers are tested and rated per IEEE standards 1-1969, 98-1972, 99-1370, and 117-1974. Based on IEEE evaluation procedures, insulation material operating continuously at its rated temperature reaches its half-life at 20,000 to 40,000 hours. Using a service temperature of 100*C in the 10'C rule equation to calculate the estimated thermal life, and considering the presence of unknown variables which influence the overall thermal life, Square D concludes that h the control trans'ormers have a Qualified Life with respect to thermal aging of at least 15 years. Terminal Blocks and Terminal Lugs The thermal aging effects due to ambient temperature and current load are considered to be negligible and insignificant on terminal blocks and terminal lugs. This is based on the low level of current which will be passing through the control circuits. Although there is not an exact method available for determining the Qualified Life of these components, Square D bases its qualification on the low level of currents which are anticipated ~ and past operating experience which indicates no significant problem areas. Therefore, Square D concludes that these components would be qualified with respect to thermal aging for at least 40 years. Control Circuit Fuses Although there is no direct method or theory on which to base a Qualified Life for fuses, the manufacturer, Bussman, has stated that under normal service conditions this type of fuse "cannot deteriorate with age, nor can its rating change." Although this statement would indicate an unbounded life expectancy, Square D is aware of the importance of assurance of proper operation of the Class IE equipment. After the manufacturer was informed of the specific application, it was concluded that the fuses would not be O B-108c Revision 3
DR-17
,q \m l affected by thermal aging for at least 10 years under specified operating cond*+'ons. Therefore, Square D recommends that the control circuit fuses be - .ced every 10 years.
(9) NUREG 0588, Section 4, paragrapc 5, Category I, requires that known material phase changes be defined. The MCC qualification report does not address phase changes. However, the design environment does not include unusual extremes of temperature or pressure (i.e. it is a normal, non-accident environment). This is a basically standard line of equipment, having standard components, that will be operating in an environment which is considered by industry as normal. It is reasonable te emetae that any unacceptable material phase changes which occur under normal environmental conditions will have been detected and eliminated during the development and early operating years of this established product line. 3adiation is the only unusual aspect of the environment and the report demonstrates that all components and materials will not suffer damage or unacceptable change of properties when subjected to the postulated 40 year total integrated radiation dose. Therefore, we conclude that material phase changes are not an aging factor for this equipment. (10)' NUREG 0588, Section 4, r..ragraph 1 states that the aging effects on all equipment should be ct.asidered during testing. This agrees with IEEE 323-1974, section 6.3.3. The ET-16 indicating lamp was tested in accordance with this criteria and it failed the mechanical cycling test. No failures except indicating function and a cracked lens cap resulted. These failures are not critical to plant safety because they have no effect on the () operation of the equipment in XPN0040. Relative humidity conditions at XPN0040 should average 50-55% over the lifetime of- the plant at the XPN0040 location. The ET-16 indicating lamp has been tested up to 65% relative humidity. We do not expect-any performance deviations during small time periods where our test data does not meet an excursions up to 90% relative humidity. (11) NUREG 0588, Section 2.2, Category I, paragraph 12 states that Cobalt 60 is an acceptable source of radiation used for environmentai aging. The SQD qualification report 108-1.02-L1 and GAI Report 2138 has stated that the materials used in device construction have been analyzed per data supplied by industrially accepted reference books. When analyzed this material has been found to be acceptable for its intended use at its location. i i B-108d j Revision 3 . l
DR-18 7200 Volt Speed and Transfer Switches (1) NUREG 0588, Section 2.2, paragraph (3), Category I, states that IEEE 323-1974, Section 6.3 is an acceptable guideline for establishing test procedures. IEEE 323-1974, Sections 6.3.1.2 and 6.3.1.3 require that the test plan includes mounting of connection requirements. There is no mounting and connection information in the Gould qualification report. The qualification report identifies the industrial standard design tests to which the equipment was subjected. These industry standards :equire that proper and appropriate mounting and cennection be utilized during testing. Therefore, the uk of infort < u,n on quipment mounting does not detract from the acceptautlity of the qualification documentation. (2) NUREG 0588, Section 2.2, paragraph (3), Category I, states that IEEE 323-1974, Section 6.3 is an acceptable guideline for establishing test procedures. IEEE 323-1974, Section 6.3.1.4 states that the test equipment shall be calibrated against auditable calibration standards and shall have documentation to support such calibration. The qualification report does not identify the instrumentation used in the standard industrial design tests, nor the calibration requirements of the instruments used. But the qualification report does refer to each of the industrial design test standards and the test report prepared for each performed test. Since Gould-Brown Boveri has a quality assurance program which complies with 10CFR50, Appendix B, which requires that, " measures shall be established to assure that tools, gages, instruments, and other measuring and testing devices used in activities affecting qualified are properly controlled, g calibrated and adjusted at specific periods to maintain accuracy within W necessary limits." Therefore, the lack of instrumentation data from the , qualification documentation is acceptable. (3) NUREG 0588, Section 5, paragraph (2), Category I, states that IEEE 323-1974 guidelines for documentation p r<. fully acceptable when fully implemented. Section 8.2 of IEEE 323-1974 aquires that the user shall maintain a qualification file that shall contain test results. Gould-Brown Bcveri has included references in their qualification report, which they retain in their permanent file as proprietary information. Since Gould-Brown Boveri has cominitted to maintain this information in their permanent file, this is an acceptable alternate to maintenance of this information, by SCE&G. (4) NUREG 0588, Section 2.1, paragraph (3)(a), Category I, states that equipment that must function in order to mitigate any accident should be qualified by test to demonstrate its operability for the time required in the environmental conditions resulting from that accident. The transfer switch must operate to mitigate a LOCA, but the only changes in environmental conditions that would be experienced by the switch 4 during a LOCA would be an increase in radiation to less than 1 15x 10 RADS. Switch components were type tested and quglified for 1 x 10 RADS and the switch was qualified by analysis to 1 x 10 RADS. Due to the low level of radiation actually seen during a LOCA and the large margin between the expected exposure dose and the test dose of radiation for which the components and, therefore, the switch, are qualified, analysis and partial type testing are sufficient to qualifv the switch for a LOCA. B-109 Revision 3 .
DR-18 m (_,) (5) NUREG 0588, Section 2.2, paragraph (12), Category I, states that Cobalt-60 is an acceptable source of gamma radiation. The qualification report does net specify what gamma radiation source was used for radiation testing. However, there is such a large margin between the expected environmental conditions and the radiation dose for which the report qualifies the equipment, that the equipment is qualified even if Cobalt-60 was not the gamma radiation source. (6) NUREG-0588, Section 2.2, paragraph (6), Category I, states that the simulated accident temperature should be defined by thermocouples on or near the surface of the component being qualified. Page 4.9 of the subject report did not state that thermocouples werc used; however, it was stated that when the equipment was tested in reference to ANSI C37.20 temperatures were measured within the equipment and were within the allowable limits. Testing to accident environment temperature was not necessary because the equipment is Category C2 and, therefore, needs to function only in a normal nonaccident environment. (7) NUREG 0588, Section 2.1, paragraph (3)(c), Category I, states that equipment that need not fanction in order to mitigate any accident and whose failure in any mode in any accident environment is not detrimental to plant safety need be qualified only for its non-accident service enviroament. Although actual type testing is preferred, other methods, when justified, may be found acceptable. The basis should be provided for concluding that such equipment is not required to function in order to mitigate any accident and _. that its failure in any mode in any accident environment is not detrimental to plant safety. Transfer switch XET2002C, located in the auxiliary
'- building at the 388' level is in this category of equipment. Transfer switch XET2002C, panel XPN0040 and motor control center XMCIDA2Y are subject to the environmental effects which result from some postulated small line breaks. None of these postulated Ifee breaks will cause a plant trip or result in protection system action. However, should charging pump B be out of service for maintenance and charnel B be electrically supplying charging pump C, charging pump C could be lost as a result of loss of transfer switch XET2002C during a small line break. Similarly, charging pump A could be lost due to the environmental effects on motor control center XMCIDA2Y.
Appendix B to Branch Technical Position APCSB3-1 states in paragraph 11(b) states that " environmentally induced failures caused by a leak or rupture of the pipe which would not of itself result in protective action but does disable protection functions. In this regard, a less of redundancy is permitted, but a loss of function is not permitted. 7or such situations plant shutdown is required." Since transfer switch Xt12002C is not required to mitigate the consequences of any of the postulated line breaks, and since no protective action will result, the criteria given above permit a loss of redundancy so leng as function is maintained. Since the Train B equipment will normally be, and remain, operable during steam line breaks, function is maintained. Therefore, transfer switch XET2002C is not required to function in order to mitigate any of the postulatad line breaks and its failure in any mode is not detrimental to plant safety. B-109a Revision 3 . l l 1
DR-19 Iso Fuses for Heat Trace (1) NUREG 0588, Sections 2.1, 2.2, 2.3, 2.4, 3, 4, and 5, Category I describe the criteria for qualifying the isolation fuse blocks and fuses in the heat tracing panels. The qualification report does not fully comply with any of the above sections. However, both the fuse blochs and fuses were manufactured to applicable industry standards and the Gould-Shawmutt fuses are UL listed. Although there is no qualification data available to demonstrate that the fuse blocks and fuses will operate satisfactorily under environmental extremes, it is evident from the characteristics of fuses f. hat during extremes of environmental conditions (maximum temperature, humidity, radiation) the worst possibility is that fuses will prematurely open the circuit thus class IE circuits will be isolated as required. Therefore, absence of detailed information in the qualification report is acceptable. Since a qualified life is not defined for these fuses and fuse block, they will be addressed in the plant aging program even though their possible failure due to age related degradation would not be detrimental to plant safety. O O B-110 Revision 3
a -ma. --- s,.,u.. -+s- < a>w e w - - aa_- m+-a - .---a va- .a a, s - - . _,, _u, ,,_, DR-20 O i (DELETED) V i i f O f d [ l l l O B-111-112 Revision 3
DR-21 O (DELETED) f 1 I t O . i l I l I I i i I I t I i I Oi l B-113 I Revision 3 e [
DR-22
; s-I
-Raychem HVT-CBN (1) NUREG 0588, Section 2.2, paragraph 3, Category II, states that IEEE 323-1971, Section 5.2 is an acceptable guideline'for establishing test procedures; IEEE 323-1971, item 5.2.1 requires that the test data include the equipewat specifications. The terminations are a manufacturer's standard item and manufacturer's product name and catalog number (Thermofit HVT-CBN) are referenced on the purchase order and bill-of-material. 'Since the manufacturer's qualification report transmittal letter references the catalog numbers, the intent of this requirement is satisfied.
, (2) NUEEG 0588, Section 2.2, paragraph 3, Category II, states that IEEE 323-1971, Section 5.2 is an acceptable guideline for establishing test
- procedures; IEEE 323-1971, items 5.2.3.2 and 5.2.4.5 state that the test program outline and test results shall include accuracy of measured 4
variables. The qualification test report 71100 gives accuracy of aging temperatures, but not other measured variables. However, the terminations were qualified to a simulated LOCA environment giving margins far in excess of those required by NUREG 0588, Section 3, paragraph 4, Category II for the postulated MSB/SLB accident environment. Therefore, the omission of accuracies for some of the measured variables is considered inconsequential. (3) NUREG 0588. Section 2.2, paragraph 3, Category II states that IEEE 323-1971, Section 5.2.is an acceptable guideline for establishing test procedures; IEEE 323-1971, item 5.2.3.3 states that the test program outline shall include the number, type, and location of test monitoring sensors for each
, variable. The qualification test report 71100 does not include this information. However, the terminations were qualified to a simulated LOCA , environment giving margins far in excess of those required by NUREG 0588, Section 3, paragraph 4, Category II for the postulated MSB/LSB accident environment. Therefore, the precise number, type, and location of monitoring sensors is considered inconsequential. This information should be maintained on file by Raychem, if needed.
(4) _ NUREG 0588, Section 2.2, paragraph 3, Category II states that IEEE 323-1971, 3 Section 5.2 is an acceptable guideline for establishing test procedures; i IEEE 323-1971, item 5.2.3.4 states that the test program outline should include the static and dynamic performance characteristics. This item is t not applicable to cable terminations which are passive in nature, and, therefore, such information is not included in the qualification documentation. It should be'noted that this information is not required by either IEEE 323-1974 or NUREG 0588 Appendix E. (5) NUREG 0588, Section 2.2, paragraph 3, Category II states that IEEE 323-1971, l Section 5.2 is an acceptable guideline for establishing test procedures; IEEE 323-1971 item 5.2.3.9 requires that the test program outline include acceptance criteria. The qualification test report 71100 does not separately list or state acceptance criteria. However, the discussion of i test results and summary conclude that the test results are acceptable and that functional capability of terminations, after LOCA and aging, was demonstrated. Therefore,.it is considered the qualification documentation , satisfies the intent of this requirement. LO B-114 Revision 3 . ~
DR-22 (6) NUREG 0588, Section 2.2, paragraph 3, Category II states that IEEE 323-1971, Section 5.2 is an acceptable guideline for establishing test procedures; IEEE 323-1971, item 5.2.4.3 states that the test results shall include test instruments and traceability records. While nanufacturers are expected to keep such information on file, it is not normally included with submitted qualification documentation. (7) NUREG 0588, Section 2.2, paragraph 3, Category II states that IEEE 323-1971, Section 5.2 is an acceptable guideline for establishing test procedures; IEEE 323-1971, items 5.2.4.7 and 5.2.6 require that the test data and test report bear un approval signature; however, it has an identifying number and revision, both of which are stated in the manufacturer's transmittal letter. Since this letter gives date of testing, bears the manufacturer's letterhead, and is signed, the intent of this requirement is essentially satisfied. (8) NUREG 0588, Section 2.2, paragraph 6, Category II, states that the LOCA test temperature should be defined by thermocouple readings on or as close as practical to the surface of the equipment being qualified. The report 71100 does not describe the method or location of temperature measurement. However, there is sufficient margin between the test temperature and the required temperature, that the omission of this data from the report does not detract from the acceptability of the qualification. The Franklin Institute report, F-C4033-3, does use thermocouples. (9) NUREG 0588, Section 2.2, paragraph 10, Category II, states that the g equipment should be subjected to variations in the nominal frequency W testing. The range of frequency the terminations are expected to experience is not more than 5% of 60 Hz. Since variations of this insignificant degree have no effect on passive devices such as terminations, it is considered that testing at the nominal frequency of 60 Hz is adequate. (10) NUREG 0588, Section 2.2, paragraph 6, Category II states if there were no thermocouples located near the equipment during the tests, heat transfer analysis should be used to determine the temperature of the component. No evidence is presented in the report that either thermocouple readings or heat transfer analysis were used. The report does state however, that the material was aged in a forced air oven at 120* 1 2*C for 168 hours. This temperature i 3 C was also used in the test sequence, thus indicating that some type of temperature measurement was used. (11) NUREG 0588, Section 4, paragraph 2, Category II states the qualification programs should address aging only to the extent that equipment that is composed, in part, of materials susceptible to aging effects should be identified, and a schedule for periodically replacing the equipment and/or materials should be established. The qualification report does not address these items. Aging effects have been considered and a 40 year life has been calculated for each of the 8 KV-High Voltage Terminations. These calculations are on file in the Gilbert Associates Electrical Engineering Department. O B-115 Revision 3
DR-22 (
. (12) NUREG 0588, Section 2.3, paragraph 1, Category II states that the test sequence selected should be justified. The test sequence in F-C4033-3 is justified because it followed the guidelines set forth for cables in IEEE-383-1974 and IEEE-323-1974. While no justification for the test sequence utilized for report 71100 is included in the report, the test sequence is more severe than that in the F-C4033-3 report and is therefore justified.
O ( B-116 ' Revision 3
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DR-23 O (DELETED) O l B-117-119 g Revision 3 W I_______-________
A<
% DR-24 ' vp0 : Kerite 600V Control' Cable / Splicing Tapes and Cement I
(1). NUREG 0588, Secton 2.2, paragraph 1, Category I, as well as IEEE 323-1974, section 6.3.1.1, Item (9),' states that performance limits or failure l criteria should be established prior to testing. Neither Kerite nor i Franklin Institute specifically established failure criteria prior to to ! testing; however, test procedures followed those outlined in IEEE 383-1974 and IEEE 383, Sectiot. 2.4.3, implies that the inability to maintain rated voltage and load constitutes failure and Section 2.4.4 implies that the inability to hold an 80 volt / mil potential for five minutes constitutes failure. (2) NUREG 0588, Section 2.2, paragraph 2, Category I states that the test results should demonstrate operability of the equipment under all service conditions (with margin). The test results indicated that one of the aged cables tested failed on the 29th day prior to the termination of the LOCA/MSB simulation test on the 30th day. In addition, this cabte along
. with the other' aged cable tested failed to pass the high voltage potential test after the LOCA/MSL simulation and only one of the four cables was subjected to a sufficiently high voltage potential to satisfy the requirements in IEEE 383-1974, Section 2.4.4. Kerite stated in their summary report that based on Arrhenius analysis the cable was qualified; however, this analysis is not currently available so there is no data supporting Kerite's statement. This data has been requested from Kerite.
(3) NUREG 0588, Section 2.2, paragraph 4, Category I, states that the simulated O vire t t aretite ter e tirvi = ee ir t 1 14 ce t i the environmental conditions resulting from any design bat.is event during t ter-any mode of plant operation. The test envelope includes the pressure and temperature boundaries of a LOCA and MSB except for the 40 sec. peak temperature associated with the HSB as illustrated in figure 6.2 - Sa of the FSAR. The test temperature was 300*F and the short peak temperature of the MSB rises from 300*F to 324*F and then decreases to 300*F in a forty sec. period. The temperature and pressure test envelope specified for a LOCA in the 10/31/75 letter from GAI to Kerite was intended to cover the worst case accident. The NRC revised the acceptable calculation method in 1977-78 for determining the temperature in containment following a MSB. For the Virgil C. Summer Station qualification, this resulted in the maximum
- temperature for the MSB exceeding the maximum LOCA temperature which was stated to be 277*F. Kerite has supplied test data showing that during a 40 second exposure to 324*F the cable insulation does not reach a temperature of 300*F and since this is a more severe condition than exists during an MSB, the cable tests do envelop a LOCA and an MSB.
(4) _ NUREG 0588, Section 5, paragraph 2, Category.I, states that the guidelines for documentation in IEEE 323-1974 when fully implemented are acceptable. The documentation required for a complete qualification file hr.s not been submitted to GAI by Kerite. The required data to complete the qualification report has been requested from Kerite or a statement that the complete qualification file exists and that they will retain it to meet the auditing
- requirements of IEEE 323-1974.
3 (a - B-120 Revision 3 .
DR-24 (5) NUREG 0588, Section 2.2, paragraph 10, Category I, as well as IEEE 323-1974, states that equipment should be subjected to variations in the nominal electrical alternating current frequency during testing. The range of frequency this cable is expected to experience is not more than 1 57,of 60 Hz. Therefore, testing at the nominal frequency of 60 Hz. is adequate. (6) NUREG 0588, Section 4, paragraph 5, Category I, state that known eaterial phase changes and reactions should be defined for the accelerated aging program to insure that no known changes occur within the extrapolation limits. Kerite knew of known phase changes or reactions associated with the 600 volt control cable when they performed the accelerated aging tests and constructed the Arrhenius plots. Therefore, phase changes and reactions have not been addressed by the qualification report. (7) NUREG 0588, Section 2.2, partgraph 3, Category I, states that IEEE 323-1974, section 6.3, is an acceptable guideline for establishing test procedures. IEEE 6.3.1.1, item (3), requires that the test plan include mounting and connection requi ements. There are no mounting and connection requirements given in the test plan since the cable was qualified in accordance with IEEE 383-1974, " Standard for Type Test of Class IE Electric Cables, Field Splice, and Connections for Nuclear Power Generating Stations", which does not address mounting and connections for type testing. However, the report documents that the cable was mounted and connected in the usual manner which consisted of winding the specimens on a mandrel and passing the ends through - vessel head penetrations so that electrical connections could be made to the cable during LOCA testing. h (8) NUREG 0588, Section 2.2, paragraph 3, Category I, states that IEEE 323-1974, l Section 6.3 is an acceptable guideline for establishing test procedures; , IEEE 323-1974, Section 6.3.1.1, item (7) states that the test plan should include test equipment requirements including accuracies. The report does not address test equipment requirements and accuracies. However, the report does include a list of data nquisition instruments which gives the raage and features of the t 6 _quipment. From a review of this list, it is evident that the instruments that were used were appropriate for the testing that was done. (9) NUREG 0588, Section 2.2, paragraph 3, Category I, states that IEEE 323-1974, section 6.3, is an acceptable guideline for establishing test procedures. IEEE 323-1974, section 6.3.1.5, item (7), states that the initial transient and dwell at peak temperature of the LOCA test should be applied at least twice. During the LOCA test, only a single transient was applied. However, the test procedures follow those outlined in IEEE 383-1974, Section 2.4 and includes a high voltage withstand test in place of the two LOCA cycles. Since it conforms to IEEE 383-1974, by NUREG 0588, introduction, paragraph 2, it complies with IEEE 323-1974. O B-121 Revision 3
DR-24 m (' ') (10) NUREG 0588, Section 2.2, paragraph 3, Category I, states that IEEE 323-1974, Section 6.3, is an acceptable guideline for establishing test procedures. IEEE 323-1974, Section 6.3.2, states that the test sequence used shall be justified as the most severe for the item being tested. No justification exists ~in the qualification report. However, the test sequence followed the one outlined in IEEE 383-1974 and is thus considered to be the most severe test for cables. (11) NUREG 0588, Section 2.2, paragraph 3, Category I, states that IEEE 323-1974, Section 6.3 is an acceptable guideline for establishing test procedures. IEEE 323-1974, Section 6.3.2, paragraph 4 states that equipment should be aged in accordance with IEEE 323-1974, Section 6.3.3 prior to subsequent testing. Kerite's summary report dated November 25, 1975 states that the cable was aged for 100 hours at 150*C in a hot air oven. This conforms to IEEE 323-1974, Section 6.3.3; however, the stpplementary aging report cited does not specifically refer to FR-cable insulation. Clarification of this point is being requested from Kerite. (12) NUREG 0588, Section 4, paragraph 6, Category I describes that the aging acceleration rate used during qualification testing and the basis upon which the rate was established should be described and justified. Kerite cable / tape qualification report does not clearly justify the 40 yrs life Arrhenius plot for the cable insulation. A letter has been written to Kerite for providing us with proper justification. (13) NUREG 0588, Section 3, paragraph 4, Category I, indicates that the 10% ( ,, time margin identified in Section 6.3.1.5 of IEEE 323-1974 should be used for equipment required for extended times after a design basis event. The LOCA test for the Kerite control cable was limited to 30 days, and as noted in paragraph (2) above, some unresolved failures occurred. However, the control cable is required for up to one year following an LOCA. , Kerite is being asked for assistance in demonstrating the capability of the cable for up to one year post accident. r i O B-122 Revision 3.
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f t DR-28 l l l NAMCO 1.imit Switches (1) NUREG 0588 paragraph 4. (9: . Category 1, specifies that the qualified life of the equipment and the basis for selection should be defined. The test results do not identify a qualified life period. IIcat aging conditions were taken from ANSI Draft Standard N278.2.1 (Draft 3, Rev. 0). The non-metallic components of the limit switch are:
- a. contact block and carrier assemblies glass filled polyester thermoset plastic
- b. gaskets - nitrile-butadiene
- c. o' rings - EPR The significant aging mechanism for the switch is actuation cycles. The test switch was subjected to 100,000 actuation cycles witheit switch failure. Subsequent tests by NAMCO have shown that the switches can be operated up to 3,000,000 cycles. The switeries as installed will be subjected to periodic testing to verify operability. If failures are noted in a switch during plant testing, evaluation to determine if the failure is random or generic will be performed, and appecpriate replacements will be implemented.
(2) NUREG 0588 paragraph 2.2 (3), Category I, speciff es that the test procedure should conform to the guidelines described in Sectior 6.3 of IEEE Standard 323-1974. Paragraph 6.3.1 indicates that a test plan should be included. The NAMCO test report is a generic report which documents a test that had g been conducteo previous to the award of the Virtsil C. Summer purchase order. W The acceptance of the NAMCO qualification docume2tation is based on a review of the generie test data as it applies to tha Virgil C. Summer station application. Therefore, the omission of a test plan is acceptable. (3) NUREG 0588 paragraph 2.2 (10), Category I, identifies that the expected extremes in voltage and frequency should be applied during testing. NAMCO tested the limit switches using a 100 V DC power supply. Since the limit switches carry the voltage from a qualified Clas9 IE power source and do not have coils or other components whir:h would require a minimum " pull-in" voltage or be susceptable to frequency variations, testing to a fixed voltage is acceptable. (4) NUREG 0588 paragraph 2.2 (6), specifies that when the equipment is exposed to the simulated accident environment, the temperature should be defined by thermocouple readings on or as close as practical to the surface of the component being qualified. The location of the thermocouple used during the testing was not ideatified in the report. The small volume of the test chamber (12" high by 8" in diameter) renders the exact location of the tN'mocouple insignificant. Therefore, this omission is acceptable. B-129 Revision 3 . ; i
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(5) NUREG 0588 paragraph 3 (2), Category I, identifies thar, in lieu of other proposed margins that may be found acceptable, the suggested values indicated in IEEE Std. 323-1974, Section 6.3.1.5, should be used as a guide.
The NAMCO LOCA envelope includes a margin over the Virgil C. Summer
.onditions; however, all factors addressed by Section 6.3.1.5 were not used.
The NAMCO qualification is based on generic testing rather than the specific Virgil C. Summer conditions. ;_e acceptance of the NAMCO qualification documentation is based on the generic testing conditions enveloping the Virgil C. Summer conditions with sufficient margins for the application's critical parameters. (6) NUREG 0588 paragraph 2.2 (3), Category I, specifies that the test plan should conform to the guidelines in Section 5.3 of IEEE Std. 323-1974. Paragraph 6.3.1.1 (3) requires mounting and connection requirements to be identified in the test plan. The NAMCO test plan does not address mountings or connections for LOCA testing. Mounting of the equipment is critical for seismic qualification; however, since environmental conditions will not induce additional loads on the equipment, mounting during LOCA testing will not affect equipment qualification. The NAMCO test report identifies that the LOCA test chamber set-up was designed to prevent moisture from entering through the conduit connection. When installed in the plant, the limit switch conduit connection will be hermetically sealed using D. G. O'Brien connectors to prevent moisture from entering the limit switch cover. O l ( i l B-130 ! Revision 3 .
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,m D. G. O'Brien (1) NUREG 0588, Section 2.2, paragraph (10), Category I, as well as IEEE 323-1974 Section 6.3.1.5, Item (5), state that equipment should be subjected to variations in the nominal frequency during testing. The range of frequency the penecrations are expected to experience is not more than
+5% of 60 Hz. Since variations of this insignificant degree have no effect on the penetrattans, testing at the nominal frequency of 60 Hz is adequate.
(2) NUREG 0588, Section 2.2, paragraph 3, Category I, states that IEEE 323-1974, Section 6.3 is an acceptable guideline for establishing test procedures; IEEE 323-1974 Section 6.3.2 states that the test sequence used should be justified as the most severe for the item being tested. No justification, as such, exists in the qualificatica report; however, the penetrations were qualified in accordance with the criteria as set forth in IEEE 317-1976. The test sequence given therein was taken as the most appropriate and severe for penetration testing. The qualification report has not followed the exact test sequence as outlined; however, it is felt the report has adequately demonstrated and met the intent of IEEE 317-1976. (3) NUREG 0588, Section 2.2, paragraph (3), Category I, states that IEEE.323-1974, Section 6.3 is an acceptable guideline for establishing test ; procedures; IEEE 323-1974 Section 6.3.1.1 states that a test plan should be included in the qualification repert. The report does not include a test plan as described by Section 6.3.1.1 of IEEE 323-1974. The penetrations were qualified by utilizing IEEE 317-1976 " Electrical Penetration Assemblies O in Containment Structures for Nuclear Power Generating Stations" as a guideline for the testing procedure. The failure of the report to include a separate test plan was considered inconsequential since it has met the intent of the test procedures as outlined in IEEE 317-1976. , (4) NUPIG 0588, Section 4, paragraph (5), Category I, states that known material i phase changes and reactions should be defined for the accelerated aging program, to insure that no changes occur within the extrapolation limits. D. G. O'Brien, Inc. knew of no phase changes or reactions associated with the penetrations when they performed the accelerated aging tests and constructed the Arrhenius plots. Therefore, phane changes and reactions have not been addressed by the qualification report. ' (5) NUREG 0588, Section 2.2, paragraph (3), Category I, states that IEEE 323-1974, Section 6.3 1s an acceptable guideline for establishing test procedures; IEEE 323-1974, Section 6.3.1.4.1 states that temperature, pressure, moisture content, gas composition, vibration and time should be
- measured variables. Section B, Sheet 7 of the report summarizes the setup and operating requirements for the test. Included is a r,chematic which references the temperature indicating thermocouples, pressure indicators and associated instrumentation for measurement of moisture content and gas composition. The time variable is accounted for in Fig. 1 of Sec. (A).
Vibration is not applicable to penetrations. The report does not include step by step sequence measurements of the subject variables; however, adequate measurement indications are referenced on applicable tables and graphs. B-133 Revision 3
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DR-30 (6) NUREG 0588, Section 2.2, pars japh (3), Category I, states that IEEE 323-1974 Section 6.3 is an acceptable guideline for establishing test procedures; IEEE 323-1974, Section 6.3.1.4 states that the test equipment should be calibrated against auditable calibration standards and shall have documentation to support such calibration. This report does not include formal test equipment calibration documentation; however, the date the associated test equipment was calibrated or due date to be calibrated was referenced in the report. In addition, D. G. O'Brien has a quality assurance program meeting the requirements of 10 CFR 50 Appendix B, which requires that " Measures shall be established to assure that tools, gages, instruments, and other measuring and testing devices used in activities affecting quality are pre jerly controlled, calibrated and adjusted at specific periods to maintain accuracy within necessary limits". (7) NUREG 0588, Section 2.2, paragraph (3), Category I, states that IEEE 323-1974, Section 6.31s an acceptable guideline for establishing test procedures; IEEE 323-1974, Section 6.3.7 states that upon completion of type testing, the equipment should be visually inspected. The equipment visual inspection procedure is identified in Appendix A, steps 1.0 and 17.0 of the report. The report is unclear on the extent or degree of inspection; however, it can be inferred fron. the procedures outlined in the report that appropriate inspections were performed. (8) NUREG 0588, Section 2.2.1, paragraph (2), Category I, states that the choice of qualification methods is a matter of technical judgment and availability of test information to support conclusions reached. The miscellaneous connectors as purchased through the penetration vendor (D. G. O'Brien) are g utilized for applications inside and outside containment. The report is unclear with respect to applicable references or degree of qualification regarding these connectors. Upon cor.tacting DGO for clarification, it was stated that the miscellaneous connecccrs were qualified by similarity analysis to other tested units. The partial test data provided to support the analytical assumptions and conclusions reacned adequately demonstrates an acceptable qualification of the connectors. D. G. O'Brieu is being contacted to secure the analysis and supporting documentation used to qualify the connectors. (9) NUREG 0588, Section 2.2.1, paragraph (2), Category I, states that the choice of qualification methods is a matter of technical judgment and availability of text information to support conclusions reached. The triax connectors are utilized in modules of various instrument penetration assemblies. The report (ER-268) is not clear on the degree of qualification for the associated triax modules. The penetration vendor (DGO) has been contacted regarding the qual.'.fication status of the subject units and has stated that they are presently performing a qualification test program specifically for the referenced triax modules. A preliminary qualification report (D. G. O' Brian Report #ER-287) has been issued. Because of difficulties which arose during initial testing of the trisx connectors, this report is based upon a similarity analysis with other DGO components which have successfully completed the testing program. A complete testing program for the triax connectors is now underway and a report is expected to be to be issued later in 1981. When the text report has been formally issued and the B-134 Revision 3
DR-30 p) 4 results obtained, an evaluation will be performed to. validate the acceptable qualification of the subject connectors. (10) 1RALEG 0588, Section 1.3, Category I, states that the concentration of caustics used for qualification should be equivalent to, or more severe than : those used in the plant containment spray system. The necessary time duration and pH of the spray have been defined to be 2 hours with a pH of 9.5 for 65 minutes and a pH of 8.7 for the remaining 55 minutes. The report states that a spray concentration consisting of 4,000 ppe boron and 2,000 ppm NaOH had been used without specifying the precise pH of the spray. The report also shows an exposure to the spray of only 20 minutes. D. G. O'Brien is being requested to supply additional information in reference to this problem. (11) NUREG 0588, Section 2-1, paragraph 3(c), Category I, states that equipment that need not function in order to mitigate any accident and whose failure in any mode in any accident environment is not detrimental to plant safety need only be qualified for its non-accident service environment.---The basis should be provided for concluding that such equipment is not required to function in order to mitigate any accident, and that its failure in any mode ,I in any accident environment is not detrimental to plant safety. The penetration triaxial connectors are in this category of equipment. As described in item (9) above, qualification data for LOCA conditions is being developed for these connectors, however, as stated in paragraph 3-11.3.2-5, the excore neutron detectors are not required to function during a LOCA or f-~ MSB inside containment or during an MSB or SLB outside containment.
\m ,g/ Therefore, these connectors may fail when subjected to the extreme environmental conditions resulting from these design basis accidents.
(12) The items which are installed at the site have no model number imposed on the item and are, therefore, difficult to relate to the items in the report. Attempts are being made to provide this relation through the Virgil C. Summer site Q/C. Program and documenta labeled IMS-94B-653-1C and IMS-94B-610-IC. D. G. O'Brien is also being contacted to provide information to supplement ER 286 which uill document the link between the items installed and the modules tested. (18) NUREG 0588, Section 3, paragraph 4, Catsscry I, indicates that the 10% time margin identified in Section 6.3.1.5 of IEEE Standard 323-1974 should be used for equipment required for extended times after a design basis event. The LOCA test for the D. G. O'Brien penetrations and associated devices was limited to 15 days; however, the penetrations for power and control circuits may be cequired for up to one year, and the instrumentation Ocircuits required for up to 4 months following an LOCA. D. C. O'Brien is being asked for assistance in demonstrating the capability of the penetrations for the extended post accident period. O V B-134a Revision 3 .
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DR-31 Rockbestos Twinax Cable O (1) N1 MEG 0588, Section 2.2 paragraph (4), Category I, states when establishing the simulated environmental profile for qualifying equipment located inside containment, it is preferred that a single profile be used that envelopes the environmental conditions resulting from any design basis event during any mode of plant operation. The Rockbestos Qualification Report for Firewall III Coaxial Constructions provides a test profile which completely envelopes the most severe environmental conditions of any Design Basis Events with two exceptions. These exceptions have been reviewed and it has been determined that the test margin at the peaks more than compensates for the two exceptions. These exceptions only occurred because the testing was done in accordance to the LOCA profile for a PWR/BWR as specified in IEEE 323-1974 Figure A1. (2) NUREG 0588, Section 2.2 paragraph (6), Category I, states the temperature to which equipment is qualified, when exposed to the simulated accident environment, should be defined by thermocouple readings on or as close as practicable to the surface of the component being qualified. No evidence is given in the report that the thermocouple readings were taken during the test. The report does state, hcwever, definite te uperatures for the thermal aging test and the simulated accident environment test, and is judged acceptable. (3) NUREG 0588, Section 2.2 paragraph (104, Category I, states expected extremes in power supply voltage range and frequency should be applied during simulated event envimamental testing. No frequency extremes as suggested h in IEEE 323-1974 paragraph 6.3.1.5 (5) were applied. It has been evaluated that the subject cable can operate within the limits listed in IEEE Std. 323-1974 parsgraph 6.3.1.5 (5), and is considered adequate. (4) NUREG 0588, Section 4, paragraph (5) states that enown material pnase changen and reactions should be defined for the accelerated aging program, to insure that no known changes occur within the extrapolation limits. Rockbestos knew of no phase changes or reactions associated with the Twinax cable when they performed the accelerated aging tests and constructed the Arrhenius plots. Therefore, phase changes and reactions have not been addressed by the Qualification Report. O B-135 Revision 3
DR-32
. 8Kv Power Cable (1) NUREG 0588, Bection 2.2, paragraph (1), Category I, as well as IEEE 323-1974, Section 6.3.1.1, item (9), state that perfornance limits or failure criteria should be established prior.to testing. The Okonite Company did not specifically establish failure criteria before testing the cable. The results of these tests, however, indicate that the insulation maintained its functional integrity.throughout the LOCA test and the 100 day post accident simulation. Therefore, the lack of pre-established fail'are criteria is acceptable.
(2) NUREG 0588, Section 2.2, paragraph (3), Category I, states that IEEE
- 323-1974, Section 6.3 is an acceptable guideline for establishing test
. procedures. IEEE 323-1974, Section 6.3.1.1, item (3) requires that the test plan include mounting and connection cequiret. ants. There are no mounting .
and connection requirements in the qualification report. Although the !
. qualification report doesn't include mounting and connection requirements, the colling and beading of the cables at various stages of the complete testing cycle is described and is a more important element of the test than the' mounting and connection of the cables. Therefore, failure to include connection details is acceptable.
(3) NUREG 0588, Section 2.2, paragraph (3), Category I, states that IEEE 323-1974, Section 6.3 is an acceptable guideline for establishing test i procedures. IEEE 323-1974, Section 6.3.1.1 requires that a test plan be 4 prepared to provide an auditable link between the specifications and the O test results. A test plan is not included in the quclification report, but the results of the performed tests are included with the identification of the respective test. Therefore, the failure to include a specific test plan
~is acceptable.
(4) NUREG 0588, Section 2.2, paragraph (3), Category I, states that IEEE , 323-1974, Section 3 is an acceptable guideline for establishing test procedures. IEEE 323-1974, Section 6.3.1.4 states that the test equipment , shall be calibrated .against auditable calibration standards and shall have documentation to support such calibration. The only instrumentation ] identified in the qualification report whose calibration are traceable to the U.S. National Bureau of Standards are the radiation dosimetry meters used for radiation exposure testing of the cables. However, Okonite has a quality assurance program meeting the requirements of 10 CFR 50, Appendix B, which requires that, " measures shall be established to assure that tools, gages, instruments, and other measurir.g and testing devicen used in activities affecting quality are properly controlled, calibrated, and adjusted at specific periods to maintain accuracy within necessary limits." Thus, omission of this data does not invalidate the qualification. (5) NUREG 0588, Section 2.2, paragraph (3), Category I, states that IEEE 323-1974, Section 6.3 is an acceptable guideline for establishing test
. p rocedures. 'IEEE 323-1974, Section 6.3.1.4.1 states that moisture content an pressure should be measured variables. It was not clear from the qualification report what the environmental pressure and moisture content were at the test temperatures illustrated in the test chamber temperature 4
B-136 Revision 3 1 y-- r ,3 , - ,_
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1 DR-32 l profile associated with the LOCA environment simulation. Gilbert / @ Commonwealth sent a letter to the Okonite Company on August 12, 1980, requesting clarification on this subject. A response was received in a letter from the Okonite Company dated August 18, 1980, which stated that the pressures associated with the temperature profile are those of saturated steam at the temperatures indicated and exceed the maximum anticipated LOCA environment pressure. Therefore, the moisture content is also that of saturated steam at the indicated temperatures, and the qualification report is acceptable as supplemented by the Okonite letter. (6) NUREG 0588, Section 2.2, paragraph 10, Category I, as well as IEEE 323-1974, Section 6.3.1.5, item (5), states that equipment should be subjected to variations in the nominal frequency during testing. The range of frequency this cable is expected to experience is not more than 15% of 60 ifZ. Since variations of this insignificant degree have no effect on cable, testing at the nominal frequency of 60 HZ is adequate. (7) NUREG 0588, Section 2.2, paragraph (6), Category I, states that the LOCA test temperature should be defined by thermocouple readings on or as close as practical to the surface of the component being qualified. The qualification report does not state whether thermocouples were used or where they were located. However, the test chamger is not known to have any internal restrictions and the peak temperatures during the LOCA simulation are held for several hours. Consequently it is expected that the cables being tested attained the peak test temperature for the duration of the peak simulation. Therefore, the failure of the report to include specific information on temperature measurement instrumentation is acceptable. g (8) NUREG 0588, Section 4, paragraph (5), Category I, states that known material phase changes and reactions shoold be defined for the accelerated aging program to insure that no known changes occur within the extrapolation limits. Phase changes and reactions have not been addressed in the qualification report. Therefore, it is assumed that the Okonite Company knew of none when they perfonned the accelerated aging tests and constructed the Arrhenius plots. O B-137 Revision 3
DR-33 7 - ( Triax Cable L(1) NUREG 0588, Section 2.2, paragraph (1), Category I, as well as IEEE 323-1974, Section 6.3.1.1, item (9), states that performance limits or failure criteria should be established prior to testing. BIW did not specifically establish failure criteria before testing the cable. However, the qualification report states that type test specimens of similar cable withstood voltage tests after being' subjected to simulated normal , environmental conditions. In addition, the type test specimens withstood voltage tests also after being conditioned for normal environmental conditions and then subjected to a LOCA design basis event during which the triaxial cable is not required to function. Therefore, lack of criteria in the test plant is acceptable. (2) NUREG 0588, Section 2.2, paragraph (3),, Category I, states that IEEE 323-1974, Section 6.3 is an acceptable guideline for establishing test procedures. IEEE 323-1974, Section 6.~3.1.1 : quires that a test plan be prepared to provide an auditable link between the specifications and the test results. A test plan is not included in the qualification report, but the results of the tests performed are included with the identification of the respective test. Therefore, the failure of the qualification documentation _to include a test plan is acceptable. (3) NUREG 0588, Section 2.2, paragraph (3), Category I, states that IEEE 323-1974, Section 3 is an acceptable guideline for establishing test procedures. IEEE 323-1974, Section 6.3.1.4 states that the test equipment shall be calibrated against auditable calibration standards and shall have documentation to support such calibration. The test reports include
- descriptions of the performed tests and the results of measured test parameters but instrumentation calibration data is not included. However, BIW has a quality assurance program meeting the requirements of 10CFR50, Appendix B, which requires that " Measures shall be established to assure that tools, gages, instruments and other measuring and testing devices used in activities affecting quality are properly controlled, calibrated, and adjusted at specific periods to maintain accuracy within necessary limits.
(4) NUREG 0588, Section 2.2, paragraph (6), Category I, states that the temperature to which the equipment is qualified when exposed to simulated accident environment, should be defined by thermocouple reading on or as close as practical to the surface of the component being qualified. The qualification report neither says how the temperature was measured nor where it was measured. However, all the tests were performed per IEEE 323-1974, Appendix A and IEEE 383-1974 and the cable maintained its functional integrity during the testing. Therefore, the lack of above documentation in the qualification report is acceptable. (5) NUREG 0588, Section 2.2, paragraph (5), Category I, states that equipment which is subjected to potential flooding should be identified and qualified for the duration required. It has been determined that some of the conduits
' outside of the reactor building through which the triaxial cable pass are subject to becoming filled with water. Tne cable used outside of containment has a double outer jacket of Bostrad 7 CSPE chlorosulfonated O
B-138 . Revision 3
DR-33 polyethylene (hypalon). The cable was type tested for water submerged application, and th" jacket material has been tested for resistance to water absorption and found satisfactory per BIW 1etters dated 10-13-80 and 12-19-80. (6) NUREG 0588, Section 2.3 paragraph (1), Category I, states that the test procedures should insure that the same piece of equipment is used throughout the test sequence. Since the triaxial cable from BIW has two different outer jacket materials, more than one type of cable had to be tested for environmental qualification. BIW test report 75B005-05 is for a triaxial cable with crosslinked polyethylene insulating material and an outer jacket of Bostrod 7 CSPE chlorosulfonated polyethylene (hypalon) which are the same insulating and jacket materials as one of the two BIW triaxial cables to be used in the Virgil C. Summer Nuclear Station. BIW test report 74G022B is for a triaxial and Tefzel ETFE for the outer jacket material to qualify Tefzel ETFE as on outer jacket material. Therefore, qualification type tests of similar cables have been analyzed to determine the qualification of the cablas to be used in the Virgil C. Summer Nuclear Station. (7) NUREG 0588, Section 4, paragraph (5), Category I, states that known material phase changes and reacticas should be defined for the accelerated aging program, to insure that no krown changes occur within the extrapolation limits. Boston Insulated Wre & Cable Co. knew of no phase changes or reactions associated with triax cables when they performed the accelerated aging tests and constructed the Arrhenius plots. Therefore, phase changes and reactions have not been addressed by the qualification report. (8) NUREG 0588, Section 4, paragraph 9, Category I, states that the qualified O life of the equipment and the basis for its selection should be defined. While the qualification report does net include the following: a) the basis of 40 years qualified life for Tefzel insulated cable and; b) the test data by which the slope of 40 yrs. Life time has been plotted for crosslinked polyethylene insulation cable, the necessary information is contained in BIW's letter to CAI dated 12-19-80 and thereby supports the 40 year qualified life. (9) NUREG 0588, Section 2.1, paragraph (3)(c), Category I, states that equipsent that need not function in order to mitigate any accident and whose failure in any mode in any accident environment is not detrimental to plant safety need be qualified only for its non-accident service environment. The basis should be provided for concluding that such equipment is not required to function in order to mitigate any accident and that its failure in any mode in any accident environment is not detrimental to plant safety. The triaxial cable is in this category of equipment. Qualification data for LOCA conditions exists for this cable, however, as stated in FSAR Section 3.11.3.2, Item 5. This cable serves the excore neutrca detactors and is not required to function during a LOCA or main steam line break (MSB) inside containment or during a ':SB or small line break (SLB) outside containment. Therefore, the triaxial cable may fail when subjected to the extreme environmental conditions resulting from these design basis accidents. d' O B-139 Revision 3 .
i l DR-34 im (,) MCC's j (1) NUREG 0588, Section 2.1, paragraph 3(c), Category I, states that although actual testing of a complete equipment unit is preferred, other methods when justified may be found acceptable. The components of the motor control center (MCC) were analyzed per IEEE Standard 323-1974 on an individual component basis. It is considered more appropriate to analyze individual components of an MCC for qualification than to test a complete MCC. The qualified life of the MCC is 40 years when specific components with shorter qualified lives are replaced in accordance with a maintenance schedule. Some specific components with a qualified life of shorter than 40 years may be requalified to have a longer life if it is determined that the operating conditions are less severe than the qualification conditions. (2) NUREG 0588, Section 2.2, paragraph 3, Category I, staces that IEEE 323-1974, Section 6.3, is an acceptable guideline for establishing test procedures; IEEE 323-1974, Section 6.3.1.1, item (7), states that the test equipment requirements, including accuracies, should be included in a test plan. Similarly, Section 6.3.1.4, states t'.at environmental and electrical variables should be monitored using test equipment whose calibration can be traced to auditable calibration staadards. In addition, NUREG 0588, Section 5, item (2), Category I, states that the guidelines for documentation in IEEE 323-1974 (which is Section 8) are acceptable when fully implemented; IEEE 323-1974, Section 8.3, iteu (4)(c), states that a description of the test facility and instrumeatation used, including calibration records reference, should be doctmented in the ' report. The (] report does not include complete details on test equipment, accuracies or calibration, and sometimes merely references or summarizes tests in support of qualification by analysis. More complete and detailed information on test equipment, accuracies, and calibration can be found in the referenced test reports and test fscility files. (3) NUREG 0588, Section 2.2, paragraph 10, Category I, as well as IEEE 323-1974, Section 6.3.1.5, item (5) states that the equipment should be subjected to variations in the nominal frequency during testing. The postulated maximum range of frequency excursions is stated in the qualification documentation as 1 5% in agreement with IEEE 323-1974. Although the frequency extremes were not applied to MCC components during testing, it is considered the results are valid since we know of no components that are particularly sensitive to frequency variations. (4) NUREG 0588, Section 2.4, Category I, states that qualification by analysis or operating experience shall be acceptable if implemented in accordance with IEEE 323-1974. Section 6.4.2 of IEEE 323-1974 requires that the documentation shall not include physical locations and mounting arrangements of the equipment in the operating facilities, as well as a maintenance log and analysis of all failures. Square D used operating experience as the basis for the qualification of certain components, but in some cases has not provided specific and detailed information as required by IEEE 323-1974. However, the operating experience covers many years, and a large populatioa of similar components, used at many varied locations and environments. Furthermore, Square D has used the operating experience approach for C d B-140 Revision 3
DR-34 analysis of passive devices (bus bars, terminal blocks and fuses) where failures are unusual. The radiation environment of the Virgil C. Summer Plant is not included within the Square D operating experience; however, radiation affects were analyzed using published material property data. In conclusion, Square D has taken a conservative approach in estimating qualified life based on operating experience data; therefore, we find using general operating experience data by Square D is acceptable. (5) NUREG 0588, Section 3, paragraph 2 Category I, states that IEEE 323-1974, Section 6.3.1.5 is an acceptable guideline for establishing margins. IEEE 323-1974 Section 6.3.1.5 subparagraph (4) requires that voltage margin of at least i 10% shall be used. The SQD electriril endurance tests for certain size contractors and starters were conduc ' at greater margins of
+ 19.8% (575V), or - 13.5% (415V) for other size _ actors and starters.
Since all the contactors and starters are similari, constructed using , similar materials, it is not considered necessary to test each contactor or starter at the plus and minus voltage margin. As the contactor and starter construction, and material of construction are similar, we find the test is applicable to, and satisfies the requirements. Fuses, fuse holders, indicating lights, terminal blocks, and control transformers were not exposed to voltage margins during testing, but we know that they should not be sensitive to the limits specified in IEEE 323-1974. (6) NUREG 0583, Section 4, paragraph 2, Category I and IEEE 323-1974 paragraph 6.3.3 require that the aging effects of cyclic operatior be considerdd in the equipment qualification program. The circuit breakers supplied with the motor control centers have 5een type tested according to UL Standard 489 which includes endurance operational testing (load and lll no-load), overload operational testing, and short-circuit operational testing. The UL Standard 489 overload tast consists of 50 close/open operations at 600% rated curreat, but not less than 150 amps, which is 1000% in the case of a 15 amp breaker. While the test does not directly correspond to the anticipated service condition of 25 overload operations per year at 200% overload, we feel that this service condition is unrealistic compared to actual operational conditions because:
- 1) Overload currents to motor feeder circuits are normally interrupted by the motor starter or other protective device--not the circuit breaker.
- 2) Motor inrush current is handled by the starter--not the circuit breaker.
i Some branch circuits are solely protected by circuit breakers, where the l connected equipment cannot impose an overload on the supply (e.g., resistance heaters). In practice, the circuit breaker functions as a disconnett device (no load operation), and for interrupting fault currents. The qualification report adequately addresses both functions and requires breaker replacement after fault current interruption. Therefore, we feel i the effects of operational aging have been adequately addressed. O B-141 Revision 3 .
4 DR-34 ( (7) NUREG 0588, Section 4, paragraph 4, Category I, states that the Arrhenius methodology _ is considere 1 su acceptable method of addressing accelerated aging. Other methods that can be supported by; type tests will be evaluated on a case-by case basis. The following are justifications for aging methods used other than the Arrhenius methodology. Circuit Breakers The Nuclear Safety Information Center (NSIC) performed a retrospective search of the NSIC computer file for circuit breaker failures. A total of 177 citations were noted with none attributed to failures due to thermal aging processes. An estimation of circuit breaker mean life was made based on reliability calculations using the exponential model with statistical f data on breaker field experience. The estimated mean life of breakers was the shortest when calculated using figures for the first year of age. The results indicated breaker mean life is well over 40 years. Use of the-Arrhenius Reaction Rate equation necessitates knowledge of the activiation energy for the thermal aging process. Regrettably, activation energy data is not readily available for mest insulating materials. Another method which may be employed to calculate the thermal life of inculation is to employ the 10*C rule of thumb which states that reaction . rates double with every 10' rise in temperature and conversely, the rates halve with every 10*C drop in temperature. The thermal life of the insulation material will be shortened or extended accordingly. Use of the 10' rule gives results similar to the Arrhenius Reaction Rate equation when the aging process has an activation energy of 19,000 calories / mole. Phenolic resin used in phenolic molding compounds, a common plastic in circuit breakers, has an activation energy of 18,000 calories / mole. Therefore, the use of the 10d rule of thumb would appear to be a reasonable method for projecting circuit breaker insulation thermal life. The circuit breaker organic insulation materials were tested per the Underwriter's Laboratories Inc. test method UL746B " Polymeric Materials -Long Terms Property Evaluations" to . determine the thermal life of the insulation. The Square D qualification [ report concludes that the qualified thermal life of the circuit breakers used as branch feeders is 15 years at the maximum anticipated conditions. Motor Starters and Pelays The thermal life of Class IE motor starters and relays is based on a review of the thermal aging of the insulation materials. Underwriters' Laboratories (UL) continually evaluates the long-term properties of electrical insulation materials. 'Jsing the procedures of UL-746B, the generic temperature indexes have been established and published in the UL Recognized Component Index. Temperature indexes are assigned by UL at an extrapolated life of 11 years. Square D motor statters and relays are UL listed in accordance with UL-508. At the anticipated environmental E conditions and applied equipment rating, the starter and relay insulation mite rials will operate at temperatures below their temperature indices. 1 Thus, the operation results in an insignificant amount of change in the i material properties during 10 years of service due to thermal aging effects. Therefore, Square D' concludes that the Qualified Life of the motor starters and relays is 10 years with respect to thermal aging.
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l DR-34 Starter Coils Since coil t'aermal life is directly related to time and temperature, accelerated thermal aging tests were performed. The test data was plotted in accordance with chemical reaction rate theory based on the work of Arrhenius. The slope of the curves vary slightly for each type of coil, but correlate with the approximate "10*C rule" for insulation deterioration which states that the life of insulation is reduced one-half for each 10*C rise in temperature. The results of the tests lead Square D to recommend that coils of NEMA Size 1 starters be replaced after 8 years of service and coils of NEMA Size 2, 3, and 4 starters be replaced after 10 years of se rvice. Class 8501 Type H-Control Relay Coils The same procedure and combination of service conditions for motor starters were used to estimate the thermal life of relay coils. Although the estimated thermal life of the coils is 47.5 years at the maximum tamperature rise of 58'C under qualification conditions. Square D recommends that they be replaced after 10 years of service. Control Transformers Square D takes the position that no industry accepted thermal accelerated aging technique as yet exists which can be applied to control transformers and yield valid results to predict service life. Therefore, the effects of g thermal aging on the qualification of control transformers for Class IE w service is based on an insulation material review. Type EO transformers are UL Recognized Components which meet UL 506 " Specialty Transformers" requirements. Temperature rise tests were performed on sample open type transformers at 75% of rated load with the primary voltage at 90, 100 and 105% of rated voltage. The coil temperature rises at 100% voltage were used for thermal life calculations since they best represent the average conditions during the service life. All of the materials used in the primary insulation system ahve temperature ratings of 130' or more. Electrical insulatior, materials used for transformers are tested and rated per IEEE standards 1-1969, 98-1972, 99-1970, and 117-1974. Based on IEEE evaluation procedures, insulation material operating continuously at its rated temperature reaches its half-life at 20,000 to 40,000 hours. Using a service temperature of 100*C in the 10'C rule equation to calculate the estimated thermal life, and considering the presence of unknown variables which influence the overall thermal life, Square D concludes that the control transformers have a Qualified Life with respect to thermal aging of at least 15 years. Bus Bars All bus bars are copper alloy, tin plated and have conductivity values of 98% minimum. The anticipated continuous current load for each is below the design rating, thus reducing the thermal aging effects. Based on this application and past operating experience, Square D concludes that the bus bar material will exhibit an insignificant amount of degradation for at least 40 years. B-143 Revision 3
DR-34 (_/ Bus Insulators All bus supports, bus bracing, and unit assembly insulators are made of a polyester molding compound and has a UL Temperature rating of 130'C. Using a maximum design temperature of 90*C and the 10* rule associated with the Arrhenius theory, the Qualified Life of the insulators is calculated to be at least 40 years. Terminal Blocks and Terminal Lugs The thermal aging effects due to ambient temperature and current load are considered to be negligible and insignificant on terminal blocks and terminal lugs. This is based on the low level of current which will be passing through the control circuits. Although there is not an exact method available for detenmining the Qualified Life of these conponents, Square D bases its qualification on the low level of currents which are anticipated and past operating experience which indicates no significant problem oreas. Therefore, Square D concludes that these components would be qualified with respect to thermal aging for at least 40 years. Control Circuit Fuses Although there is no direct method or theory on which to base a Qualified Life for fuses, the manufacturer, Bussman, has stated that under normal service conditions this type of fuse "cannot deterinrate with age, nor can its rating change." Although this statement would indicate an unbounded (,,s) life expectancy, Square D is aware of the importance of assurance of proper operation of the Class IE equipment. Af ter the manufacturer was informed of the specific application, it was concluded that the fuses would not be affected by thermal aging for at least 10 years under specified operating conditions. Therefore, Square D recommends that the control circuit fuses be replaced every 10 years. Wiring General Electric hes not subjected the SIS wire (SI57275) which will be supplied for the Class IE motor control centers, to a complete qualification program per IEEE Standard 323-1974. However, they have conducted some tests on their SIS FR-1 wire which provided sufficient data to formulate an an Arrhenius curve that relates the life expectancy of the wire with a continuous operating tem 7erature. From information avsilable from General Electric, the Square D qualification report concludes that the SIS FR-1 (SI57277) has a qualified life of at least 40 years. The SIS wire (SI57275) is similar to the SIS FR-1 wire but no specific Arrhenius type data is presently available to confirm a life expectancy. General Electric has indicated this data will be available in the near future from testing now in progress. However, data is available from testing per Underwriters' Laboratories Inc., Standard for Safety, " Rubber-Insulated Wires and Cables," UL44 for the SIS wire (SI57275). Assuming this wire (SI57275) has similar properties as the SIS FR-1, and Arrhenius relationship can be used to approximate its thermal life. Using conservatism in the thermal life calculation and allowing for additional unknown variables, the Square D l (~) V l B-144 Revision 3 l
i DR-34 qualification report concludes that the thermal life of the SIS wire (SI57275) is at least 15 years. It is anticipated that this thermal life will be extended to at least 40 yerrs when the thermal aging test is completed and the results are evaluated. Cyprus has not subjected their Hypalon Appliance and Motor Lead Wire to a complete qualification program in accordance with IEEE Standard 383-1974. However, they have conducted two test programs on cables with hypalon jackets. The Hypalon compounds tested are similar in chemical formulation to those used in the Appliance and Motor Lead Wire. Although there is no specific Arrhenius data available for this particular wire, it is reasonable to assume it to be similar to Anaconda cable which also has a hypalon type jacket and for which complete Arrhenius data is available. Using additional margin and allowing for additional unknown variables, the Square D qualification report concludes that the thermal life of the Cyprus Hypalon Appliance and Motor Lead Wire is at least 15 years. (8) NUREG 0588, Section 4, paragraph 5, Category I, requires that known material phase changes be defined. The MCC qualification report does not address phase changes. However, the design environment does not include unusual extremes of temperature or pressure (i.e. it is a normal, non-accident environment). This is a basically standard line of equipment, having standard components, that will be operating in an environment which is ccnsidered by industry as normal. It is reasonable to assume that any unacceptable material phase changes which occur under normal environmental conditions will have been detected and eliminated during the development and early operating years of this established proauct line. Radiation is the g only unusual aspect of the environment and the report demonstrates that all W components and materials will not suffer damage or unacceptable change of properties when subjected to tbc postulated 40 year total integrated radiation dose. Therefore, we conclude that material phase changes are not an aging factor for this equipment. (9) NUREG 0588, Section 2.1, paragraph 3(c), Category I, states that equipment that need not function in order to mitigate any accident and whose failure in any mode in any accident environment is not detrimental to plant safety need only be qualified for its non-accident service environment. The basis should be provided for concluding that such equipment is not required to function in order to mitigate any accident and that its failure in any mode in any accident environment is not detrimental to plant safety. Motor Control Center XMCIDA2Y, located at elevation 412'-0" in the auxiliary building, is in this category of equipment. Motor Control Center XMCIDA2Y is subject to the environmental effects which result from some postulated small line breaks. None of the postulated small line breaks that can adversely affect this Train "A" control center will cause a plant trip or result in protection system action, similiarly the breaks can adversely affect auxiliaries for the train "C" charging / safety injection pump. However, none of these breaks will disable any of the train "B" equipment required for plant shutdown, therefore, so long as the train "C" charging / safety injection pump is not being used for train "B" while the train "B" is-taken out of service, the capability for plant shutdown is maintained. in this unlikely event, the train "B" pump could be returned to Oll B-145 Revision 3
DR-34 (,) service or the hydro test pump could be used for required make-up for cold shutdown. Appendix B to Branch Technical Position APCSB 3-1, in paragraph 11.(b) states that " environmentally induced failures caused by a leak or rupture of the pipe which would not of itself result in protective action but does disable protective functions. In this regard, a loss of redundancy is permitted, but a loss of function is not permitted. For such situations plant shutdown is required." Since Motor Control , Center XMCIDA2Y is not required to mitigate the consequences of any of the postulated line breaks, and since no protective action will result, the criteria given above permits a loss of redundancy, so long as function is maintained. Since the train "B" shutdown equipment will remain operable, function is maintained. Therefore, XMCIDA2Y is not required to function in order to mitigr.te any of the postulated line breaks and its failure in any mode is not detrimental to plant safety. (10) NUREG 0588, Section 3, paragraph 2, Category I states that IEEE 323-1974, section 6.3.1.5 is an acceptable guideline for establishing margins. All motor control center equipment except size #1 starters has been qualified for at least 10 yrs. at 35*C. Average temperature at the XMCIDA2Y location will be less than 27'C so that temperature margin for avg. conditions will be 8'C. Margin is not addressed for extreme conditions at XMCIDA2Y. (11) NUREG 0588, Section 2.2, Category I, paragraph 12 states that Cobalt 60 is an acceptable source of radiation used for environmental aging. The SQD qualification report 108-1.02-L1 and GAI Report 2138 has stated that the materials used in device construction have been analyzed per data supplied by industrially accepted reference books. When analyzed this material has t] been found to be acceptable for its intended use of its location. B-146 Revision 3
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DR-39 Service Water Booster Pump Motors (1) NUREG 0588, Section 1.4, Category I, states that the radiation environment for qualification of equipment should be based on the normally expected radiation environment over the equipment's qualified life, plus that associated with the most severe design basis accident (DBA), during which the equipment must remain functional. Louis Allis Co. was not originally required to s gply motors for other than background radiation gnvironments. Ilowever, recent investigation has revealed that a dosage of 10 rads may be encountered over the life of the plant. Qualification to this level of radiation exposure is being pursued. (2) NUREG 0588, Section 2.1, paragraph 3(c), Category I, states equipment that need not function in order to mitigate any accident and whose failure in any mode in any accident environment is not detrimental to plant safety need only be qualified for its non-accident service condition. Service Water Booster Pumps fall into this category in that the Design Basis Accidents to which these components are exposed (Main Steam Line Breaks-outside containment) are accidents which do not require operation of these motors, with one exception. This exception is that a Small Line Break occurrir.g concurrently with a Loss of Offsite Power would still require Reactor Bldg. Atmospheric Cooling in order to pren nt the building temperature from exceeding the equipment qualification limit. Although Reactor Building Atmospheric Cooling is still neccessary and the normal means for providing this cooling upon Loss of Offsite Power is by these pumps. The required cooling can be obtained by energizing the XCI-1B-C1 Industrial Cooler from the diesel generator "A" (Tag #XEG 0001A) via the XSWIDA-ES, XSW1DAl-ES and XSW1111-ES buses. (3) NUREG 0588, Section 2.4, Category I, states qualification by analysis or operating experience implemented as directed in IEEE Std. 323-1974 and other ancillary standards may be found acceptable. The adequacy of these methods will be evaluated on the basis of the quality and detail of information submitted in support of the assumptions made. The subject report states that " Louis Allis Co. used as its base criteria a test on a Class A insulation system." The report then goes on to compare Class A inaulation properties with those of Class F (uoed in this motor) and states "The thermal endurance qualification is based on relating the expected time-temperature exposure of the motor to an equivalent time at rated temperature of the insulation system. The insulation properties in the report show the Class F insulation good for 27,065 hours at 155 C; however, no detailed information is supplied in support of this analysis. This information is being sought at this time to support the assumptions made. (4) NUREG 0588, Section 3, Paragraph (2), Category I states in lieu of other proposed margins that may be found acceptable, the suggested values indicated in IEEE Std. 323-1974, Section 6.3.1.5 should be used as a guide. In the case of Maximum and Average Temperatures, the equipment qualification did not allow the +15*F margin stated in the 323-1974 Std. However, because , the equipment is calculated to run for the equivalent of 1099 hours at l design temperature, but is capable of running for 27,065 hrs. there is more than enough margin in time to make up for the neglect of margin in temperature. h B-158 Revision 3
DR-39 l
~h (5) NUREG 0588, Section 2.2, Paragraph-(10), Category I, states expected extremes in power supply voltage range and frequency should be applied
.during simulated event environmental testing. The motors were specified in accordance with NEMA Std. MG-1 which requires that they be operational within 110% of the rated voltage and '5% of the rated frequency.
, Documentation of conformance to this NEMA Std. is being requested, and because the service water booster pumps are not expected to experience voltage and frequency values beyond the NEMA Std. extremes, design to this
. standard is acceptable.~ :
(6) NUREG 0588, Secton 2.2, Paragraph (7), Category I,' states performance characteristics sh9 uld be verified before, after, and periodically during , testing throughout its range of required operability. Although this section of NUREG 0588 applies to type testing and only partial-type testing was performed on the insulation system the intent of this paragraph should still be imposed. There is no evidence in the qualification report that performance characteristics were checked. Neither is there any evidence of equipment operability monitoring throughout the test as specified in NUREG 0588, Section 2.2, Paragraph 9. The report does state that the insulation system used in this motor is qualified in accordance with IEEE 117. A description of the test methods used in accordance with
- IEEE 117 and the supporting data.has been requested from the Louis Allis Co.
(7) NUREG 0588, Section 4, Paragraph (5), Category I, states that known material
- j. phase changes and reactions should be defined for the accelerated aging ,
program, to insure that no known changes occur within the extrapolation limits._ Louis Allis Co. knew of no phase changes or reactions associated with the motor insulation when they performed the accelerated aging tests. 3 Therefore, phase changes and reactions have not been addressed by the i qualification report. (8) NUREG 0588, Section 5, Paragraph (2), Category I, states the guidelines for
- documentation in IEEE Std. 323-1974 when fully implemented are acceptable;
} IEEE Std.'323-1974 Section 8.3 Item 4 (h) and Section 8.5 Item (?) state
- that a qualification report should include an approved siglature and date.
The report itself does not include any approval signatures or dates. It was, however, transmitted with a signed transmittal letter. Therefore, the i reports' failure to include an approval signature does not detract from its validity. (9) NUREG 0588, Sectier 2.2, Paragraph (6), Category I, states that the simulated accident temperature should be defined by thermocouples on or near the surface of the component being qualified. There is no evidence of the ' ! use of-thermocouples in the Louis Allis Test Report; however, the s-rvice
- . water booster pump motors, being category C2 equipment, need only be qualified for the normal nonaccident environment. Use of the resistance method to measure temperature during the normal service qualification tests l (pages 4A and 4B of test data furnished at time of shipment) does not
- detract from the validity of the qualification.
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r DR-40 Emergency Feedwater Pump Motor (1) NUREG 0588, Section 2.1, paragraph (2), Category I, states that qualification by analysis is acceptable if (a) testing of the component is impractical due to size limitations, and (b) partial type test data is provided to support the analytical assumptions and conclusion reached. The qualification for the General Electric emergency feedwater pump motors meets the criteria of (a) and (b) above and therefore is acceptable. (2) NUREG 0588, Section 2.2, paragraph (10), Category I, states that the expected extremes in power supply voltage range and frequency should be applied during simulated event environmental testing. General Electric did not subject the prototype motors to the expected extremes of voltage and frequency. However, the motors were specified and designed to be in accordance with NEMA Standard MG1 which requires motors to be operational within 110% of rated voltage and 15% of rated frequency. The emergency feedwater pump motors are not expected to experience voltage and frequency values beyond their design extremes, therefore, testing at nominal voltage and frequency is acceptable. (3) NUREG 0588, Section 2.4, Category I, states that qualification by analysis or operating experience implemented as described in IEEE Standard 323-1974 and other ancilliary standards, may be found acceptable. IEEE Standard 323 paragraph 6.4.3 states that, "for equipment whose operational history becomes a basis for qualification, the operating environment must equal or exceed the design environment in severity." Although test data is used on operating experience to demonstrate qualification of the rotor, bearings, and shield, and general construction, no data is given in the Qualification lll Documentation to the types of environments into which similar motors have been installed. However, the documentation notes that a total of 15,106 such motors were shipped by General Electric from 1961 through 1966. Since the service conditions for the Emergency Feed Water Pump Motors are mild when compared with typical industrial conditions, it can be assumed that some of the 15,106 motors identified in the report are intalled under more severe conditions. Temperature and Pressure extremes are exceptions to the statement above, however, temperature is acceptable by analysis. The pressure extreme is beyond the qualified level of continuing operation. There is an increase from atmospheric pressure to 2.3 psig or 15%. Since these motors have a totally enclosed fan cooled enclosure and a sealed Class "F" insulation, the windings will not experience any effects from a 15% ambient pressure increase. Therefore, the qualification is acceptable. (4) NUREG 0588, Section 5, paragraph 2, Category I, states that the guidelines for documentation in IEEE Std. 323-1974 when fully implemented are acceptable; IEEE 323-1974, Section 8.3, item (4), (h), Section 8.4, item (8), and Section 8.3, item (7), states that the qualification report should include an approval signature and date. The report does not include any approval signature; however, the report was written specifically for the motors on the Virgil C. ummer job and was forwarded to GAI from GE with a signed transmittal lettc . Therefore, the report's failure to include an approval signature does not detract from the validity of the qualification. O B-160 Revision 3 .
DR-40 y.- , k (5) NUREG 0588, Section 4, paragraph (5), Category I, states that known material phase changes and reactions should be defined for the accelerated aging program, to insur6 than no known changes occur within the extrapolation limits. General Electric knew of no phase changes or reactions tssociated with the motor insulatiota system when they performed the accelerated aging tests and constructed the Arrhenius plots. Therefore, phase changes and reactions have not been addressed by the qualification report. (6) NUREG 0588, Section 4, paragraph (6), Category I, states that "The aging acceleration rate used during qualification testing and the basis upon which the rate was established should be described and justified." The tests were cop'.ucted in accordann with AIEE #51 (the predecesser of IEEE #275) and the Jaca analyzed and reported in accordance with AIEE #1F (the predecessor of IEEE (#101). Justification of the aging rate is based upon the fact that the above-listed standards were the industry accepted standards for testing and analyzation at the time the tests were performed. (7) NUREG 0588, Section 4, paragraph (2), Category I, states that the degraded influences discussed in Sections 6.3.3, 6.3.4, and 6.3.5 of IEEE Standard 323-1974 and the electrical and mechanical stresses associated with cyclic operation of equipment should be considered and included as part of the aging program. All necessary influences with the exception of radiation exposure were applied as part of the aging program. The riualification documentation includes a review of the radiation tolerar of the materials used in the motor. This review indicated no detectable , mage to any of the materia}s for radiation exposures several orders of magnatude higher than O the <10 rads to which these motors may be exposed. Therefore, qualification based on testing of a motor which was unirradiated is acceptable. O B-161 Revision 3 a
DR-41 Reactor Building Spray Pump Motors h (1) NUREG 0588, Section 1.4, Category I, states that the radiation environment for qualification of equipment should be based on the normally e::pected radiation environment over the equipment qualified life, plus that associated with the most severe design basis accident (DBA) during which that equipment must remain functional, and an additional 20% radiation margin as per IEEE Std. Section 6.3.1.5. When the equipment was ordered, it was believed 1323-197g,RadTotalintegrateddose(TID) x 10 qualificagionwassufficient;however,investigationshowsthataTIDof 9.12 x 10 Rads over the 40 year life followed by the DBA - LOCA is the most severe design condition for which these motors must remain 6functi nal. Although the equipment qualification report gives 1.0 x 10 Rads TID as the radiation qualification, a subsequent letter dated October 14, 1980, from E.7F . Harrison of the motor manufacturer justified the use of 1.01 x 10 Rads for the qualification value. (2) NUREG 0588, Section 2.2, paragraph (10), Category I, states that expected extremes in power supply voltage range and frequency should be applied during simulated event environmental testing. General Electric did not subject the prototype motors to the expected extremes of voltage and frequency. However, the motors were specified and designed in accordance with NEMA Std. MG-1 rhich requirer that they be operational within i 10% of rated voltage and i 5% of rated frequency. The spray pumps are not expected to experience voltage and frequency variations beyond their design extremes; therefore, testing at nominal voltage and frequency is acceptable. (3) NUREG 0588, Section 2.1, paragraph 3 (c), Category I, states that equipment O that need not function in order to mitigate any accident, and whose failure in any mode, in any accident environment is not detrimental to plant safety, need only be qualified for its non-accident service environment. Although actual type testing is preferred, other methods when justified may be acceptable. The basis s.1ould be provided for concluding that such equipment is not required to function in order to mitigate any accident, and that its failure in any mode or accident environment is not detrimental to plant safety. Reactor Building Spray Pump Motors fall into the not required to operate category, in that the Design Basis Accidents to which these components are exposed (Small Line Breaks) do not require operation of these motors. The accidents for which the operation of the motors is necessary are the Loss of Coolant Accident (LOCA) and Main Steam Line Breaks (MSB) inside containment. Diaring a LOCA or MSB the temperature and pressure to which the motore are subject does not vary significantly from the normal environment. (4) NUREG 0588, Section 2.4, Category I, states that qualification by analysis or operating experience implemented, as described in IEEE Std. 323-1974 and othar ancillary standards, may be found acceptable. IEEE Std. 323-1974, paragraph 6.4.3 states that: for equipment whose operational history becomes a basis for qualification, the operating environment must equal or exceed the design environment in severity. J.1.though test data is used for the qualification of the insulation system, General Electric has relied on operating experience to demonstrate qualification of the rotor, bearings, O B-162 Revision 3
DR-41 end shield, and general" construction. No_ data is given in the Qualification Documentation to the types of environments into which sinilar motors have been installed. However, GE's operating experience documents that 15,106 such a tors were shipped by G.E. from 1961 through 1966. Since the service conditions for the. reactor building spray pump motors are niid when compared u with typical industrial' conditions, it can be assumed that some of the ' 15,106 motors identified in the report are installed under more severe-conditions. Radiation exposure is an exception to the statement above and > qualification data has been obtained as stated in (1) above. ; (5) NUREG 0588, See ton 2.4, Category I, states that qualification by analysis
-or operating expecience implemented, as described in IEEE Std. 323-1974 and other ancillary ste dards may be found acceptable. IEEE Std. 323-1974 paragraph 6.4.3 states that for equipment to be qualified by operating history, it should be noted that if design environment includes seismic accelerations followed by a design basis event environment that is more ,
severe than the recorded in service environment, then the installed ' equipment must, in general, be removed from service and subjected to a ;
- partial type test to include the seismic and design basis event effects !
before the equipment can be considered fully qualified. The Reactor ' , Building Spray Pumps are qualified for operation after or during a seismic
- event. Summary of this qualification is given in G. E. Report NE-400
" Seismic-Stress Analysis of Horizontal Motor." Qualification to the Design Basis Event is not necessary in that, as stated in (3) above, the Design Basis Events to which these motors are exposed are events which do not require their operation.
(6) NUREG 0588, Section 4, paragraph (5) states that known material phase changes and reactions should be defined for the accelerated aging program, to insure that no known changes occur within the extrapolation limits. ; General Electric knew of no phase changes or reactions associated with the motor insulation when they performed the accelerated aging tests and constructed the Arrhenius plots. Therefore, phase changes and reactions have not been addressed by the qualification report. (7) NUREG 0588, Section 4, paragraph (2), Category I, states that the degraded influences discussed in Sections 6.3.3, 6.3.4, and 6.3.5 of IEEE Std. 323-1974 and the electrical and mechanical stresses associated with cyclic operation of equipment should be considered and included as part of
- the aging prograia. All necessary influences with the exception of radiation exposure were applied as part of the aging program. Radiation exposure '
qualification was justified in the qualification report and GE letter dated , October 14, 1980, by analysis. Thisan9ysisshowsallcomponentsofthe 1 motor to be good for at least 1.01 x 10 RADS as stated in the rubject letter. This analysis is, therefore, acceptable in lieu of radiation . exposure aging. (8) NUREG 0588, Section 4, paragraph (6), Category I, states that the aging acceleration' rate used during qualification testing and the basis upon which the rate was established should be described and justified. The tests were conducted in accordance with AIEE #511 (the predecessor of IEEE #275) and the data analyzed and reported in accordance with AIEE #1F (the predeceuor F O B-163 i l- Revision 3
- . _ _ - _ . . _ . - _ - . _. . ~
DR-41 of IEEE #101). Justification of the aging rate is based upon the fact that the above-listed standards were the industry accepted standards for testing and analyzation at the time the tests were performed. (9) NUREG 0588, Section 5, paragraph 2 states that the guidelines for documentation in IEEE Std. 323-1974 when fully implemented are accepted; IEEE Std. 323-1974, Section 8.3 Item (4) (h), Section 8.4, Item (8), and Section 8.5, Item (7) state that a qualification report should include an approved signature and date. The report does not include any approval signatures or dates; however, this report was written specifically for the qualification of the motors for the Virgil C. Summer plant and application. The report was forwarded f rom G. E. with a signed transmittal letter. A signed certificate of conformance is also on file. Therefore, the repor1.s failure to include an approval signature does not detract from the valiGity of this qualification. (10) NUREG 0588, Section 4, paragraph (2), Category I, states that the degraded influences discussed in Sections 6.3.3, 6.3.4, and 6.3.5 of IEEE Standard 323-1974 and the electrical and mechanical stresses associated with cyclic operation of equipment should be considered and included as part of the aging program. All necessary influences with the exception of radiation exposure were applied as part of the aging program. The qualification documentation and subsequent letter from E. F. Harrison of the motor manufacturer, dated October 14, 1980, include a review and verification of the radiation tolerance of the materials used in the motor. This review indicated no detectable damage to the critical motor components for radiation 6exposure more than one order of magnitude higher than the 9.12 x 10 Rads to which these motors may be exposed. Therefore, qualification based on testing of a motor which was unirradiated is
.cceptable.
O B-164 Revision 3 .
A 4 s 4- 5 cA-M4 m 4 m _A- .am- e- % . a mm- A m r -A i. - - -+- eu -. w--aw-- - dh DR-42 O i (DELETED) i O . f l I i l I l I O B-165-166 l Revision 3 [ 1
I 1 l DR-43 600 Volt Power Cable (1) NUREG 0588, Section 2.1, paragraph 1, Category I states that qualification methods should conform to the requirements defined in IEEE Std. 323-1974. NUREG 0588, Introduction, page 2, paragraph 5 states that "... qualification programs for specific equipment, such as cables, valves, motors, and electrical penetrations, that are designed to conform with the requirements of the daughter standards of IEEE Std. 323-1974 (as endorsed by NRC Regulatory Guide) are acceptable for demonstrating compliance with the objectives of IEEE Std. 323." The qualification methods used were based on the IEEE-323-1974 daughter standard, for cables, splices and field connections, IEEE 383-1974 and are therefore acceptable. (2) NUREG 0586, Section 2.2, paragraph 1, Category I states that failure criteria should be established prior to testing. Neither Kerite nor Isomedix Inc. established failure criteria before electrically loading the cable and subjecting it to the LOCA simulation, or before performing the high-potential withstand test. Hcwever, failure criteria was established on IEEE 383-1974, Section 2.4.3 which implies that the inability to maintain rated voltage and load constitutes failure and Section 2.4.4 implies that the inability to hold an 80 VAC/ mil potential for five minutes constitute failure. Therefore, the intent of this regulation has been satisfied. (3) NUREG 0588, Section 2.2, paragraph 2, Category I states that " test results should demonstrate that the equipment can perform its required function for all service conditions postulated (with margin) during its installed life. The test results indicated that at least some of cable tested was unable to llh maintain its full rated voltage and current loads (600 volts and 50 Amperes) during the LOCA simulation due to high leakage currents to ground. Furthermore, two of the four cables tasted failed to hold the high potential voltage applied after the LOCA simulation for the duration of the tect and the other two cables were not tested with sufficiently high voltages as specified in IEEE 383-1974, Section 2.4.4. Kerite states in their
" Responses to Attachment I, December 30, 1980 letter", Item 1, paragraph 1 that wban a failure occurs prior to the end of test cycle Arrhenius analysis is appiled to the data prior to failure in order to show that the equipment is quelified. Kerite in their summary report dated December 11, 1975 stated that the power cable was qualified, but they did not say whether Arrhenius analysis was applied to the failure and if it was, it is not included in the qualification report. Furthermore, the two cables that failed the high potential withstand tests both contained splices and the failure of this test as well as the leakage current might have been due to splice failure and not cable failure; this splice is not used at Virgil C. Summer. Kerite is being asked to clarify the situation.
(4) NUREG uS88, Section 2.2, paragraph (3), Category I, states '. hat IEEE 323-1974, Secton 6.3, is an acceptable guideline for establishing test precedures. IEEE 323-1974, Section 6.3.1.1, item (3), requires that the test plan include mounting and connection requirements. There are no mounting and connection requirements given in the test plan since the cable was qualified in accordance with IEEE 383-1974, " Standard for Type Test of Class IE Electric Cables, Field Splices, and Connections for Nuclear Power Generating Stations," which does not address mounting and connections for lll B-167 Revision 3 . L.
DR-43
. type testing. However, the report documents that the cable was mounted and connected in the usual manner which consisted of winding the specimens on a mandrel and passing the ends through vessel head penetrations so that electrical' connections could be made to the cable during LOCA testing.
(5) NUREG 0588. Section 2.2, paragraph (3), Category I, states that IEEE 323-1974, Section 6.3, is an acceptable guideline for establishing test procedures. IEEE 323-1974,.section 6.3.1.1, ites (7), states that test equipment requirements including accuracies should be included in a test plan. The qualificaton report does not address test equipment requirements and accuracies. However, the report does include an instrumentation list which gives the range and features of the test equipment. From a review of this list, it is evident that the instruments used were appropriate for the , testing that was done. (6) NUREG 0588, Section 2.2, paragraph (3), Category I, states that IEEE 323-1974, Section 6.3, is an acceptable guideline for establishing test procedures; IEEE 323-1974, Section 6.3.1.4, states that the test equipment shall be calibrated against auditable calibration standards and shall have documentation to support such calibration. Although the report does not include any documentation of calibration, th- test equipment list gives the frequency of calibration of the test equipment. It is reasonable to assume that the calibration was done to an acceptable standard. (7) NUREG 0588, Section 2.2, paragraph (3), Category I, states that IEEE 323-1974, Section 6.3, is an acceptable guideline for establishing test procedures. IEEE 323-1974, Section 6.3.1.4.1, states that temperature, pressure, moisture content, gas composition, vibration and time should be measured variables. These variables were measured except for vibration and gas composition, which are not applicable to cable as per IEEE 383-1974. (8) NUREG 0588, Section 2.2, paragraph 10, Category I, as well as IEEE 323-1974, Section 6.3.1.5, item (5), states that equipment should be subjected to + variations in the nominal electrical alternating current frequency during testing. The range of frequency this cable is expected to experience is not more than i 5% of 60 Hz. Therefore, testing at the nominal frequency of 60 Hz is adequate. (9) NUREG 0588, Section 2.2, paragraph 3, Category I states that IEEE 323-1974, Section 6.3 is an acceptable guideline for establishing test procedures. IEEE 323-1974, Section 6.3.1.5, item 7 states that the initial transient and . dwell at peak temperature of the LOCA test should be applied at least twice. IEEE 383-1974, Section 2.4.4, note states that the high potential withstand . test supplies a more severe margin test than the two cycles of peak temperature exposure required by IEEE 323-1974. Because the NUREG 4 discussion states that equipment designed to daughter standards are acceptable for demonstrating compliance with IEEE 323-1974, the intent of this regulation has been satisfied. (10) NUREG 0588, Section 2.2, paragraph 3, Category I, states that IEEE 323-1974, Section 6.3 is an acceptable guideline for establishing test procedures. IEEE 323-1974, Section 6.3.2 states that the test sequence used shall be ! Justified as the most severe for the item being tested. No justification ' B-168 Revision 3
DR-43 exists in the qualification report. The report follows'the guidelines in IEEE 383-1974 for type testing and is therefore considered to be the most severe type of test for cable. (11) NUREG 0588, Section 2.2 paragraph (3), Category I, states that IEEE 323-1974, Section 6.3, is an acceptable guideline for establishing test procedures. IEEE 323-1974, Section 6.3.2, item (3), states that the equipment shall be operated to the extremes of all performance and electrical characteristics prior to the LOCA simulation. The cable was not subjected to extremes of voltage, current or f requency prior to the test. However, this is acceptable since the cable was subjected to maximum vMtage and current during at least part of the test. As stated in paragraph (r, clarification has been requested from Kerite as to why maximum voltage and current was not applied for the full length of the test. (12) NUREG 0588, Section 2.2, paragraph (6), Catepry I, states that the LOCA test temperature should be defined by thermocouple readings on or as close as practical to the surface of the componen: being qualified. Although the test temperatures were measured with a thermocouple, its exact location cannot be determined from the qualification report. However, more than adequate margin existed between the test temperature and the expected accident condition, and the vessel did not contain compartments. Thus, measured temperature is representative of the vessel's interior. Therefore, the failure of the report ts give the exact location of the thermocouple is acceptable. (13) NUREG 0588, Section 4, paragraph (5), Category I, states that known material phase chaages and reactions should be defined for the accelerated aging program to insure that no known changes occur within the extrapolation limits. Kerite knew of no phase changes or reactions associated with the 600 volt power cable when they performed the accelerated aging tests and constructed the Arrhenius plots. Therefore, phase changes and reactions have not been addressed by the qualification report. (14) NUREG 0588, Section 1.3, Category I, states that the concentration of caustics used for qualification should be equivalent to or more severe than those used in the plant containment spray system. The pH of the spray used in the containment spray system has been analyzed, under the criteria of Section 1.3 of NUREG 0588, and found to be 10.7 peak and 8.7 long-term. The pH of the spray used during the LOCA simulation was maintained, for the majority of the test, between 9.5 and 10. Although the spray pH of 10.7 l that the cable will experience during accident conditions of slightly greater than that used in the test, it is a peak value occurring occasionally within the first 65 minutes of the accident; therefore, it is not expected to cause any significant deterioration of the cable insulation. (15) NUREG 0588, Section 4, paragraph 6, Category I, describes that the aging acceleration rate used during qualification testing and the basis upon which the rate was established should be described and justified. Kerite cable qualification report does not clearly justify the 40 yrs. life Arrhenius plot for the cable insulation. A letter has been written to Kerite for providing us with prcper justification. B-169 Revision 3
DR-43 O k/ (16) NUREG 0588, Section 2.2, paragraph 4, Category I, states that the simulated environmental profile for qualifying equipment inside containment envelope
' the environmental conditions resulting from any design basis event during any mode of plant operation. Table 3.11-3 of the FSAR states that the relative humidity inside the reactor building during a LOCA or MSB will reach a maximum valre of 100%. Analysis of the temperature and pressure data in the Isomedix report indicates that the cable was not exposed to 100%
relative humidity during the simulated LOCA, however, the cable was kept wet during the entire test by being sprayed with a boric acid solution and therefore saw essantially 100% relative humidity. (17) NUREG 0588, Section 2.2, paragraph 4, Category I, states that the simulated environmental profile for qualifying equipment inside containment envelope the environmental conditions resulting from any design basis event during any mode of plant operation. FSAR Figures 6.2-1, 6.2-4, 6.2-Sa and 6.2-7 were not enveloped by Isomedix Report Figure 4 in that the test did not approach the maximum conditions in the short time specified. The test hcwever did exceed the maximum conditions expected and held the higher values for a greater period of time and therefore demonstrate the acceptability.
'(18) NUREG 0588, Section 3, paragraph 4, Category I, indicates that the 10%
time margin identified in Section 6.3.1.5 of IEEE Standard 323-1974 should be used for equipment required for extended times for a design basis event. The LOCA test for the Kerite power cable was limited to
.fs 100 days, and as noted in paragraph (3) above some unresolved failures
( occurred. However, the power cable is required for up to 1 year following an LOCA. Kerite is being asked for assistance in demonstrating the capability of the cable for up to one year post accident. l - %.) (3 B-170 Revision 3. l.
DR-44 Component Cooling Pump Motor (1) NUREG 0588, Section 2.2, paragraph (1), Category II, states that the failure criteria should be established prior to testing. The qualification report for Westinghouse motors does not address the above item. However, all the tests were performed per IEEE 112-1978, IEEE 275-1976 and NEMA MG-1, and the motor maintained its functional integrity af ter the test. Therefore, omission of establishing failure criteria before test does not detract from the acceptability of the qualification report. (2) NUREG 0588, Section 2.2, paragraph 6, Category II, states that the temperature to which the equipment is qualified should be defined by thermocouple readings or by heat transfer analysis. The qualification report shows that temperature was measured by the resistance method. However, IEEE 112-1978, Section 5.3.1.3, states that measurement of temperature by resistance method is an acceptable method. Therefore, measurement of the temperature by resistance method will not change the functional integrity of the test and is judged acceptable. (3) NUREG 0588, Section 2.2, paragraph 10, Category II, states that expected extremes in power supply voltage cange and frequency should be applied during simulated event environmental testing. The qualification does not show that the motor was subjected to extremes of frequency. However, the motors were specified and designed in accordance with NEMA Standard MG-1 which requires that they be operational within 15% of rated frequency. Component cooling water pump motors are not expected to experience any frequency beyond the design extremes (15%). Therefore, testing of these motors at normal frequency is acceptable. $ (4) NUREG 0588, Section 2.2, paragraph 3, Category II, states that Section 5.2 of IEEE 323-1971 is an acceptable guideline for establishing test procedures. IEEE 323-1971, Sections 5.2.3.7 and 5.2.3.8 state test data shall contain equipinent mounting and cable connection information. The qualification report for component cooling water pump motors does not address the above. However, the tests were performed per IEEE-275 and other approved standards which require that proper and appropriate mounting and connection be utilized during testing. Therefore, the lack of information on equipment mounting and connection does not detract from the acceptability of the qualification documentation. (5) NUREG 0588, Section 2.2, paragraph 3, Category II, states that Section 5.2 of IEEE 323-1971 is an acceptable guideline for establishing test procedures. Section 5.2.4.3 of IEEE 323-1971 states the type test data shall contain test facility and instrumentation with traceability records. The l qualification report does not identify the test facility and instrumentation with traceability. Since Westinghouse has a quality assurance program in accordance with 10 CFR 50, Appendix B, which requires that "Heasures shall be established to assure that tools, gages, instruments, and other measuring and testing devices used in activities affecting quality are properly controlled, calibrated, and adjusted at specific periods to maintain accuracy within necessary limits". Therefore, the lack of information on test facility and instrumentation traceability from the qualification report is acceptable. g B-171 Revision 3
DR-44' W(_) (6) NUREG 0588, Section 1.4, paragraph 1, Category II, specifies that radiation _ qualification of equipment should be based on the normally expected radiation environment over the equipment qualified life, plus that associated with the most severe design basis accident. Also, Section 2.2, paragraph -12, Category II, specifies that Cobalt 60 is an acceptable gamma radiation source for environmental qualification. The Qualification report does not address any radiation exposure on component cooling water pump motor nor does it address the use of Cobalt 60 as a radiation source. However, the radiation level in the component cooling motor area after installation of shielding is only 600 Rads (LOCA + 40 yrs. TID). In a letter from Mr. E. E. Hudgins to H. E. Yocom dated 11/18/80, it has been stated that the component cooling water pump motors were designed and manufactured to reactor coolant pump motor applicable standards. One of the requirements in those standards, for. RCP motors is 50 Rad / hour. This would be 438,000-Rads / year. This radiation figure is much higher than the radiation level to which the above motor will be subjected. Therefore, it can be concluded that the above motor will be able to withstand a TID of 600 Rads and the omission of use of Cobalt 60 is acceptable. (7) NUREG 0588, Section 2.3, paragraph 1, Category II, states that justification of the adequacy of the test sequence selected should be provided. The qualification report does not justify the adequacy of the test sequence. However, all the tests were performed per IEEE Standard 112-1978 and IEEE 275 and found to be satisfactory. Therefore, it can be concluded that the test sequence is adequate. (~N (8) YsREG 0588, Section 2.3, paragraph 4, Category II, states that testing shall
'\ J subject the same piece of equipment to radiation and the hostile steam environment sequentially. Tha qualification report does not indicate that the equipment which was tested in the hostile steam environment was also irradiated. Hom-ver, because the equipment experiences no additional radiation during accident conditions and the normal radiation exposure is insignificant compared to the equipment qualification, sequential effects testing is not deemed necessary in this case.
(9) In the process of parformia; maintenance on one of the motors, a polyester based varnish has beer applied to the stator windings. Documentation to relate this varnish to the qua lifica* ion of the motor has been requested from Vestinghouse. (10) NUREG 0588 Section 3, paragraph 4, Category I, indicates that the 10% time margin identified in Section 6.3.1.5 of IEEE Standard 323-1974 should be used for ec,uipment required for extended times after a design basis event. The qualiiication report for the component cooling water pump motor addresses operation for 6 months subsequent to an MSLB, but the component cooling water pump motor may be required for up to one year following an MSB. However, the qualification report shows that the totally enclosed water cooled motor is unaffected by the MSB transient; and he report demonstrates that the motor can be operated for more than the required one year subsequent to an MSB. In addition, the motor is accessible within a few hours following an MSB for maintenance, if necessary, b;
~.
B-172 Revision 3 .
DR-45 Low Voltage Tapes Kerite friction tape is being used as part of a splicing system outside of the reactor building as recommended by Kerite. Although Kerite has not supplied any qualification documentation for this tape, it continues to be succez:sfully utilized as a splicing material in industrial applications. Kerite has been requested to supply justification for the use of this material in normal and abnormal environments associated with nuclear power plants. Additionally, a search of the entire plant will be made to ensure that none of this tape has been used in splices subject to a harsh environment. Although Kerite has not made available any qualification documentation for Bishop Bi-Seal 3, Scotch No. 33, or Scotch No. 88 tapes, they have been industry proven to exhibit excellent stability of electrical, chemical, mechanical and thermal properties. Furthermore, Kerite has been requested to supply justification for the use of these tapes in normal and abnormal service environments of nuclear power plants. Additionally, a search of the enti,e plant will be made to ensure that none of these tapes have been used for splices subject to a harsh environment. Kearney Airseal is being used as part of a splicing system inside the reactor building as recommended by Kerite. Although Kerite has not submitted any qualification documentation for the use of this material inside containment, it has been shown to exhibit excellent stability of electrical, mechanical, chemical and thermal properties. Kerite has been requested to supply justification for the use of this material in the harsh environment associated with a nuclear 3 reactor building. W B-173 Revision 3
DR-46 O evce RTD s - inside Centainment (1) NUREG 0588, paragraph 2.2 (3), Category I, specifies that the guidelines of paragraph 6.3 of IEEE Standard 323-1974 should be followed. Paragraph 6.3.1.1 (7) requires that test equipment reluirements including accuracies be included in the qualification test plan. The Pyco test plan does not identify test equipment accuracies. This omission is considered acceptable singe the qualification report (Appendix 5) identifies the test equipment used by Isonedix, Inc. during the testing program. The equipment list identifies span, calibration frequency, manufacturer, and Isonedix identification number. The identification number can be traced to the manufacturers data. (2) NUREG 0588, paragraph 2.2 (3), Category I, specifies that the requirements of paragraph 6.3 of IEEE Standard 323-1974 should be followed. Paragraph 6.3.2 (1) identifies that inspection may be performed to assure that a test unit has not been damaged due to handling. The Pyco report does not identify that this inspection was performed. This omission is acceptable since pretest data taken before the thermal aging of the equipment demonstrated that the equipment functioned properly. (3) NUREG 0588, paragraph 2.2'(3), Category I, specifies that the requirements of paragraph 6.3 of IEEE Standard 323-1974 should be used as a guide. Paragraph 6.3.7 requires that upon completion of type testing, the equipment shall be dismantled and the condition of components recorded. The Pyco report does not identify that dismantling was performed and conditions recorded. This omission is acceptable since post-test data demonstrates O' that the equipment functioned as designed afetr completion of the accident test. (4) NUREG 0588, paragraph 2.2 (6), Category I, specifies that when the equipment is exposed to the simulated accident environment, the temperature should be defined by thermocouple readings on or as close as practical to the surface of component being qualified. The location of the thermocouple used during the test was not identified in the report. Due to the long periods of time which were used as holding times, temperatures within the test chamber would have reached steady-state conditions prior to each step drop in temperature. Since the critical function is that the equipment be qualified to a temperature which exceeds the expected accident temperature (which has been demonstrated), and since the temperature reached a steady-state conditions, the omission of the thermocouple location is acceptable. l l (5) NUREG 0588, paragraph 2.2 (10), Category I, specifies that the expected ! extremes of voltage and frequency in power supply should be applied during testing. The characteristics of an RTD are not dependent on voltage or frequency; therefore, testing to voltage and freguency extremes is not L applicable. Electrical characteristic tests which included element resistance and insulation resistance at 500 volts were conducted ! during the qualification test. i
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B-174 Revision 3
DR-46 (6) NUREG 0588, paragraph 4 (4), Category I, specifies accelerated aging methods other than the Arrhenius methodology may be acceptable if it can be supported by type tests. Tbe degree of aging chosen was based on what is considered adequate for cable (IEEE 383-1975). It is to be realized the materials used in the equipment are completely inorganic with the execption of the silicone pot seal and short lengths of insulating sleeving which are provided primarily to improve handling characteristics of the assemblies. The parameters for aging were selected on the basis of consistancy with the qualification of electric cable (reference: IEEE 383-1975) as a means of comparison between clement componente and not as a means of simulating an extended period of time by accelerated aging techniques. The justification for this approach is contained in the position statement to IEEE 323A-1975 as well as the philosophy and intent of IEEE 381-1977 in that aging was considered as an operational parameter and its effect on performance was determined not to result in age-related failure mechanisms unlike vibratory motion which could degrade the safety function performence of the assemblies. It is further to be understood that routine in-service testing of elements may readily be performed to detect performance outside the design range specification which would allow replacement of degraded elements and thereby extend the qualified life of the assemblies. Application of the "10'C" rule for accelerated aging to the Thermal Aging conditions performed during the qualification test, namely 7 days at 121*C Based on an ambient temperature environment of 50 C, results in an estimation of installed life at being 2-1/2 years. A replacement period greater than the vendor stated 2-1/2 years is desired. This issue will be addressed in the plant aging program. (7) NUREG 0588, paragraph 2.2 (4), Category I, specifies that a single profile that envelopes the environmental conditions resulting from a design basis I event should be used as the test profile. Both the main steam line break l and LOCA postulated profile have a quicker temperature rise than the tested profile. The rate of temperature rise for the postulated profiles exceed the test profile only for a period of seconds, af ter which the test profile deviation from the test envelope is acceptable. (8) NUREG 0588, paragraph 3 (2), Category I, trecifies that the margins suggested in IEEE Standard 323-1974 should be used as a guide. Margins were used during the test, but not consistently to the applicable values identified in Section 6.3.1.5 of IEEE Standard 323-1974. Item number 7 describes where a temperature margin does net exist. In addition, a 10% factor for time was not used. The margins used for the test profile have been evaluated for the application and are considered adequate. (9) NUREG 0588, paragraph 2.2 (8), Category I, specifies that caustic spray should be incorporated during simulated event testing. The spray pH range for the Virgil C. Summer station is 8.7 to 10.7; however, the tested equipment was subjected to a pH range of 9.5 to 10.5. The postulated spray solution pH is 10.7 maximum for a period of 65 minutes after which the pH will drop to 8.7 for a period of approximately 30 hours. These deviations O B-175 Revision 3
DR-46 l (,/ are considered 4:ceptable since the Pyco test subjected the RID's to chemical spray throughout the LOCA simulation, whereas, the Virgil C. Summer station spray is for two hours minimum. (10) The RTDs successfully performed their intended function throughout the various phases of the test program, except as follows:
- a. Short circuiting of element number IB following the LOCA simulation and intermittent shorting of element SB also after the LOCA simulation.
The cause for this is thought to be a result of moisture, either condensate or spray solution, entering the unit head.
- b. Evidence of performance of Units 1 and 5 outside the acceptable limits of operation was recorded during the LOCA simulation prior to the post-LOCA calibration.
- c. Test Unit 3 was determined to have ceased operation during the LOCA simulation and the subsequent calibration verified this observation.
The vendor recommendation to preclude the observed shorting is to seal the threaded connections to prevent the ingress of condensate or spray solutions. O) v. n U B-176 Revision 3
DR-47 Rosemount - CC Flow to RCP's (1) NUREG 0588, paragraph 4 (1) and paragraph 4 (2), Category II, identifies the requirement to address aging of components qualified to IEEE 323-1971. The Rosemount qualification report does not address aging. The omission of aging criteria is acceptable since these instruments are not required to function post-accident. Age related malfunctions will be detected during periodic in plant testing. In addition, however, a similar Rosemount transmitter is currently undergoing qualification testing to IEEE Standard 323-1974 (including aging). Upon successful qualification a material comparison will be performed between the two units to demonstrate aging applicability of the new test to the instelled equipment. (2) NUREG 0588, paragraph 2.2 (3), Category II, identifies that the test procedure should conform to the guidelines in paragraph 5.2 of IEEE Standard 323-1971. Paragraph 5.2.1 requires the test data to include equipment specifications. The Rosemount report identifies the model number of the equipment qualified. Equipment specifications for these model numbers can be found in the Rosemount catalog; therefore, omission of equipment specifications is acceptable. (3) NUREG 0588, paragraph 2.2 (3), Category II, identifies that the test procedure should conform to the guidelines in paragraph 5.2 of IEEE 323-1971. Paragraphs 5.2.3.7 and 5.2.3.8 require equipment mountings and cable connections be relevant to performance. The Rosemount report does not address the mountings or cable connections used for environmental qualification. Mounting of eqaipment is critical for seismic qualification; llh however, environmental conditions will not induce detrimental loading at the equipment mounting location. The method used in connecting the cable to the transmitter is not significant, since this equipment is not required to function post-accident (see paragraph 8). Therefore, the above omissions are acceptable. (4) NUREG 0588, paragraph 2.2 (10), Category II, identifies that the expected extremes in power supply voltage range and frequency should be applied during simulated event environmental testing. The Rosemount report identifies that the liftoff voltage (i.e. voltage required to operate the transmitter) was monitored for informational purposes. The report shews that the liftoff voltage after testing had not deviated significantly from baseline values esta'olished prior to testing. The power supplies installed at Virgil C. Summer provide high precision regulation; therefore, voltage variations are negligible. Based on the above, this omission is acocptable. l (5) NUREG 0588, paragraph 2.2 (6), Category II, specifies that when the equipment is exposed to the simulated accident environment, the temperature should be defined by thermocouple readings on or as close as practical to the surface of the component qualified. The location of the thermocouple used during the test v=s not identified in the report. Since this equipment is not required to opi ite post-accident (see paragraph 8) this omission is acceptable. O B-177 Revision 3 .
l DR-47 v.
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is_j (6) NUREG 0588, paragraph 2.2 (4), Category II, identifies that the test profile should envelope the conditions produced by the main steam line break and l loss of coolant accidents. The simulated environmental profile at test was ' not accomplished for an exact design base event. This occurred within the first three (3) minutes, when the simulated test did not achieve the rise in temperature; however, the Rosemount report established that the time (seconds)' verse magnitude and duration, the postulated conditions exceed the qualified conditions with adequate margin. Since this equipment is not required to function post-accident (see paragraph 8) this deviation is acceptable. (7) NUREG 0588, paragraph 2.3, Category II, specifies that justification of the H adequacy of the test sequence selected should be provided. The Rosemount report follows the guidelines of paragraph 6.3.2 of IEEE Std. 323-1974, except for aging. The detection of age related failures is discussed in paragraph 1. (8) NUREG 0588, Section 2.1 paragraph (3), Category II, subparagraph C states that the basis should be provided for concluding that equipment which could experience environmental conditions of design basis line break accidents, including steam line breaks, need not function for mitigation of said accidents, and whose failure (in any mode) is deemed not detrimental to plant safety and need not bc qualified for any accident environment. These instruments could experience a steam break or LOCA environment; however, the function of these instruments is not required to mitigate the postulated steam break or LOCA. The safety function of this instrumentation is to (y
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detect loss of component cooling water to the reactor coolant pumps during normal conditions. Therefore, this equipment need not function during a main steam line break or LOCA environment. w
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B-178 Revision 3 l
l DR-48 Reactor Building Sump Level Transmitters (1) NUREG 0588, paragraphs 2.2 and 2.3 identify criteria to be used when evaluating equipment qualification reports which demonstrate qualification by testing. The sump level transmitters were qualified by a combination of analysis and test. The analysis performed demonstrates that the Rosemount model #1153-0022-0001 transmitter is similar to the previously qualified Rosemount model #2253DA4. A prototype 1153-0022-0001 transmitter was tested for leak tightness and function during a 7-day submergency test. For details of the 1153DA4 transmitter qualification report see DR 49. The following discussion is based on the submergence test.
- a. NUREG 0588, paragrap 2.2 (1), Category II, specifies that the failure criteria should be established prior to testing. Rosemount test procedure #47824, revision A does not specifically identify a failure criteria; however, the procedure does require that the transmitter output be continuously recorded throughout the test. The procedure also requires that the tested unit be inspected for leakage at the conclusion of the test. Since the test data demonstrates that leakage of significant transmitter drift did not occia , the omission of a failure criteria is acceptable.
- b. NUREG 0588, paragraph 2.2 (3), Category II, specified that the items described in Section 5.2 of IEEE Standard 323-1971 should be considered as guidelines. Section 5.2 requires equipment specifications to be included in the test data. The Rosemount submergence report does not identify equipment specifications. This omission is acceptable since dwgs. 01153-0022, sheets 1 & 2 (attached to Rosemount Report #1794, dated 1/12/79) identify equipment specifications.
- c. NUREG 0588, paragraph 2.2 (3), Category II, specifies that the test plan should conform to the guidelines in Section 5.2 of IEEE Standard 323-1971. Paragraph 5.2.3.3 requires the number, type, and location of test monitoring sensors be identified. The Rosemount submergence test does not identify the location of the test monitoring sensors. Rosemount repart 5798C identifies water temperature and pressure measurement in sufficient detail to deduce the location of the sensors; therefore, the above omission is acceptable.
- d. NURFG 0588, paragraph 2.2 (3), Category II, specifies that the test plan should conform to the guidelines in Secton 5.2 of IEEE Standard 323-1971. Paragraphs 5.2.3.7 and 5.2.3.8 require equipment mountings and cable connections to be identified. The Rosemount test plan does not address the mounting or connections of the tested equipment. The omission of mounting data is acceptable since the environmental qualification test will not produce additional loads on the equipment. The method used in connecting the cable to the transmitter is not significant, provided all connections are sealed to prevent in-leakage of the chemical / steam / water environment. Tb-Virgil C. Summer plant utilizes sealed connections; therefore, . .m above omissions are acceptable.
O B-179 Revision 3 .
DR-48 V e. NUREG 0588, paragraph 2.2 (3), Category II, specifies that the test 1 program should conform to the guidelines in Section 5.2 of IEEE Standard 323-1971. Paragraph 5.2.3.4 requires the test facility and instrumentation with traceability records be identified in the qualification report. The Rosemount submergence test report does not identify the test facility which performed the test. Appendix A of Rosemount report #47824 (Appendix A of submergence report #77812) is a tuoltug and equipment list to which accuracy is traceable to the National Bureau of Standards. The list identifies the autoclave as manufactured by Rosemount which implies Rosemount performed the test. Therefore, the omission of this information is acceptable.
- f. NUREG 0588, paragraph 2.2 (6), Category II, specifies that when the equipment is exposed to the simulated environment, the temperature should be defina! by a thermocouple reading or or as close as practical to the surface or the component being qualified. The location of the thermocouples used during the submergency test was not identified in the report. The omission of this information does not compromise the results of the report since the transmitter was submerged during the test and water temperature was monitored.
- g. NUREG 0588, paragraph 2.2 (8), Category II, specifies that caustic spray should be incorporated during simulated event testing. The Rosemount submergence test does not idylude caustic spray. Since the purpose of this test was to demonstrate the water tight integrity of the transmitter, the omission of a caustic, solution is acceptable.
The Rosemount Model #1153DA4 was tested to spray conditons under test report #3788. *-
- h. NUREG 0588, paragraph 2.2 (10), Category II, specified that expected extremes in power supoly voltage range and frequency should be applied during simulated environmental testing. ' :e the purpose of this test was to demonst, rate the water tight integrtcy of the transmitter, the omission of testing to voltage and frequency 2xtremes is acceptable.
- i. NUREG 0588, paragraph 2.2 (12), Categocy II, identifies Cobalt 60 as an acceptable gamma radiation source for environmental qualification. The sample which was submerged was not subjected to radiation. This is acceptable since the Rosemount model #1153DA4 (qualified by test report #3788) was subjected to Cobalt 60.
J. NUREG 0588, paragraph 2.3 (4), Category II, specifies that hostile environment testing should be conducted in a manner that subjects the same piece of equipment to radiation and hostile steam environment sequentially. The Rosemount test is for submergence only. This is acceptable since the Rosemount model #1153DA4 transmitter was qualified to radiation, steam and spray in an acceptable manner documented in Rosemount report #3788. l
- k. NUREG 0588, paragraph 2.2 (4), Category II, identifies that a single profile that envelopes the conditions produced by the main steam line l break and loss-of-coolant ascidents be used for the simulated 1 b-B-180 Revision 3
i 1 l DR-48 environmental profile. The environmental envelope used for the submergence test was not as severe as the Virgil C. Summer LOCA/ Main steam break envelope. Testing to a less severe environmental envelope for this applicaton is acceptable, since the values used during the test exceed the predicted values of the sump (see FSAR Figure 6.2-6). (2) NUREG 0588, paragraph 2.4, Category II, allows qualification methods other than testing to be used where supporting detail is provided. Section 4.0 of Rosemount report RMT 17931, revision A, provides a comparison of the similarities and differences between the model #1153-0022-0001 and 1153DA4 transmitters. Section 5.0 of Rosemount report RdT 17931, revision A provides justification of performance in radiation, seismic, and steam chemical environment. Therefore, the analysis is acceptable for the application. (3) NUREG 0388, paragraph 3, Category II, specifies that margins are to be used to assure that the postulated accident conditons have been enveloped during testing. The margin in temperature and pressure for test can be seen in FSAR figures 3.11-25, 6.2-4, and 6.2-Sa. The main steam line break postulated profile has a quicker temperature rise than the tested profile. The rate of temperature rise for the postulated profiles exceeds the test profile for only a period of seconds, af ter which the test profile temperatures exceed the postulateo. The time chosen was an arbitrary value and as such the margin is not coplica51e. Radiation is discussed in paragraph 5. In conclusion, with t he exc eption of radiation, the margins utilized have been evaluated as adeqzate for the application. llh (4) NUREG 0588, paragraph 4 (2), Category II, requires that the qualification programs identify aging effects on materials subject to aging. Since this equipment was purchased to IEEE Standard 323-1971, aging was not considered at the time of equipment qualification. Major components of the transmitters are stainless steel and not susceptable to aging. The 0-rings used in the transmitters are ethylene propylene and will be replaced periodically. Age related electrical component malfunctions will be detected during periodic in-plant testing; therefore, the omission of aging is acceptable. In addition, however, a similar Rosemount transmitter is currently undergoing qualification testing to IEEE Standard 323-1974 (including aging). Upon successful qualification, a material comparison will be performed between the two units to demonstrate aging applicability of the new test to the installed equipment. (5) DELETED (6) NUREG 0588, paragraph 4 (2), Category II, states that a replacement period l should be established for replacing equip;ent and/or materials susceptible to aging. This issue will be addressed in the plant aging program. O B-181 Revision 3 .
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DR-49 Rosemount (1) NUREG 0588, paragraph 4 (1), and paragraph 4 (2), Category II, identifies the requirement to addrese aging of components qualified to IEEE 323-1971. The Rosemount qualification report does not address aging. Major components of the transmitters are stainless steel and not susceptable to aging. The 0-rings used in the transmitters are ethylene propylene and will be replaced periodically. Since age related electrical component malfunctions will be detected during periodic in-plant testing, the omission of aging is acceptable. In addition, however, a similar Rosemount transmitter is currently undergoing qualification testing to IEEE Standard 323-1974 (including aging). Upon successful qualification, a material comparison will be performed between the two units to demonstrate aging applicability of the new test to the installed equipment. (2) NUREG 0588, paragraph 2.2 (3), Category II, identifies that the test procedure should conform to the guidelines in paragraph 5.2 of IEEE Std. 323-1971. Paragraph 5.2.1 requires the test data to include equipment specifications. The Rosemount qualification report does not include equipment specifications. The Rosemount report identifies the model number of the equipment qualified. Equipment specifications for these model numbers can be found in the Rosemount catalog; therefore, omission of equipment specifications is acceptable. (3) NUREG 0588, paragraph 2.2 (3), Category II, identifies that the test procedure should conform to the guidelines in paragraph 5.2 of IEEE Std. 323-1971. Paragraph 5.2.3.7 and 5.2.3.8 require equipment mountings llh and cable connections be relevant to perfor&ance. The Rosemount report does not address the mountings or cable ccanections used for environmental qualification. Mounting of equipment is critical for seismic qualification; however, environmental conditions will not induce detrimental loading at the equipment mounting location. The method used in connecting the cable to the transmitter is not significant, provided all connections are sealed to prevent in-leakage of the chemical / steam environment. The Virgil C. Summer plant utilizes sealed connections, therefore, the above omissions are acceptable. (4) NUREG 0588, paragraph 2.2 (10), Category II, identifies that the expected extremes in power supply voltage range and frequency should be applied during simulated event environmental testing. The Rosemount report identifies that the liftoff voltage (i.e. voltage required to operate the transmitter) was monitored for informational purposes. The report showed that the liftoff voltage after testing had not deviated significantly from baseline values established prior to testing. The power supplies installed at Virgil C. Summer provide high precision regulation; therefore, voltage variations are negligible. Based on the above, this omission is acceptable. (5) NUREG 0588, paragraph 2.2 (6), Category II, specifies that when the equine-nt is exposed to the simulated accident environment, the temperature should be dedined by thermocouple readings on or as close as practical to the surface af component being qualified. The location of the thermocouple used during the test was not identified in the report. Due to the long O B-183 Revision 3 .
DR-49 l T_/ periods of time which were used as holding times, temperatures within the test chamber would have reached steady-state conditons prior to each step down in temperature. Since the critical function is that the equipment be qualified to a temperature which exceeds the expected accident temperature (which has been demonstrated) and since the temperature reached a
. steady-state condition, the omission of the thermocouple location is acceptable.
(6) VUREG 0588, paragraph 2.2 (4), Category II, identifies that the test profile should envelope the conditions produced by the main steam line break and loss of coolant accidents. The need to qualify to a LOCA environment is not applicable for equipment located outside of the reactor building. The qualified envelope does envelop the postulated steam line break environment for the equipment location. Transmitters IFT-7263A & B are in the reactor building but are Category C and therefore are not required to function for the accident environment. (7) NUREG 0588, paragraph 2.3, Category II, specifies that justification of the adequacy of the test sequ nce selected should be provided. The Rosemount report follows the guidel; as of paragraph 6.3.2 of IEEE Std. 323-1974, except for aging. The detection of age related failures is discussed in paragraph 1. (8) NUREG 0588, Section 2.1, paragraph (3), Category II, subparagraph C states that the basis should be provided for concluding that equipment which could experience environmental conditions of the design basis line break (]) accidents, including steam line breaks, need not function for mitigation of said accidents, and whose failure (in any mode) is deemed not detrimental to plant safety and need not be qualified for any accident environment. Rosemount flow transmitters IFT-7273A-CC, IFT-7273B-CC, IFT-4466-SW, IFT-4496-SW, IFT-7368-SP, and IFT-7378-SP are located in areas subject to environmental changes as a result of either a small line break or a main steam line break outside of the reactor building. The basis for exempting these transmitters from qualification follows.
- a. The function of transmitters IFT-7273A-CC and IFT-7273B-CC is to monitor component cooling water flow to the thermal barriers for the reactor coolant pumps when the reactor coolant pumps are operating.
These transmitters would be exposed to the environment resulting from a main steam line break (MSLB) outside of the reactor building. The reactor coolant pssps are non-electrical class IE and, therefore, not required to mitigate the consequences of a main MSLB accident outside of the reactor building. If the reactor coolant pumps are operated during the MSLB the primary means for removing heat from the pumps is through the water supplied by the safety injection / charging pumps. Based on the above, transmitters IFT-7273A-CC and IFT-7273B-CC neet not be qualified. It should be noted; however, that as identified in DR-49, paragraph 6, the transmitters are qualified to the conditions of the MSLB accident outside of the reactor building to which they are exposed. A V B-184 Revision 3
DR-49
- b. The function of transmitters IFT-4466-SW and IFT-4496-SW is to monitor service water booster pump discharge flow when the booster pumps are operating. Detailed Report DR-39, paragraph 2, describes the conditions which exempt the service water booster pump motors from qualification. Since these transmitters are not required when the pump is not operating, these transmitters are exempt from qualification on the same basis described in DR-39. It should be noted; however, that as identified in DR-49, paragraph 6, the transmitters are qualified to the conditions of the main steam line break accident outside of the reactor building to which they are exposed,
- c. The function of transmitters IFT-7368-SP and IFT-7378-SP is to monitor reactor building spray pump discharge flow when the spray pumps are operating. These transmitters would be exposed to the environment resulting from a small line break outside of the reactor building. The spray pumps only operate for a loss of coolant accident (LOCA) or main steam line break accident inside the reactor building. Since these transmitters are not required to function when the spray pumps are not operating and small line break outside of the reactor building is not considered coincident with a LOCA or main steam line break inside the reactor building, the transmitters are not required for the small line break accident outside of the reactor building. It should be noted; however, that as identified in DR-49, paragraph 6, the trans:nitters are qualified to the conditions of the small line break accident outside of the reactor building to which they are exposed.
(9) NUREG 0588, paragraph 4 (2), Category II, states that a replacement period should be established for replacing equipment and/or materials suspectible to aging. This issue will be addressed in the plant aging program. O B-184a Revision 3
DR-50 (q -
/ Reliance Fan Motor, Auxiliary Building (1) NUREG 0588, Section 2.1, paragraph (3), subparagraph (C), states that the basis should be provided for concluding that equipment which could experience environmental conditions of design basis line break accidents, including SLB and MSB, through which it need not function for mitigation of said accidents, and whose failure (in any acde) is deemed not detrimental to plant safety, need not be qualified for any accident environment, but is qualified for the nonaccident service environment. Fan motor XFN-0132 could experience an SLB, but operation of the fan is not required to mitigate the SLB's postulated for the auxiliary building, nor would the failure of this fan during an SLB be detrimental to plant safety, as it provides air for other C, equipment as detailed in DR-34. However, the available qualifitation data indicates these fan motors are qualified for the SLB, thereby providing additional margin.
(2) NUREG 0588 paragraph 2.2 (1) Category I identifies that the expected extremes and voltage and frequency should be applied during testing. Reliance tested the motors to a voltage extreme only. Since in motors the effects of small frequency changes are the same as small changes in voltage, the effect of the expected 157, variation in frequency is adequately addressed by the testing to the expected extremes of voltage. (3) NUREG 0588 paragraph 2.2 (6), specifies that when the equipment is exposed to the simulated (accident) environment, the temperature should be defined by thermocouple readings on or as close as practical to the surface of the O V component being qualified. The location of the temperature sensory device (thermocouple not specified in Reliance report) used during the test was not identified in the report. Since Reliance holds parts of the qualification program as proprietory, the Reliance Certificate of Compliance to the test envelope is sufficient. (4) NUREG 0588 paragraph 2.2 (3), Category I, identifies that the test procedure should conform to the guidelines in paragraph 6.3 of IEEE Standard 323-1974. Paragraphs 6.3.1.2 and 6.3.1.3 require that equipment mountings and cable connections be relevant to performance. The Reliance report does not address the mountings or cable connections used for environmental qualification. Mounting of equipment is critical for seismic qualification; however, environmental conditions will not induce datrimental loading at the equipment mounting location. The method used for electrical connections to the motor leads is not significant, provided these connections are insulated to prevent short circuits. The installation in the Virgil C. Summer Nuclear Plant utilizes taped splices to the motor leads. The qualification of these taped splices is addressed elsewheee in this report under the title of Kerite low voltage tapes. (5) NUREG 0588 paragraph 3 (2), Category I, identifies that in lieu of other proposed margins that may be found acceptable, the suggested values indicated in IEEE Standard 323-1974, Section 6.3.1.5 should be used as a guide. The Reliance qualification report includes a margin over the Virgil C. Summer conditions; however,- the factor on pressure and the number of environmental transients recommended by Section 6.3.1.5 were not used. The B-185 Revision 3 .
T I DR-50 factors are not considered applicable since these motors are not required to perform during an u.vironmental transient. Therefute, the margins used for t.he Reliance qualification are considered acceptable. (6) NUREG 0588 paragraph 2.4, Category I, specifies that the analysis or operating experience should conform to the guidelines of IEEE Std. 323-1974. Paragraph 8.5.2 indicates that the interface or boundary conditions of the equipment should be contained in the analysis. The Reliance qualification report specifies the environmental conditions, including extremes of temperature and hunidity and the resulting failures. The most vulnerable components are also specified, such a the insulation, bearings, lubricants, seals. Since these components are encased in a frame, boundary conditions other than environmental effects, temperature, and humidity are considered not to have a detrimental effect on the equipment's qualification. (7) NUREG 0588 paragraph 2.4, Category I, identifies that analysis or operating experience should follow the guidelines set by IEEE Standard 323-1974. Paragraph 8.4 (3,5) indicates that the specifications and the comparisons of previous and new specifications should be s.tated in the qualification report. The Reliance report utilizes its operating experience to verify the qualified life of specific components and/or prove that a limited life need not be a consideration for these components. Consequently, the aging of these components will not affect motor operation. Since these components are standard with the motor, and the new motor is basically the same as the oae from which the operating experience was recorded, comparison of the motors is not required. (8) NUREG 0588 paragraph 2.2 (3), Category I, specifies that the test procedure O should conform to the guidelines in Section 6.3 of IEEE Standard 323-1974. Paragraph 6.3.1.7 requires that the accuracy of the test equipment. requirements must be specified. The Reliance motor qualification report does not specify the accuracies for the equipment requirements, but since the Reliance report includes the equipment information, the omission of test equipment accuracies is acceptable. (9) NUREG 0588 paragraph 2.2 (3), Category I, identifies that the test procedure should conform to the guidelines in Section 6.3 of IEEE Standard 323-1974. Paragraph 6.3.1.1.1 requires the test plan to include equipment descriptions. The Reliance report identifies that test models (motorettes) were used for much of the testing. IEEE Standard 117-1974, allows the selection "motorette" as the basis for thermal evaluation of Class H, Type RH insulation systems. The Reliance report also indicates the model number of the complete motor tested for radiation endurance. Equipment descriptions for this model number can be found in the instruction manual l included with the report. Therefore, Omission of the equipment descriptions is acceptable. ! (10) NUREG 0588, Section 2.1, paragraph (3), subparagraph (C), states that the basis should be provided for concluding that equipment. which could experience environmental conditions of design basis line break accidents, including SLB and MSB, through which it need not function for mitigation of said accidents, and whose failure (in any mode) is deemed not detrimental to O B-186 Revision 3 . 1
DR-50 plant safety, need not be qualified for any accident environment, but is
. qualified for the nonaccident service environment. Fan motors XFN0081A&B~
could experience an MSB, but operation of the fans is not required to mitigate the MSB's postulated for the intermediate building, nor would the failure of these fans during an MSB be detrimental to plant safety, as they provide air for other C equipment 2 as detailed in DR-39. (11) NUREG 0588, Section 2.1, paragraph (3), subparagraph (C), states that the basis should be provided for conclading that equipment which could experience environmental conditions of design basis line break accidents, including SI.B and MSB, through which it need not function for mitigation of said accidents, and whose failure (in any mode) is deemed not detrimental to
; plant safety, need not be qualified for any accident environment, but is quslified for the'nonaccident service environment. Fan motors XFN0083A&B could experience an MSB, but operation of the fans is not required to } mitigate the MSB postulated for the intermediate building, nor would the failure of these fans during an MSB be detri:sental to plant safety.
(12) NUREG 0588, Section 2.2, paragraph (7), Category I, specifies that the performance characteristics of equipment should be verified before, after and periodically during testing throughout its range of required operability. Reliance Summary Report NUC-9 summarizes the results of testing performed but does not include periodic test data. Reliance considers the test data proprietary and available for review only at its
- offices in Cleveland, Ohio. NUC-9 reports no failures associated with performance testing and it is considered reasonable to conclude that G
-- V equipment performance was monitored before, during, and af ter testing throughout its range of required operability.
(13) NUREG 0588, Section 5, parargraph (2), Category I, states that the guidelines for documentation in IEEE Std. 323-1974 when fully implemented are acceptable. The documentation should include sufficient information to address the required information identified in NUREG 0588, 4;p udix E.
- Reliance Summary Report NUC-9 summarizes the results of testing performed
; but does not include actual test data. Reliance considers the actual qualification data proprietary and available far review only at its offices l in Cleveland, Ohio. Until these documents are reviewed, it cannot be concluded that the documentation requirements of NUREG 0588 and IEEE-1974, Section 8.3, have been met. Data will be audited prior to fuel load.
1 (14) NUREG 0588, Section 5, paragraph (2), Category I, states that a Certificate i of Conformance (C0C) by itself is not acceptable unless it is accompanied by. 4 test data and information on the qualification program. A C0C has been 1 received from the vendor that certifies specific equipment to a quality 1 assurance specification. Reliance considers this specification proprietary and available for review only at its offices in Cleveland, Ohio. Until the review is coa.plete, it cannot be concluded that the COC requirements of NUREG 0588 have been met. COC will be audited prior to fuel load. l O B-186a l Revision 3. t l
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t 1 1 ! 4 I l 1 I i B-191 Revision 3
DR-55 Limitorque Valve Operators - Outside Containment (1) NUREG 0588, paragraph 2.2 (3), Category II, specifies that the test procedure should conform to the guidelines in Section 5.2 of IEEE Std. 323-1971. Paragraph 5.2 requires that the test data accuracy must be specified. The Limitorque qualificatica report B0003 does not specify the accuracy for the test data, but it does specify that the test equipment has been calibrated by standards which require periodical calibration. Therefore, since adequate conservatism (margins) does exist in test results, the omission of s'a test data accuracies is acceptable. (2) NUREG 0588, paragraph 2.2 (10), Category II, identifies that the expected extremes in voltage and frequency should be applied duri.'g testing. Limitorque tested the valve operators to a voltage extreme only. Since this equipment is not expected to see significant frequency changes in its installed service, testing to a fixed frequency is acceptable. (3) NUREG 0588, paragraph 2.2 (3), Category II, identifies that the test procedure should conform to the guidelinas in paragraph 5.2 of IEEE Std. 323-1971. Paragraph 5.2 requires equipment mountings be relevant to performance. The Limitorque report does not address the mountings used for environmental qualification. Mounting of equipment is critical for seismic qualification; however, environmental conditions will not induce detrimental loading at the equipment mounting location. Therefore, the omission of mounting information does not detract from the validity of the qualification. (4) NUREG 0588, Section 4, paragraph (5), states that known material phase 9 changes and reactions should be defined for the accelerated aging program, to insure that no known changes occur within the extrapolation limits. Limitorque knew of no phase changes or reactions associated with the valve actuators when they performed the accelerated aging tests and constructed the 10' half life plots of thermal regression. Therefore, phase char ^ nd reactions have not been addressed by the qualification report. l l O B-192 Revision 3
I l l DR-56 l 1 O (DELETED) i
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O i i l l I 1 O B-193-194 Revision 3 i l 1
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DR-57
'losemount (1) KUREG 0588, paragraph 2.2 (1), Category II, specifies that the failure criteria should be established prior to testing. A Rosemount test plan is not included with the qualification records. The omission of a test plan identifying failure criteria is acceptable since p.iragraph 4.1 of qualification report #117415, revision B, identifies that the transmitters tested performed within acceptable limits.
(2) NUREG 0588, paragraph 2.2 (3), Category II, specifies that the test plan should conform to the guidelines in Section 5.2 of IEEE Standard 323-1971. Paragraph 5.2.3.7 of IEEE Standard 323-1971 requires mounting and connection requirements to be identified. The Rosemount test data does not address mounting or connections of the equipment during the simulated accident test. Mounting of the equipment is critical for seismic qualification; however, since environmental conditions will not induce additional loads on the equipment, mounting during LOCA testing will not affect equipment qualification. This equipment will not see a steam break environment simultan tusly with its need to function; therefore, the method of connection is not critical. Based on the above, the omission of this information is acceptable. (3) K' REG 0588, paragraph 2.2 (4), Category II, specifies that a sir.gle test e ofile which envelopes the environmental conditions resulting from any cesign basis event during any mode of plant operation is preferred. The scope of the Rosemount report identifies that this report is intended to qualify equipment for LOCA conditions; however, the steam temperature / pressure curves do not envelope the Virgil C. Summer LOCA curves and the equipment was not subjected to spray conditions. The transmitters which were qualified by this report are located outside the reactor building and, therefore, will not be subjected to the inside reactor building LOCA environment. The test environment does envelope the outside of reactor building steam break conditions. The report is therefore acceptable for the application of these transmitters. (4) NUREG 0588, paragraph 2.2 (6), Category II, specifies that when the equipment is exposed to the simulated accident environment, the temperature should be defined by a thermocouple reading on or as close as practical to the surface of the component being qualified. The location of the I thermocouple is shown in Figure 5 of Rosemount report #117415, revision B. At this location, the thermocouple is reading temperature in the clectrical conduit connected to the test chamber. The significant concern of the location of the thermocouple is to assure that the readings are representative of the environment being simulated. The location of the thermocouple is acceptable since the steam inlet to the chamber is remote from the thermocouple location and the thermocouple is sufficiently removed from the chamber to result in conservative temperature readings. O B-195 Revision 3 .
DR-57
; /3
(,,) (5) NUREG 0588, paragraph 2.2 (8), Category II, specifies that caustic spray should be incorporated during simulated event testing. The Rosemount
. qualification program did not include a caustic spray during the steam pressure / temperature testing. The omission of a caustic spray during testing is acceptable since the transmitters qualified by this program are located outside of the reactor building and will not be subjected to a caustic spray solution.
(6) NUREG 0588, paragraph 2.2 (10), Category II, specifies that extremes in power supply voltage range and frequency should be applied during simulated event environmental testing. The Rosemount report does not address the
-values used for the qualification. Since the transmitters are pcwered from a DC source, frequency variations are not applicable. Ia addition, the power source is electrical Class 1E and remote from the steam environment with a maximum output variation of i2 volts. Therefore, the omission of test data for voltage variations does not compromise the equipment qualification.
(7) NUREG 0588, paragraph 4 (2), category II, requires that aging effects be considered. The Rosemount report does not address aging. Major components of the transmitters are' stainless steel and not susceptable to aging. The 0-rings used in the transmitters are ethylene propylene and will be replaced periodically. Age related electrical component malfunctions will be detected during periodic in plant testing; therefore, the omission of aging is acceptable. In addition, however, a similar Rosemount transmitter is currently undergoing qualification testing to IEEE 323-1974 (including O aging). Upon successful qualificaton, a material comparison will be performed between the two units to demonstrate aging applicability of the new test to the installed equipment. (8) NUREG 0588, Section 2.1, paragraph (3), Category II, subparagraph C states that the basis should be provided for concluding that equipment which could experience environmental conditions of design basis line bre.;k accidents, including steam line breaks, need not function for mitigation cf said accidents, and whose failure (in any mode) is deemed not detrimental to plant safety and need not be qualified for any accident environment. One wide range pressure transmitter (IPT-954B-HR) is located in the fuel handling building where 'igh energy line break accidents can not occur; however, a high radiatice condition could exist as a result of a rod drop accident. The function of the transmitter is to monitor reactor building pressure following a loss of coolant accident (LOCA) or main steam line break accident inside the reactor building. Since the reactor building pressure will not change as a result of a rod drop accident and a rod drop accident is not considered coincident with a LOCA or main steam line break inside the reactor building, the wide range pressure transmitter need r.ot be qualified to the rod drop radiation dose. It should be noted; however, that the transmitter is qualified to the radiation conditions which could exist as a result of a rod drop accident.
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' e 4 0 . B-196 Revision 3 t
DR-58 Rosemount (1) NUREG 0588, paragraph 2.2 (1), Category II, specifies that the failure criteria should be established prior to testing. A Rosemount test plan is not included with the qualification records. The omission of a test plan identifying failure criteria is acceptable since paragraph 4.1 of qualification report #117415, revision B, identifies that the transmitters tested performed within acceptable limits. (2) NUREG 0588, paragraph 2.2 (3) Category II, specifies that the test plan should conform to the guidelines in Section 5.2 of IEEE Standard 323-1971. Paragraph 5.2.3.7 of IEEE Standard 323-1971 requires mounting and connection requirements to be identified. The Rosemount test data does not address mounting or connections of the equipment during the simulated accident test. Mounting of the equipment is critical for seismic qualification; however, since environmental conditions will not induce additional loads on the equipmenc, mounting during LOCA testing will not affect equipment qualification. This equipment will not see a steam break environment simultaneously with its need to function; therefore, the method of connection is not critical. Based on the above, the omission of this information is acceptable. (3) NUREG 0588, paragraph 2.2 (4), Category II, specifies that a single test profile which envelopes the environmental conditions resulting from any design basis event during any mode of plant operation is preferred. The scope of the Rosemount report identifies that this report is intended to qualify equipment for LOCA conditions; however, the steam temperature / pressure curves do not envelope the Virgil C. Summer LOCA curves and the lll equipment was not subjected to spray conditions. The transmitters which were qualified by this report are located outside the reactor building and, therefore, will not be subjected to the inside reactor building LOCA environment. The test environment does envelope the outside of reactor building steam break conditions. The report is therefore acceptable for the application of these transmitters. (4) NUREG 0588, paragraph 2.2 (6), Category II, specifics that when the equipment is exposed to the simulated accident environment, the temperature should be defined by a thermocouple reading or as close as practical to the surface of the component being qualified. The location of the thermocouple is shown in Figure 5 of Rosemount report #117415, revision B. At this location, the thermocouple is reading temperature in the electrical conduit connected to the test chamber. The significant concern of the location of the thermocouple is to assure that the readings are representative of the environment being simulated. The location of the thermocouple is acceptable since the steam inlet to the chamber is remote from the thermocouple location and the thermocouple is sufficiently removed from the chamber to result in conservative temperature readings. l (5) NUREG 0588, paragraph 2.2 (8), Category II, specifies that caustic spray should be incorporated during simulated event testing. The Rosemount qualification program did not include a caustic spray during the steam pressure / temperature testing. The omission of a caustic spray during O B-197 Revision 3 .
DR-58 O V testing is acceptable si ace the transmitters qualified by this program are located outside of the r actor building and will not be subjected to a caustic spray solution. (6) NUREG 0588, paragraph 2.2 (10), Category II, specifies that extremes in power supply voltage range and frequency should be applied during simulated event environmental testing. The Rosemount report does not address the valo s used for the qualification. Since the transmitters are powered from a DC source frequency variations are not applicable. In addition, the power source is electrical Class IE and remote from the steam environment with a maximum output variation of t2 volts. Therefore, the omission of test data for voltage variations does not compromise the equipment qualification. (7) NUREG 0588, paragraph 4 (2), Category II, requires that aging effects be considered. The Rosemount report does not address aging. Major components of the transmitters are stainless steel and not susceptable to aging. The 0-rings used in the transmitters are ethylene propylene and will be replaced periodically. Age related electrical component malfunctions will be detected during periodic in-plant testing; therefore, the omission of aging 4 is acceptable. In addition, however, a similar Rosemount transmitter is currently undergoing qualification testing to IEEE 323-1974 (including aging). Upon successful qualification, a material compariuon will be performed between the two units to demonstrate aging applicability of the new test to the installed equipment. (8) NUREG 0588, paragraph 3 (4), Category II, specifies that margins are to be O ed rer 9 iirvi== a in ent. Paragraph 3 further requires that for post-accident monitoring equipment the 10 percent time margin, identified in Section 6.3.1.5 of IEEE Standard 323-1974 be used. The steam temperature / pressure test was conducted over a 50 hour period. This equipment is located where the environmental extremes to which it may be subjected do not occur simultaneously with the plant conditions which the equipment is intended to monitor; therefore, the equipment is acceptable for its application. t (9) NUREG 0588, Section 2.1, paragraph (3), Category II, subparagraph C states that the basis should be provided for concluding that equipment which could experience environmental conditions of design basis line break accidents, including steam line breaks, need not function for mitigation of said accidents, and whose failure (in any mode) is deemed not detrimental to plant safety and need not be qualified for any accident environment. One wide range reactor building pressure transmitter (IPT-954A-HR) is located in an area subject to an environmental change as a result of a main steam line l break. The function of this transmitter is to monitor reactor building pressure following a loss of coolant accident (LOCA) or main steam line break accident ineide the reactor building. Since the reactor building pressure will not change as a result of a main steam line break outside of the reactor building and a break outside of the reactor building is not considered coincident with a LOCA or main steam line break inside the reactor building, the wide range transmitter need not be qualified to the line break environment. It should be noted; however, that as identified in DR-58, paragraph 3, the transmitter is qualified for the conditions of a , main steam line break outside of the reactor building. B-198 l Revision 3 l
DR-58 (10) NUREG 0588, paragraph 4 (2), Category II, states that a replacement period should be established for replacing equipment and/or materials susceptible to aging. This issue will be addressed in the plant aging program. O l i O B-198a Revision 3
DR-59
./s d NAMCO Limit Switches (1) ' NUREG 0588 paragraph 4 '(9), Category. I, specifies that the qualified life of the equipment and the basis for selection should be defined. The test results do not identify a qualified life period. Heat aging conditions were taken from ANSI Draft' Standard N278.2.1 (Draft 3, Rev. 0). The nonmetallic components of the limit switch are:
- a. contact' block and carrier assemblies - glass filled polyester thermoset plastic
- b. gaskets - nitrile-butadiene
- c. o' rings - EPR i
The significant aging mechanism for the switch is actuation cycles. The ; test switch was subjected to 100,000 actuation cycles without switch , failure. Subsequent tests by NAMCO have shown that the switches can be ' operated up to 3,000,000 cycles. The switches as installed will be subjected to periodic testing to verify operability. If failures are noted in a switch durina plant testing, evaluation to determine if the failure is random or generic will be performed, and appropriate replacements will be implemented. (2) NUREG 0588 paragraph 2.2 (3), Category I, specifies that the test procedure should conform to the guidelines described in Section 6.3 of IEEE O Standard 323-1974. Paragraph 6.3.1 indicates that a test plan should be included. The NAMCO test report is a generic report which documents a test that had been conducted previous to the award of the Virgil C. Summer purchase order. The acceptance of the NAMCo qualification documentation is based on a review of the generic test data as it applies to the Virgil C. Summer station application. Therefore, the omission of a test plan is acceptable. (3) NUREG 0588 paragraph 2.2 (10), Category I, identifies that the expected extremes in voltage and frequency should be applied during testing. NAMCO tested the limit switches using a 100 V DC power supply. Since the limit switches carry the voltage from a qualified Class 1E power source and do not have coils or other components which would require a minimum " pull-in" voltage or be susceptable to frequency variations, testing to a fixed voltage is_ acceptable. (4) NUREG 0588 paragraph 2,2 (6), specifies that when the equipment is exposed to the simulated accident environment, the temperature should be defined by thermocouple readings on or as close as practical to the surface of the component being qualified. The location of the thermocouple used during the test was not identified in the report. The small volume of the test chamber (12" high by 8" in diameter) renders the exact location of the thermocouple insignificant. Therefore, this omission is acceptable. (5) NUREG 0588 paragraph 3 (2), Category I, identifies that ir lieu of other proposed margins.that may be found acceptable, the suggested values O B-199 Revision 3 . 1
DR-59 indicated in IEEE Std. 323-1974, Section 6.3.1.5, should be used as a guide. the NAMCO LOCA envelope includes a margin over the Virgil C. Summer conditions; however, all factors addressed by Section 6.3.1.5 were not used. The NAMCO qualification is based on generic testing rather than the specific Virgil C. Summer conditions. The acceptance of the NAMCO qualification documentation is based on the generic testing conditions enveloping the Virgil C. Summer conditions with sufficient margins for the application's critical parameters. (6) NUREG 0588 paragraph 2.2 (3), Category I, specifies that the test plan should conform to the guidelines in Section 6.3 of IEEE Std. 323-1974. Paragraph 6.3.1.1 (30 required mounting and connection requirements to be identified in the test plan. The NAMCO tcst plan d is not address mountings or connections for LOCA testing. Mounting of the egaipment is critical for seismic qualification; however, since environmental conditions will not induce additional loads on the equipment, mounting during LOCA testing will not affect equipment qualification. The NAMCO test report identifies that the LOCA test chamber set-up was designed to prevent moisture from entering through the conduit connection. Then installed in the plant, the limit switch conduit connection will be hermetically sealed using D. G. O'Brien connectors to prevent moisture from entering the limit switch cover. (7) NUREG 0588 paragraph 5 indicated that "the qualification documentation shall verify that each type of electrical equipment is qualified for its application." The safety related application of the NAMCO limit switch model #EA180 or #EA740 consists of a " seal-in" circuit which maintains g solenoids in a de-energized state after the circuit is interrupted by a w cafety related signal. The power requirements for the solenoids which are in the limit switch circuit vary approximately from 10 watts to 30 watts. The limit switch contact is qualified such that it does not close or that its resistance does not decrease below a value which would energize the load. A minimum contract resistance of 20k-OHM has been selected considering minimum pick-up voltage, power requirements and ample margin. (8) NUREG 0588, paragraph 4. (9) Category 1 stated that qualified life of the equipment should be defined. This issue will be addressed in the plant aging program. (9) NUREG 0588, Section 2.1 paragraph (3), Category I, subparagraph (C) states that the basis should be provided for concluding that equipment which could experience environmentel conditions of design basis line break accidents, including (SLB) and (MSB), need not function for mitigation of said accidents, and whose failure (in any mode) is deemed not detrimental to plant safety and need not be qualified for any accident environment. This equipment could experience a SLB, however, its operation is not required to mitigate the SLB postulated for its location (auxiliary building) nor would the failure of this equipment during an'SLB be detrimental to plant safety. The equipment safety function.is required during a postulated fuel cask drop. Therefore, this equipment need not be qualified to operate during an SLB; however, the available qualification data indicates that this equipment
.is qualified for the SLB as well as the conditions (radiation) associated with a fuel cask drop accident.
B-200 Revision 3 .
f DR-60 1 ASCO Solenoid Valves (1) NUREG 0588 paragraph 2.2 (3), Category I, specifies that the test procedure should conform to the quidelines in Section 6.3 of IEEE Standard 323-1974. Paragraph 6.3.1.1 (7) indicates test equipment requirements should be included in the test plan. The ASCO test plan does not identify test-equipment requirements. Since ASCO report AQO 21678/TR includes test equipment information the omission of requirements from the test plan is acceptable. (2) NUREG 0588 paragraph 2.2.(10), Category I, identifies that the expected extremes in voltage and frequency should be applied durign testing. Since this equipment is designed for de operation, testing to frequency extremes is not applicable. It is not readily determined from the ASCO report that
, the solenoid valves were tested to voltage extremes. The test plan !
performance specifications identify limits of operation as 90 V de to 140 V dc. The " summary of valve performance" table within the test report identifies that .ae valves have passed the performance requirements. Therefore, it can be concluded that the test for voltage extremes is adequate. (3) !!UREG 0588 paragraph 2.2 (6), Category I, specifies that when the equipment is exposed to the simulated accident environment, the temperature should be defined by the.cmocouple readings on or as close as practical to the surface i of the component being qualified. The ASCO report identifies that test i chamber temperature was measured during the qualification to the LOCA j( )' environment; however, the location of thermocouple used during the ti,t was not identified in the report. Due to the long periods of time which were used as holding times, temperatures within the test chamber would have . reached steady-state conditions prior to each step drop in temperature. Since the critical function is that the equipmen; be qualified to a minimum temperature which exceeds the expected accident temperature (which has been demonstrated), and since the temperature reached a steady-state conditons, the , mission of the thermocouple location is acceptable. (4) NUREG 0588 paragraph 2.2 (3), Category I, specifies that the test plan should conform to the guidelines in Section 6.3 of IEEE Standard 323-1974. Paragraph 6.3.1.1 (3) required mounting and connection requirements to be identified in the test plan. The ASCO test plan does not address mountings or connections for LOCA testing, mounting of the equipment is critical for i seismic qualification however, since environmental conditions will not induce additional loads on the equipment, mounting during LOCA testing will l not affect equipment qualification. The ASCO test report identifies > failures due to caustic spray entering through the conduit connection. When installed in the plant, these ASCO solenoid valves (with the ex eption of valve. number XVT2662B) will not be sealed to prevent entrance of moisture; however, the application of the solenoid valves is such that deenergized is the safe position. Therefore, the above will not compromise the equipment suitability for its specific application. Valve XVT2662B is a containment isolation valve which must be energized under accident condition to perform its safety function; therefore, its conduit connection will be sealed to prevent spray or condensate from entering the solenoid enclosure. D - - V B-201 Revision 3
DR-60 O (5) NUREG 0588 paragraph 4 (4), Category I, specifies accelerated aging methods other than Arrhenius methodology may be acceptable if it can be supported by type tests. The accelerated aging program utilizes the 100C rule (i.e. for every 100C rise in temperature above the normal operating temperature, the test time duration is hal"ud). The 100C rule is based on the Arrhenius methodology in IEEE Standard 101A, Appendix B. This is consistent with state of the art methods and, therefore, does not compromise the equipment qualification. (6) NUREG 0588 paragraph 3 (2), Category I, identifies that in lieu of other proposed margins that may be found acceptabic, the suggested values indicated in IEEE Standard 323-1974, Section 6.3.1.5, should be used es a guide. The ASCO LOCA envelope includes a margin over the Virgil C. Summer conditions; however, all factors addressed by Section 6.3.1.5 were not used.
- The ASCO qualification is based on generic testing rather than the specific Virgil C. Summer station conditions. Both the main steam line break and LOCA postulated profile have a quickea temperature rise than the tested profile. The rate of temperature rise for the postulated profiles exceeds the test profile only for a period of seconds, after which the test profile temperatures during the test exceeded the postulated temperature. This deviati)n from the test envelope is acceptable.
(7) NUREG 05o8, paragraph 2.2 (8), Category I, specifies that caustic spray should be incorporated during simulated event testing. The spray pH range for the Virgil C. Summer station is 8.7 to 10.7; however, the tested equipment was subjected to a pH range of 9.5 to 10.5. The postulated spray g solution pH is 10.7 maximum for a period of 65 minutes after which the pH will drop to 8.7 for a period of approximately 30 hours. These deviations are considered acceptable since the ASCO test subjected the solenoid valves to chemical spray throughout the LOCA simulation, whereas, the Virgil C. Summer station spray is for two hours minimum. O
' B-202 Revision 3.
DR-61 Limitorque Valve Operators - Outside Containment, Category C (1) NUREG 0588, paragraph 2.2 (3), Category II, specifies that the test procedure should conform to the guidelines in Section 5.2 of IEEE Std. 323-1971. Paragraph 5.2 requires that the test data accuracy must be specified. The Limitorque qualification report B0003 does not specify the accuracy for the test data, but it does specify that the test equipment has been calibrated by standards which require periodical calibration. Therefore, since adequate conservatism (margins) does exist in test results, the omission of the test data accuracies is acceptable. (2) NUREG 0588, paragraph 2.2 (10), Category II, identifies that the expected extremes in voltage and frequency should be applied during testing. Limitorque tested the valve operators to a voltage extreme only. Since this equipment is not expected to see significant frequency changes in its installed service, testing to a fixed frequency is acceptable. (3) NUREG 0588, paragraph 2.2 (3), Category II, identifies that the test procedure should conform to the guidelines in paragraph 5.2 of IEEE Std. 323-1971. Paragraph 5.2 requires equipment mountings be relevant to performance. The Limitorque report does not address the mountings used for environmental qualification. Mounting of equipment is critical for seismic g alification; however, environmental conditions will not induce detrimental loading at the equipment mounting location. Therefore, the omission of mounting information does not detract from the validity of the qualification. O (4) NUREG 0588, paragraph 2.2 (6), Category II, stated that the temperature should be defined by thermocouple readings on or as close as practical to the surface of the component being qualified. The Limitorque report addresses locations of multiple thermocouples on and within the test chamber, but does not quantify proximity to the component being tested. The information provided is adequate to assure comprehensive temperature measurement and does not invalidate the qualification. (5) NUREG 0588, Section 4, paragraph (5), states that known material phase l changes and reactions should be defined for the accelerated aging program, to insure that no known changes occur within the extrapolation limits. Limitorque knew of no phase changes or reactions associated with the valve actuators when they performed the accelerated aging tests and constructed the 10*C half life plots of thermal regression. Therefore, phase changes and reactions have not been addressed by the qualification report. (6) NIT.EG 0588, Section 2.1, paragraph (3), subparagraph (c) states that the basis should be provided for concluding that equipment which could experience environmencal conditions of design basis line break accidents, including SLB and MSB, through which it need not function for mitigation of said accidents, and whose failure (in any mode) is deemed not detrimental to plant safety, need not be qualified for any accident environment, but is qualified for the non-accident service environment. These valve operators could experience a SLB, but their function in Containment Spray (XVG 3001 l O B-203 Revision 3
DR-61 A,B-SP, XVG 3002 A/B-SP, SVG 3005 A/B-SP), ,.: M RHR ll/X (XVB 9503 A/B-CC), or nonessential coraponent cooling isolation (XVG 9625-CC, XVG 9626-CC, XVB-9524 A/B-CC, XVB 9525 A/B-CC) is not required to mitigate the SLB postulated, nor would the failure of these motor operators during a SLB be detrimental to plant safety. Therefore, these motor operators need not l'e qualified to operate during a SLB. Furthermore, it should be noted that 'he vendor qualification data indicates these motor operators are qualif1-d for a SLB. O 1 l l O 1 B-204 Revision 3
4 - 4s- - -- --+ -,W. a-e a -_g &_ w A a a m -r. ._,am m- - - -- rmm..*, % & - - - - _ _m- ._ a,_ _ DR-62 6 f a (DELETED) 4 , I I i i l I i O t I l I l l I 1 l l l t O B-205 Revision 3 l- - - _ _ . ___-__ _. - ..__ ___ . __ __ , _ . . _ _ _ _ _ _ . . _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ _
m, ---a- ,_-. . ,+n l DR-63 ) l O l l l (DELETED) O' \ l 0 B-206-207 Revision 3
DR-64 V ASCO Solenoid Valves for FH Bldg. Exh. Fan Inlet Isolation Dampers (1) NUREG 0588 paragraph 2.2 (3), Category I, specifies that the test procedure should conform to the guidelines in Section 6.3 of IEEE I Standard 323-1974. Paragraph 6.3.1.1 (7) indicates test equipment requirements should be included in the test plan. The ASCO test plan does not identify test equipment requirements. Since ASCO report AWS 21678/TR includes test equipment information the omission of requirements from the test plan is acceptable. (2) NUREG 0588 ;aragraph 2.2 (10), Category I, identifies that the expected extremes in voltage and frequency should be applied during testing. Since this equipment is designed for de operation, testing to frequency extremes is not applicable. It is not readily determined from the ASCO report that the solenoid valves were tested to voltsge extremes. The test plan performance psecifications identify limits of operation as 90 V de to 140 V dc. The " summary of valve performance" table within the test report identifies that the valves have passed the performance requirements. Therefore, it can be concluded that the test for voltage extremes is adequate. . (3) NUREG 0588 paragraph 2.2 (6), Category I, specifies that when the equipment is exposed to the simulated accident environment, the temperature should be defined by thermocouple readings on or as close as practical to the surface of the component being qualified. The ASCO report identifies the test chamber temperature was measured during t.he qualification dg to the LOCA environment; however, the location of thermocouple used during the test was not identified in the report. Due to the long periods of time which were used as holding times, temperatures within the test chamber would have reached steady-state conditioas prior to each step drop in temperature. Since the critical function is that the equipment be qualified ;o a minimum temperature which exceeds the expected accident temperature (which ha.s been demonstrated), and since the temperature reached a steady-state condition, the omission of the thermocouple location is acceptable. (4) NUREG 0588 paragraph 2.2 (3), Category I, specifies that the test plan should conform to the guidelines in Section 6.3 of IEEE Standard 323-1974. Paragraph 6.3.1.1 (3) requires mounting and connection requirements to be identified in the test plan. The ASCO test plan does not address mountings or connections for LOCA testing. Mounting of the equipment is critical for seismic qualification; however, since environmental conditions will not induce additional loads on the equipment, mounting during LOCA testing will not affect egnpment qualification. The ASCO test report identifies that the LOCA tost chamber set-up was designed to prevent moisture from entering thrcagh the conduit connection. When installed in the plant, these ASCO solenoid valves will cot be sealed to prevent entrance of moisture; however, the application of the solenoid valves is such that deenergized is the safe position. Therefore, the above will not compromise the equipment suitability for its specific application. Therefore, omission of this information from the test plan is acceptable. B-208 l Revision 3 l
DR-64 (5) NUREG 0588 paragraph 4 (4), Category I, specifies accelerated aging methods other than Arrhenius methodology may be acceptable is it can be supported by type tests. The accelerated aging program utilizes the 10*C rule (i.e. for every 10*C rise in temperature above the normal operating teamperatue, the test time duration is haEved). The 10 C rule is based on the Arrhenius methodology in IEEE Standard 101A, Appendix B. This is consistent with the state of the art methods and therefore, does not compromise the equipment qualification. (6) NUREG 0588, Section 2.1, paragraph (3), subparagraph (c), states that the basis should be provided for concluding that equipment which could experience environmental conditions of design basis line break accidents, including SLB and MSB, through which it need not function for mitigation of said accidents, and whose failure (in any mode) is deemed not detrimental to plant safety, need not be qualified for any accident environment, but is qualified for the non-accident service environment. These solenoid valves could experience an SLB, but their operation of the Fuel Handling Building Exhaust Fan Inlet Isolation Dampers is required for the conditions of a fuel cask drop accident, not mitigation of SLB postulated, nor would the failure of these solenoid valves during an SLB be detrimental to plant safety. Therefore, these solenoid valves need not be qualified to operate during an SLB Furthermore, it should be noted that the vendor qualification data indicated these solenoid valves are qualified for an SLB. O O B-209 Revision 3
_.,s a ;s a.-- a- r4a aa+.aa na,a c- a s'.a.- A - a ea-e,,-6-_a >--a I,- 1 1- - - - , --4 n s- A_.M._u - - - - K-4..p -. _,_a,as an__,.n,+,,,_ __a__ DR-65 1 l (DELETED) 1 1 i ! 4 i i i 1 t 1 i !O ' I l t f 1 i l l ( O B-210-211 Revision 3
DR-66 NAMCO I.imit Switches, FH Building Exh. Fan Inlet Iso. Damper (1) NUREG 0588 paragraph 4. (9), Category I, specifies that the qualified life of the equipment and the basis for selection should be defined. The test results do not identify a qualified life period. Ifeat aging conditions were taken from ANSI Draf t Standard N278.2.1 (Draf t 3, Rev. 0). The nonmetallic components of the limit switch are:
- a. contact block and carrier assemblies glass filled polyester thermoset plastic ,
- b. gaskets - nitrile-butadiene
- c. o' rings - EPR The significant aging mechanism for the switch is actuation cycles. The test switch was subjected to 100,000 actuation cycles without switch failure. Subsequent tests by NAMCO have shown that the switches can be operated up to 3,000,000 cycles. The switches as installed will be subjected to periodic testing to verify operability. If failures are noted in a switch during plant testing, esaluation to determine if the fiilure is random or generic will be performed., and appropriate replacements will be implemented.
(2) NUREG 0588 paragraph 2.2 (3), Cat 2 gory I, specifies that the test procedure should conform to the guidelines described in Section 6.3 of IEEE Standard 323-1974. Paragraph 6.3.1 indicates that a test plan should be included. The NAMCO test report is a generic report which documents a test that had g been conducted previous to the award of the Virgil C. Summer purchase order. T The acceptance of the NAMCO qualification documentation is based on a review of the generic test data as it applies to the Virgil C. Summer station application. Therefore, the omission of a test plan is acceptable. . (3) NUREG 0588 paragraph 2.2 (10), Category I, identifies that the expected extremes in voltage and frequency should be applied during testing. NAMCO tested the 'imit switches using a 100 V DC power supply. Since the limit switches carry the voltage from a qualified Class IE power source and do not have coils or other components which would require a minimum " pull-in" voltage or '>e susceptable to frequency variations, testing to a fixed voltage is acceptable. (4) NUREG 0588 paragraph 2.2 (6), specifies that when the equipment is exposed to the simulated accident environment, the 'emperature should be defined by thermocouple readings on or as close as practical to the surface of the component being qualified. The location of the thermocouple used during the test was not identified in the report. The small volume of the test chamber (12" high by 8" in diameter) renders the exact location of the thermocouple insiginificant. Therefore, this omission is acceptable. l l O B-212 Revision 3 .
DR-66 (q,f~ (5) NUREG 0588 paragraph 3 (2), Category I, identifies that in lieu of other proposed margins that may be foand acceptable, the suggested values indicated in IEEE Std. 323-1974, Section 6.3.1.5, should be used as a guide. The NAMCO LOCA envelope includes a margin over the Virgil C. Summer
! conditions; however, all factors addressed by Section 6.3.1.5 were not used.
The NAMCO qualification is based on generic testing rather than the specific Virgil C. Summer conditions. The acceptance of the NAMCO qualification documentation is based on the generic testing conditions enveloping the Virgil C. Summer conditions with sufficient margins for the application's critical parameters. (6) NUREG 0588 paragraph 2.2 (3), Category I, specifies that the test plan should conform to the guidelines in Section 6.3 of IEEE Std. 323-1974. Paragraph 6.3.1.1 (3) requires mounting and connection requirements to be identified in the test plan. The NAMCO test plan does not address mountings or connections for LOCA testing. Mounting of the equipment is critical for seismic qualification; however, since environmental conditions will not induce additional loads on the equipment, mounting during LOCA testing will no: affect equipment qualification. The NAMCO test report identifies that the LOCA test chamber setup was designed to prevent moisture from entering through the conduit connection. When installed in the plant, the limit switch conduit connection will be hermetically sealed using D. G. O'Brien connectors to prevent moisture from entering the limit switch cover. (7) NUREG 0588 paragraph 5 indicates that "the qualification documentation shall verify that each type of electrical equipment is qualified for its " application." The safety related application of the NAMCO limit switch model #EA180 consists of a " seal-in" circuit which maintains solenoids in a
- de-energized state after the circuit is interrupted by a safety related signal. The power requirements for the solenoids which are in the limit switch circuit vary approximately from 10 watts to 30 watts. The limit switch contact is qualified such that it does not close or that its resistance does not decrease below a value which would energize the load. A l minimum contact resistance of 20k-OHM has been selected considering minimum pickup voltage, power requirements and ample margin.
(8) NUREG 0588, Section 2.1 paragraph (3), Category I, subparagraph (C) states that the basis should be provided for concluding that equipment which could experience environmental conditions of desian basis line break accidents, including (SLB) and (MSB), need not function for mitigation of said accidents, and whose failure (in any mode) is deemed not detrimental to i plant safety and need not be qualified for any accident environment. This equipment could experience a SLB, however, its operation is not required to mitigate the SLB postulated for its location (auxiliary building) nor would the failure of this equipment during an SLB be detrimental to plant safety. The equipment safety function is required during a postulated fuel cask . drop. Therefore, this equipment need not be qualified to operate during an SLB; however, the available qualification data indicates that this equipment is qualified for the SLB as well as the conditions (radiation) associated with a fuel cask drop accident. O , B-213 l Revision 3 . l
DR-67 O (DELETED) O
, l B-214-215 Revision 3
l l DR-68 n b Atwood-Morrill 32" Air Operated Solenoid Valve (1) NUREG 0588, paragraph 2.2 (3), Category I, specifies that the guidelines of paragraph 6.3 of IEEE Std. 323-1974 should be followed. Paragraph 6.3.1.1 (7) requires the test equipment requirements, including accuracies, be included in the qualdiation test plan. The Atwood and Morrill Co. test report does not identify test equipment accuracies. This omission is considered acceptable as the qualification report (Appendix A)
' identifies the test equipment used during the testing program. The equipment list identifies manufacturer, model, serial number, and calibration frequency, all of which allows traceability to the manufacturer's data.
(2) NUREG 0588, paragraph 2.2 (3), Category I, identifies that the test procedure should conform to the guidelines of paragraph 6.3 of.IEEE Std. 323-1974. Paragraph 6.3.1.2 requires that equipment mounting simulates expected installation. Mounting during environmental testing did not exactly simulate expected inste11ation. Mounting cf equipment is critical for seismic qualification; however, environments conditions will not induce detrimental loadings on the equipment. Hence, this variance is judged acceptable. (3) NUREG 0588, paragraph 2.2 (10), Category I, specifies that extremes in power supply. voltage range and frequency should be applied during simulated event environmental testing. The Atwood and Morrill report does not address the values used for the qualification. However, as initiation of this equipment is in the de-energized to actuate mode, omission of this data from the test data does not compromise the equipment qualification. (4) NUREG 0588, paragraph 2.2 (3), Category I, specifies that the requirements of paragraph 6.3 of IEEE Std. 323-1974 should be used as a guide. Parigraph 6.3.2 (1) identifies that inspection may be performed to assure that a test unit has not been damaged due to handling since manufacture. The Atwood and Morrill test report does not identify that this inspection was performed. This omission is acceptable as mechanical testing was performed before thermal aging of the equipment, and demonstrated satisfactory performance of the equipment. (5) NUREG 0588, paragraph 4. (5), Category I, states that known phase ch.mges and reactions should be defined to insure that no known changes occur within the extrapolation limits. Atwood and Morrill knew of no phase changes or reactions assoc.ated with this equipment when they performed aging tests. Therefore, phsse changes and reactions have not been addressed by the qualification .w r t . O B-216 Revision 3
DR-69 Hydrogen Analyzer and Remote Control Panel (1) The qualification reports for this equipment are currently under review. (2) NUREG 0588, Section 2.1, paragraph (3), Category II, subparagraph C states that the basis should be provided for concluding that equipment which could experience environmental conditions of design basis line break accidents, including steam line breaks, need not function for mitigation of said accioants, and whose failure (in any mode) is deemed not detrimental to plant safety and need not be qualified for any accident environment. The hydrogen analyzer remote control panels (XPN7258A, XPN77388) and the hydrogen analyzer panel (XPN7215A) are located in an are, subject to an environmental change as a result of a small line break. Hydrogen analyzer XPN7215B is located in the fuel handling building where the harsh environment is radiation. The funicion of the analyzer; however, is to monitor hydrogen concentration of the reactor building atmosphere following a LOCA or main steam line break inside the reactor building. Since the reactor building atmosphere will not change as a result of a small line break outside of the building, the analyzer need not be qualified to the line break environment. The high radiation in the fuel handling building is a result of a rod drop accident. As with the small line break, this accident will not affect the reactor building atmosphere. It should be noted that in addition to the hydrogen analyzer, provisions are provided at the Virgil C. Summer Nuclear Station to manually sample the reactor building atmosphere for hydrogen concentration. This equipment does not see recire. radiation conditions in the fuel handling building or auxiliary building. p O B-217 Revision 3
DR-70 , ~ O c et i t ai a a ai tie ite ! (1) The qualification report for this equipment is under review. The vandor : 3; has been requested to provide addition 1 informatioa. ! i a i , f 4 A i 4 f i t
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E , APPENDIX I PLAN FOR REVIE'd 0F EIIVIRONMENTAL QUALIFICATION OF CLASS IE ELECTRICAL EQUIPME!IT e
.O. y',
Prepared by -
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; - l bel / b'. bC$e l f/E!S/
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i .n (, d /J AUd i Approved by 4 /5/8/ Manag,er, Nuclear Engineering Date uh'k Manager, Quality Assurance a
/Date Yl/ l (Y
Ma'na r, ktl t-V. C. Summer Station l Dhts WS/P]
?ana,er, Quality Control Ul4Dgte
/P) 0
LIST OF EFFECTIVE PAGES l PAGE REVISION kP Title original i original 1 original 2 original 3 original 4 original Figure 1 original l O l h 1 :
, 1.0 PURPOSE 's The purpose of this plan is to provide a method to conduct an independent review of environmental qualification programs to the 4
requirenenoa of NUREG 0588, " Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment". 2.0 SCOPE This plan is to be conducted in accordance with the provisions for preparation of licensing documents provided in the Nuclear Licensing Procedures Manual. This document describes the tasks to be performed to fulfill the purpose of the plan and ider.tifies the organizations responsible for conducting the tasks. At this time, only Class 1E cquipment in harsh environments is being evaluated. 30 REFERENCES 31 HUREG 0588, " Interim Staff Position on Environmental Qualification of Safety Relatel Electrical Equipment"
,, 32 SCE&G/QA Plans 33 SCE&G Nuclear Licensing Procedure HE-101 34 GAI Project Management Manual 35 SCE&G QA Procedure QAP-6, 17, 19, 20, 21 and 23 36 SCE&G Nuclear Operations Procedures Manual
'j . 7 SCE&G QC Procedures Manual 4.0 RESFONSIBILITY Figure 1 identifies the organizations responsible for performing the tasks required by this plan.
,/
50 GENERAL To assure the adequacy of qualification programs to the requirements 9 of NUREG 0588 an independent review of qualification data for Class 1E equipment was planned. The review consists of five major efforts: (1) documentation of environmental qualification program scope, (2) verification of qualification program status, (3) collation of qualification data, (4) establishment of provisions to maintain qualifications, and (5) identify ahortcomings in qualifications programs and initiate corrective actions. The scopo of the environmental qualification program is documented by means of a NUREG 0588 review report submitted to the NRC. An initial verification of the status of environmental qualification programs is performed by SCE&G for equipment under NSSS acope of supply and by Gilbert Accociates, Inc. (GAI, the A/E) for BOP equipment. A final verification is then performed by SCE&G for all Class 1E equipment. If the review of qualification programs reveals the existence of deficiencies, they will be identified; and corrective action will be initiated and documented. A Checklist / Summary Sheet, with entries based on NUREG 0588 requirements (Attachment I), provides a consistent and adequate means to asseso the qualification program against the NUREG reqiirements. In addition, a field inspection of all Class 1E equipment to document the link between tested and installed equipment is necessary to complete the Check 1.ist/ Summary Sheet. Collation of qualifi;ation data will be effected through O establishment of environmental qualification documentation packets to be placed in the Central File at VCSNS. Provisions Lo maintaia qualification of equipment throughout the life of the plant will be incorporated into the VCSNS maintenance procedures. Completion of the tasks identified in this plan will establish the adequacy of qualification programs, identify the need for additional qualification effort, and provide the means to maintain equipment qualified for its intended purpose for the life of the facility. 6.0 PROCEDURE The procedural steps to conduct the independent review are organized by major tasks in the following sections. Figure 1 presents an overview of the review process. T . l t 6.1 Development and Submittal of NUREG 0588 Report A; f GAI has the responsibility to complete a document:for submittai to the NRC using input from (1) SCE&G (Operations) describing the maintenance program as it applies to environmental qualification and (2) SCE&G (Nuclear Engineering and QA) describing the NUREG 0588 independent review effort. The submittal will provide an overview of the qualification program for both NSSS and BOP Class 1E equipment and will address specific issues raised by the NRC during the March 6,1981, audit. , The submittal will be reviewed by SCE&G and comments resolved prior to transmitting it to the NRC. Transmittal of the submittal will be in accordance with the Nuclear Licensing Procedures Manual after completion of verification of equipment status and establishment of'an auditable document file. 6.2 Verification of Qualification Program Status and Establishment of a Document File A' review of qualification programs against the requirements of NUREG 0588 will be conducted by SCE&G (Nuclear Engineering) for NSSS equipment and GAI-for B0P equipment. During the review process an index of the documento necessary to demonstrate qualification will be generated. To maintain an adequate depth ("T of review and consistency, a Checklist / Summary Sheet
\/ (Attachment I) is to be used to document the review. The reviewers shall be familiar with the provisions of NUREG-0588 and applicable IEEE Standards and have ready access to copies of these documents during the review. In all cases, SCE&G must complete the checklists because certain checklist items apply to the inspection of installed Class 1E equipment which will be performed by SCE&G Quality Control personnel, and SCE&G personnel must review and approve the checklist.
The inspection of installed Class 1E equipment will be performed by SCE&G Quality Control personnel using a Field Inspection Checklist (Attachment II). The field inspection will establish (1) a traceable link between the equipment installed at the . plant and the equipment that was qualified, (2) a direct verification that any special installation requirements identified in the qualification program were applied, and (3) a verification that gaskets, seals, protective covers, etc. have been installed. Finally, using the index of qualification documentation generated during the qualification program reviews, a master file of qualification documentation will be established in the Central File by SCE&G (QC) at VCSNS. 13
.Q ..
63 Maintenance of Equipment Qualification To establish requirements for periodic maintenance and O replacement of Class 1E equipment to maintain environmental qualifications, SCE&G (Operations) shall develop / modify existing maintenance procedures to incorporate the information provided by GAI identifying life-limiting components to be replaced and periodic maintenance to be performed to maintain equipment qualifications. GAI is to provide the necessary information to SCE&G by letter. Operations' procedures will address the means by which modifications to qualified equipment will be reviewed for impact on the parent components' qualification status. This ~ information will be fed into the qualification documentation. 7.0 DOCUMENTATION The following Environmental Qualification Documentation documents shall be maintained in the Central File at the VCSNS. 7.1 A copy of this plan 7,2 A copy of each of the SCEtG ITUREG-0588 submittals to the NRC 7.3 Qunlification Documents for Class 1E equipment O O p g -
.,s
(. FI .. /I (s' NUREG 0588 Maintenance n Program Descriptit>n SCE&G (OPS) 16tC (W Info., items from Print & Submit Audit
! to P51C Review submittal _ Resolve Comments _
n 3 25-81gal meeting, etc.) }fCompletesubmittal gal
~ SCE&G INE,QA. OPS) 'SCE&G (NE,QA, OPS) "
SCE&G (NE, NL) F O g EQ Program Description SCE&G (NE, QA) Develop File Index Review and Accept index [h 1 gal m
~
SCE&G (NE) BOP l Final Review & approval Enter j, Review Documents against of documents agalnst Documents g Complete Documentation Review & Check / Sum. Sheets Index & Check / Sum. Sheets 3 1ndex & Check / Sum. Sheets _into File gal J SCE&G (NE,QA, OPS,QC) 4 SCE&G (NE) "SCE&G (QC) fd3 Develop File index ,, Finalize File index i SCE&G (NE) A SCE&G (NE) NS$$ 8 l' Complete Documentation Review f. Check / Sum.Sheetg u SCE&G (NE) Ins e / Verify installed Equipment O SCE&G (0QC, CQC) Develop and Implement section of maintenance / replacement procedure for NUREG 0588 SCE&G (OPS)
SAMPLE FORMAT VIhGIL C. SLY.:ER :nTCLEAR S TATiOM CHfCK/SU:O'ARY S!!EET FOR ENVIRON: ENTAL QUALIFICATION OF ELECTRICAL EQUIP"ENT FOR ::UREG-0538 Original P. O. # Equipnent
Description:
System: Tag Number: , Location of Equipment: Equipmeat Elev.: Flood Level Elev.: Above Flood Level: Yes !!o "an u f a c t u re r : Tested Model/ Serial #: Test qualification Report #: Spec: Function: FSAR Category: (from FSAR Tables 3.11.0 & 3.11.0a) Accident Environeent at Equipment Location: T._ perature Pressure ?clative Humidity Chc.aical Spray _ Radiation ____ Envfroarent for which Equipment is Qualified: g Temperature Pressure Relative Humidity Chemical Spray _ Radiation Qutilified Life: Operating Tire: Specified Accuracy: Specified (Post Accident) Qualified Demonstrated __ Harsh: Non-Harsh: Equipecnt is exempt from qualification, for details see page Equipr.>nt is qualified: Yes ::o (See Notes) Equirrent Qualificatien documentation availabic (NSSS Vendor _ _ _ Central File ) 'otes: ___ _ ATTACHMENT 1
Notes (Cont'vi.) ___ __ _ O The encloser' information has been suenarized from qualification reparts, letters, n.crorandons, etc. and has been reviewed for completeness, adequacy and accuracy us.ag approved procedures. The signatures below certify participation in the gathering of this infor=:stion, the review of its accuracy and conpleteness, and approval for placement in the equipment qualification file. PREPARED BY: DATE: ORG.U:IZATION CHECKED BY: DATE: ORCA'112ATICN APPROVED 3Y: DATE: ORGANIZATION SCESG REVIE'GD BY: DATE: APPROVED BY: D1TE: O
}
s VIRGIL C. SL"CiEn ';UCLEAR STATICN CHECK /SU'OfARY SHEET FOR ENVIP.0::' ENTAL QUALIFICATION OF ELECTRICAL EQUIP!'E:;T FOR SUKEC-0588 O
' NOTE: Iten answred "No" must be justified.
i'"0TE : Specific page, section, paragraph, etc. to be entered if arailable. REPORT sIEST EVALUATION REPORT RE:' ARKS OR NUREG-0538 YES *NO REFEnE:;CE JUSTIFICATIONS 2.0 QUALIFICATION !$THODS 2.1 Selection of Nthods
- a. Do qualification methods conform to IEEE-323-19717
- b. Do qualification methods conform to TEEE-323-74?
- c. If analysis was perforred in liet of testing, was justification provided?
- d. If analysis was performed in liet of testing, was partial type test data provided to support analy-tical assumptions and conclu-siens?
- e. If testing was perforced, did th<
test deconstrate the operability of the equiptent for the time required in the environmental conditions resulting from the accident?
- f. For equipment (safety related or ncn-safety related) that need not to function in order to citi-3 ate any accident, but that must not fail in a manner detricental to plant safety, was it demon-strated that it is capable of withstanding any accident envi-ronrent for the time during which it cust not fail?
- g. Tor equipment that need not func-tien to miti;,te any accident, eas it de 'nstrrted that the eiuip e it , mld r at fall in a anner detrirontal to plant safety?
r i' VIRCIL C. SU':11R NUCLEAR STATION Cl!ECK/ SUE ARY Sl!EET FOR E:iVIR0!!Ei'i.1L QUALIFICATION OF ( ; ELECTRICAL EQUIPMENT FOR SUREC-0538 4:0TE: Item answered ":fo ' must be justified.
?:.0TE: Specific page, section, paragraph, etc. to be entered if available.
REPORT # TEST EVALUATION REPORT REPARKS OR NUREG-0588 YES *NO REFERE:;CE JUSTIFICATIONS 2.2 Qualification by Test
- a. Was failure critoria established befera the test?
- b. For qualification inside contain-ment did test profile envelop a composite LOCA/I!SLB profile?
- c. If equipmene could becoec submer-ged due to flooding, has the
' ability or necessity for submer-ged operation been demonstrated?
- d. Was simulated accident temperature
/~'s defined by thermocouples on or
(_ / near the equipeent or heat analy-sis used?
- c. Uere performance characteristics demonstrated before, during and after the test?
- f. Was the operability status of equipment monitored continuously during tesc or for long term test monitoring jusification provided?
- g. Mas caastic spray of the proper concentration enployed at the pro-per time and duration during the test?
- h. Were expected extremos in power supply voltage ranga and frequen-cy applied during simulated event environnental testing?
- 1. _Uas Cobalt-60 employed for the ganna irradiatien of the equip-ner :7 p
G.
VIRGIL C. SCZER NUCI. EAR STATION CHECK /SCL"ARY SHEET FOR ENVIRON" ENTAL QUALIFICATION OF ELECTRICAL EqUIFMENT FOR ';UREG-0533 O
*;3TE: . Item answered ""o" must be justified. "'0TE:
Specific page, section, paragraph, etc. to be entered if available. REPORT # TEST EVALUATION
~
REPORT REMARKS OR MUREG-0538 yg3 ago REFERENC E JUSTIFICATIONS 2.3 Test Sequence
- a. k'as the adequacy of the test cequence selected, justified?
- b. Did tne test simulate as closely as practicable the postulated environment?
- c. Did the test procedure conform to the suidelines of Section 5 of IEEE-323?
- d. N'ere sequential effects tests used as the qualification nethod?
3.0 "ARGINS lll
- 3. "ere quantified nargins applied to design parareters to assure enveloping of accident conditions?
- b. For equipment which performs its safety function within a short time period (seconds or minutes) was equip.nent demonstrated to re-main functional in accident envi-rennent for at least 1 hour in excess of the tir.e assumed in the accident?
- c. For all other equipment function within a long time pericd was equipment demonstrated to remain functional in accident environ-ncnt within a 107. time margin?
5.0 3GING
- 1. 2a the q:alificatirn program
. n f c cm t o r m qu i r.; a a ts o f I E EE-
~3 -1972 for valve n;araters and IEEE-334-1971 for motors?
h
VIRGIL C. SC:"ER NUCLEAR STATION Ci!ECK/SDNARY SIIEET FOR ENVIRON ENTAL QUALIFICATION OF
.), ELECTRICAL EQUIP:5NT FOR NUREG-0588 ANOTE: Item caswered "No" nust be justified.
F.20TE: Specific page, section, paragraph, etc. to be entered if available. REPORT # TEST EVALUATION REPORT PIMARKS OR NUREC-0588 YES *::0 REFERENCE JUSTIFICATIONS
- b. Fo r n.o to r s and valve operators were aging ef fects considered as per IEEE-323-747
- c. For other equipment, does qualifi -
cation address aging effects?
- d. If susceptible to aging how does this ef fect sch3dule of replac-ing?
5.0 QUALIFICATION DOCDENTATION
- a. Does the qualification documenta-
/~') tion verify that the equiptent is \~/ qualified for its application av neets its speicified performance requirenents?
- b. Is qualification data used to demonstrate equipment qualifica-tion organized in an auditable form?
- c. Does qualification documentation meet the guidelines of IEEE-3237 6.0 EQUIP"ENT INTERFACE
- a. Are there any special qualifica-tion configurations such as rounting, wiring, seals, etc.?
If any, identify or reference in the rcrarks coluen. 7.0 EQUIP:5NT APPLICABILITY
,_ a. Is t!' e a certificate of cen-I ,
nii;* a frca voador which veri-
'~'
f!3s the qualificatica ra; ort versus the equiptent radel nus-bers?
i VIRGIL C. SC SIER 'UCLEAR STATION CHECK /SU""ARY SiiEET FOR ENVIRC:i"E:lTAL QUALIFICATIO:t OF ELECTRICAL EQUIi% NT FOR NUREC-0588 O cOTE: Item ancacred "::o" must be justified.
' . 'OT E : Specific page. section, paragraph, etc. to be entered if availabic. _
RET-G T # TEST EVALU!. TION REPORT RE". ARKS OR NUREC-0588 YES *NO REFERE!CE JUSTIFICATIONS
- b. Were there any failures during qualificatien testing? If so, 111ent ify and is .vidence provid-ed justifying <.cceptance?
3.0 ITE:ts TO 3E C0:tFLETED BY SCESG
- a. Is the test report applicable to as-installed equipment?
- b. Itave the special qualification configuration identified in item 6a. been ret for equipr.ent as installed, if applicab'_e?
O
Sanpin Fort:ut 10UIP:C7r VERIFICATION /INSFD' TIC:: FOP 14 ECUIP:CT I'#2: 05P,8 'IASK GPOUP CnvRIETE CC CC"PIETE
- 1. Equirnent: Itdel # 1. CC Verificd: Itdel #
Tag # Tag #
- 2. Locaticn: Building 2. CC verified Incaticn At:
Elev. 3uilding _,_,_ Colt:rn Line Elev.. or Recm Colt:rn Lire er Pocm
- 3. Ems test report identify any special 2, For sgeific listcd rcquirarents, is irstallaticn or orientation rr_qaire- ._quiprent installed to neet these nunts? rcqaircTents?
O ves O :d O ves 0b O N/A If yes, give specific orientation Pararks: __ _ rcq1ircd or applicable dra.ving: u.:p] tcd Sy: C rplet~3 By:
)
Signature Cate Signature Site Attachment II
l
. APPENDIX II 4
PROCEDURE FOR REVIEW OF CLASS 1E ELECTRICAL EQUIPMIhT FOR COMPLIANCE WITH NUREG 0588 .i l . APPROVED BY: - NM H. com, Pr act Manager DATE: April 7, 1981 Revision 1: April 15,1981 - Approved .> b o - Revision 3 Sheet 1of 21
I AlPENDIX II TABLE OF CONTENTS O Section Title Page
- 1. PURPOSE 1
- 2. SCOPE 1
- 3. DEFINITIONJ 1 3.1 WORK PACKAGE 1 3.2 DEVIt. TION REPORT 1
- 4. RESPONSIBILITY 2
- 5. PROCEDURE 2 5.1 INITIATI ON_ 2 5.2 PREPARATION OF THE NUREG 0588 WORK ShTET 3 5.3 REVIEW 4 5.4 PROCESSING 5 5.5 PREPARATION OF CHECK /
SUMMARY
SHEET 6
- 6. REFERENCES 7 O
Revision 3 Page 2 of 21
APPENDIX II (7 V
- 1. PURPOSE The purpose of this procedure is to provide guidelines for the initiation, preparation, review and processing of the required materials necessary for the preparation of reports on equipment
, qualifications to satisfy the intent of V. C. Summer D.C.P. ,,4.7.1 Processing of Safety Analysis Reports and the V. C. Summer Project Management Manual.
- 2. SE2EE The scope of this procedure is the review of Class lE electrical equipment. for compliance with NUREG 0588, " Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment".
- 3. DEFINITIONS 3.1 30RK PACKAGE - A work package is a compilation of information and contains the following:
A. Completed MUREG 0588 Work Sheet. B. Marked-up copy of IEEE Std. 323-1974 Section 6.3 or 323-1971 Section 5.2. C. Detail Report (if required).
- b. Form " Guideline for Technical Review of the Discussions of Compliance With NUREG 0588 for Equipment Qualified to IEEE 323-1971" or " Guideline IEEE 323-1974".
l 3.2 JE[I6IL REPORT - Detail Report is defined as a report which is l completed utilizing the instructions provided by the Project Engineer when the 1> formation required for column 14 of NUREG 0588 Work Sheet l is not available. t l l Revision 3 Page 3 of 21 l m , --- ,
APPENDIX II O
- 4. RESPONSIBILITY, 4.1 The Project Engineet , or designee, is responsible for appointing:
A. A technically qualified individual as the Originator.
- 3. Technically qualified reviewer for review of the work package for completeness and technical content.
4.2 The Originator is responsible for completing the NUREG 0588 Work Sheet form, signing the ' ' 'deline for Technical Review of the Discussions of Complianc With NUREG 0588 for Equipment Qualified to IEEE 323-1974" form, preparing a Detail Report as directed by the Project Engineer and completing the " Check / Summary Sheet for Environmental Qualificction of Electrical Equipment for NUREG 0588," form. 4.3 The Electrical Department. IGC Department, and Project Management gg are responsible for review of the work package.
- 5. PROCEDURE 5.1 INITIATIGM The Originator obtains a NUREG 0588 Work Sheet form (Attachment I) from the Project Engineer and prepares the form in accordance with Paragraph 5.2.
l l O Revision 3 Page 4 of 21
APPENDIX II
~
. (/)% 5.2 PREPARATION OF THE NUREG 0588 WORK SHEET 5.2.1 The Originator utilizes the following reference information to complete the NUREG 0588 Work Sheet form (Attachment I): A. Columns 1 thecugh 7 are completed utilizing Table 3.11-0a of the Final Safety Analysis Report. B. Column 8 is completed utilizing applicable information provided by the Applied Engineering Analysis and Building Services Proj ect Engineer. C. Columns 9,11 and 13 are completed utilizing the information obtained from the appropriate vendor's qualification report. D. Columns 10 and 12 are completed utilizing the Originator's
/~3 knowledge of the system and available technical information.
V E. Column 14 is completa utilizing the vendor's qualification report. If the required information is r.ot available, the Originator prepares a Detail Report in accordance with the instructions of the Project Engineer. In addition, the Originator marks up a copy of IEEE Standard 323-1971 Section 5.2 or IEEE Standard 323-1974 Sectica 6.3. 5.2.2 Af ter the NUREG 0588 Work Sheet form (.\ttachment I) is completed, the Originator compiles the work package for review. 5.2.3 When the work package has been compiled, the Originator signs the "Guidel.ine for Technical Review of the Discussions of Compliance With NUREG 0588 for Equipment Qualified to IEEE 323-1971 or 1974" form and submits the work package to the Project Engineer for review. 5.2.4 For equipment reviewed subsequent to April 1,1981, preparation of a work package (Attachments I and II) is not required. The procedure 1 , Os outlined by Section 5.5 is sufficient, based upon changes in the i review methodology resulting from discussions with the NRC. Revision 3 Rev. 1: 4-15-81 Page 5 of 21
I l 1 APPENDIX II j l l O 5.3 REVIEW 5.3.1 The Project Engineer, or designee, appoints a technically qualified individual to review the work package. 5.3.2 The appointed reviewer reviews the work package in accordance with the instructions provided on the " Guidelines for Technical Review of the Discussion of Compliance With NUREG 0588 for Equipment Qualified to IEEE 323-1971 or 1974" form (Attachment II). 5.3.3 Af ter the review is completed, the appointed reviewer completes and signs the " Guidelines for Technical Review of the Discussion of Compliance With NUREG 0588 for Equipment Qualified to IEEE 323-1971 or 1974" form. 5.3.4 After the appointed reviewer has reviewed the work package, the following is accomplished: A. If the appointed reviewer has no comments, the work package is forwarded to the Electrical Department, I&C Department and the scoject Management for review. B. If the appointed reviewer has comments, the work package is returned to the Originator for cc-a nt resolution. After the connents have been resolved the work package is returned to the appointed reviewer and if there are no f.rther comments the work package is forwarded to the Electrical Department, I&C Department and the Project Management for review. O Revision 3 Page 6 of 21 APPENDIX II ( )~ c.3.5 After Electrical Department, I&C Department and Project Management have reviewed the work package the following is accomplished: A. If the Electrical Department, I&C Department and Project Management have no comments, the work package is forwarded to Project Office for processing.
- 5. If the Electrical Department, I&C Department, and/or Project Management have comments the work package is returned to the
. Originator for resolution of comments. After the comments have 1 been resolved, ' the work package is returned to the applicable department (s) and if there are no further comments the work package is forwarded to Project Office for processing. ! 5.4 PROCESSING \ 5.4.1 Project Office, utilizing the information on the NUREG 0588 Work Sheet, extracts the information required to satiefy the requirements of NRC letter dated February 22, 1980 and forwards this information to typing. This information is typed in a form as shown on Attachment III. i ! 5.4.2 The typed form, along with the work package, is returned to the I Originator. t i-1 l 5.4.3 The Originator reviews the typed form for completeness, files the work package, and returns the typed form to Project Office. 5.4.4 Project Office distributes the typed form to the client and , i applicable members of the project team. ' l l t i { L Revision 3 ! Page 7 of 21
APPENDIX II O 5.5 PREPAFATION OF CHECK /
SUMMARY
SHEET 5.5.1 The Originator obtains the " Check / Summary Sheet for Environmental Qualification of Electrical Equipment for NUREG-0588" form (Attachment IV) from the Project Engineer. 5.5.2 The originator completes (Attachment IV - Sheet 1) utilizing the information from the NUREG 0588 Work Sheet (Attachment I),if applicabic, 1 (used for revie.s prior to April 1,1981) with the following numbered exceptions: A. Number 1 - Equipment elevation is to be supplied by the client. B. Number 2 - Tested Model/ Serial No. is obtained from the vendor's qualification report. C. Number 3 - Function is obtained from the Originator's knowledge 5.5.3 of the system and available technical information. The Originator completes (Attachment V) utilizing the information in h Column 14 of A';tachment I,if applicable, (dsed for reviews prior to April 1,1981) and the vendor qualification report. 5.5.4 The Originator revisen the Detail Report and the final typed form (Attachment III), if required. 5.5.5 The Originator signs the PREPARED BY section of Actachment IV - Sheet 2 after Attw hment IV - Sheet 1 and Attachment V h..ve been completed. 5.5.6 The Originator forwards the " Check / Summary for En/tronmental Qualification of Electrical Equipment for NUREG 0588" forms (Attachments IV and V), Detailed Reports and, if changed. 1 Attachment III to the Project Engineer for review. 5.5.7 Af ter the review is completed, the Project Engineer makes distribution of the ' Check / Summary for Environmental Q'.:alification of Electrical Equipmer.t for NUREG 0".88" forms, (Attachments IV and V), Detailed Reports and, if changed,..::achment III to the appropriate disciplines for y review. Revision 3 Page 8 of 21 Rev. 1: 4-15-81
APPENDIX II
'fh b
5.5.8 The appropriate discipline project engineers appoint technically qualified individuals to review the "Che:k/ Summary for Invironmental , Qualification of Electricel Equipment for NUREG 0588" forms, (Attachments IV and V), Detailed Reports and, if changed, Attachment III 1 for technical content and accuracy. l 5.5.9 Upon completion of the review, the appointed reviewer, who may be the project engineer, signs the CHECKED BY portion of Attachment IV - ; Sheet 2 and forwards the " Check / Summary for Enviroamental Qualification of Electrical Equipment for NUREG 0588" forms, (Attachments IV and V), ! Detailed Reports and, if changed, Attachment III to the Project 1 Engineer. : 5.5.10 The Project Enginser signs the APPROVED BY portion of Attachment IV - Sheet 2 and submits the package to the Proj ect Office for distribution. . l
- 6. REFERENCFS 6.1 NUREG 0588 " Interim Staff Position on Environmental Qualification of Safety Related Elactrical Equipment".
6.2 GAI Project Management Manual. . 6.3 IEEE Standard 323-1971 and 1974. r ! I i I l i Revision 3 t l Page 9 of 21 i
~
l t Rev. :: 4-15-81 I
APPENDIX II
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2; E, *;* Revision 3 [h:, Psge 10 of 21 9 332
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O n f j v anmEO 954e uusu '#*.ET W.C. SletES used t.As STATION $ beet _5 ef _ Dets __ pres ebilit y Assessey or Seepense Accureep or Reefense Time Reeelnemente flee Deensetreced Queli{lge[los Sege_gt b teethod posseea gt_2d Trip scopensis stem faly resposee Stee General llgggle3M] Time beJere esip/ operate Cycle time (welves) Cyste time (welveep Fell asseracy televsnce poll occuracy tolerance Reyest 1.9. Wese meestoe need (V/u) Tiene eithest feltere
- Bapt. Trees. I.etter $se. Dat e pese oesgles adequete (3/u)
Amelyste Comb. Wee feesteen demo. for ese beer es set mese them Conslausee under sersel Sedered estersey telesence gedeced seeerary tolerance Itethed; Test eemdstlene Jeettlisetten for Itethod @,peated tog. (T/u) Tee big to test but beve pestgat test dese Time et full ersessey sies subject to taCA/SLS or est required to Agtes (4) - Appl 8ee se eelve spesetese, estese. Immsttee and een f all (Cetegory (c) and pad egelgeseg_m{gh gggggig{g goggepglg{g,,gy,pg{pg Ytes et .e4eced ee. Id) 89-) e:es eep ~ ~ t>sel8Elod lite years Wee thessel egleg comeldesed (t/u/ map et replaceaset regetred destes quellited Were operettag sysise seesteered(1/u/edI~ e (Tee /ue) Wee redletlee semeldered (T/ufus) time We =tbretles seenidesed (T/u/u4) ~ Wei yearstette ef tag toep. . Wee .r,be.ios motbe.fects need forsemeldesed ti.esosi .I,s TT7u/ma) -
..f.s. to g1}. m a n 3-i ri te ,,
IEtt 323-l,74 (1/u) ,, (other) Were meterfel phase ebensee censidesed (iful Wee accelerated aging sete jaettfled (t/s) g [g ggging d p (7,d Wee quellised life joettiged (yfu) jygreggtges for q'let Tbte Westeboet pelle etabliebed befese test gggege,gggle. Q
- 1) use ese mesbeheet for each I.ecettee per type of egelpeemt.
(Y
. operabilley (yfu) soste of quelliteetten esplatsed (ftu) d
- 2) there them ese settles el sessene 8 and 9 esy beve to be Test se H Test det 323-l,75 pose. S.3 (T/u) Date le perateena (T/u) emeetated depeedtog en the setegestee listed to setiene S. Test enve eye i lacA and sta
~
Orseelsed to en meditabl U e~re (t/u)
- 3) rmplete eppleasele Stees and llee-e.it men,-eppliesble ese (T/u) pecementattee meets 3tts 313 3373 pose. 3 Qo Test for se f applicable)(T/u) (T/II) to reline.e to, ble it, and 13. Test temp. y TC (T/N) tecumentattom te esse them a senttissate of D
- 4) si et. eve to Lrechste[ ]sefer to paressaph einant. ore of perfossence sbar. sbeck re/ alter /derlos seafermance (T/u) Q uswa assa, t est (vtu) a sprey sendisseee ( pgtgg Opesability moette erleg test (T/M) subjected to entre I welt med fsequency Esplete any "me" steen ebeve er esiy opes tes seer (V/M) elderettene.
Dust addressed if appli ceLett 60 used for tse (t/u) lost sequence adequate ( ) Test almeletee restelesed environ. (V/u t one psetetype tested to sedlet ten, etese and opsey (V/u) (k bu t Dirtinede hd oo < (g pa-
=
Does progree meet st eendes de (V/88) , 8 . tt io. . t..t. em .4 a.i e.at e it m p-o iv/u, - m Y O mW x N y + H H i t 9
GUIDELINE FOR TE. :::ICAL RE'.*!."..? 0F THE APPENDIX II DISCUSSIONS OF COMPLIA';CE */ITH ::UREC 0558 FOR EQUIPSE2;T QUALIFIED TO IEEE 3I3 - 1971 O Oept. _ Sh. No. Originator Revie*4er YES E Fcilure Criteria Addressed? Ov0ry item in Section 5.2 of 323 addressed for testing? Erpreially: Test program outline? Test Monitoring Sensors? Special Conditions Applied? Instrument Traceabili ord / e,essf~a of TC f ., ad*%mWal S f' I Ad quacy of Test Sequence add , sed l l l Evary item in Saction 5 f3 dressed for operating cxperience? Every item in Section 5.4 of 323 addressed for analysis? h' Adcquacy of margins addressed? Stetien 4. (Aging) of NUREG 0588 addressed for motors and valve l l cparators? Component replacement schedule addressed for all other equipment? Categorization of ci and c2 equipment justified? W o PH of spra/ addressed? Comarnts: 9 L f O' Revision 3 Page 12 of 21 .
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- GUIDELINE FOR TECliKICAL REVIEW CT THE APPENDIX II
. DISCUSSIONS OF COMPLIANCE WITH W.' REC 0588 TOR EQUIPMENT QUALIFIED TO IEEE 323 - 1974 Dept. Sh. No.
Originator . i
~
Reviewer , YES 20 yailure Criteria Addressed? Every item"in Sectica 6.3 of 323 addressed for testing? Especially: Test Plan? . Test Equipment Requirements? Instrument Calibration Documentation? .
~
Applied frequency Variations? sf 9 Two Environmental Trans'i O NostSevereTesthuen c1*===1c 1 Post LOCA Ope e-on? ere toc ^t wi,% of fa areatar~s AMI%%U Q. Every item in Section 6.4 of 323 addressed foc operating experience?
.EveryiteminSection6,5of323addressedfora$alysis?
Adequacy of margins addressed? Arrhenius method used or alternate method justi'ied? Phase Changes And Reactions addressed? , j Qualified life justification addresseii? Every item in Section 8 of 323 addressed? Categorization of c1 and c2 squipment justified? Lack of synergiscie effee.cs testinr justified?
. Was PH of spray addressed? !
i COMMENTS: O : I 4
. Ratision 3 l Eage 13 of 21 l l
t
. - _ _ - . . . _ _ . . , _ _,. ~_.I
4 1 ATIACIDiENT III APPENDIX If 1 i ll !! li li li e I !"l lIl I!!is l!st N!ii I ,it: .- tri i
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APPENDIX II ATTACHMENT IV SHEET 1 O V VIRGIL C. SLMfER NUCLEAR STATION , CHECK /3LWfART SHEET FOR ENVIRONMENTAL QUALIFICATION OF I ELECTRICAL EQUIPMENT FOR NUREG-0588 j original P.O. # Equipment
Description:
System: Tag Number: Incation of Equipment: Equipment Elev.: _ Flood Level Elev.: Above Flood Lavel: Tes No j Manufacturer: hTestedModel/Se 1 #: l Test Qualification Report I: _, Spec: A v Function: ory: {
. om AR Tables 3.11.0 & 3.11.0a)
Accident Environment at Equipment Temperature PFess Relative Humidity Chemical Spray Radiation Environment for which Equipment is Qualified: Temperature , Pressure Balative Humidity Chemical Spray Radiation Qualified Life: Operating Time: Specified Accuracy: Specified l (Post Accident) Qualified Demonstrated 1 Harsh: _ Non-Harsh: Equipment is exempt frem qualification, for details see page Equipment is qualified: Tes No (See Notes) Equipment Qualification ccurentation ava11sble (NSSS Vendor _, Central File _) Fotes: l Revision 3 ' Page 15 of 21 _ ._ ,,,,.-r. ,, . . _ _ ...,_,...,,......~._--,e--- -
l APPENDIX II ATTACHME:.T IV SHEET 2 O Notes (Cont'd.) The enclosed information has been sumarized from qualification reports,letr.ers, memorandums, etc. and has been reviewed for complete , adequacy and accuracy l using approved procedures. The signatures belo arti participation in the gtthering of this information, the. revie es curacy and completeness, and typroval for placement in the equA b, qu l ication file.
\ '
PREPARED,3Y: DATE: ORGANIZATION: CHECKED BY: s DATE: ORGANIZATION: APPROVED BY: DATE: ORGANIZATION: SCE&G REVIEWED BY: , __ DATE: l AFPROVED 67: DATE: l O Revision 3
.Page 16 of 21
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l ATTAC19fENT V APPENDIX II O . 4 VIRGIL C. SCO:2", ::UCLEAR STATIO:t CIECX/SU::::AF.! SHIET TOR E: 7IZO::::E :TAL Q'.*ALITICATIO t OF , ELECTRICAL EQUI? :E::T TOR ::CKEG-0538 i
. I
':~0 !: Iten s:.svered ":*o" nest be justified. I t:0!E: 5;scific page, section, paragrsph, etc. to be ence' red if available. !
REPORT fTEST EVALUATIO:t REPORT RZ:4 ARKS OR NUREG-0538 , yg3 .::a grygpan c; aus7tytc27to::s
*;0 QUALIFICATI0 I METHODS j
!;L.5 election of Methods l
- I
- a. Do qualification methods conform I to IEEE-323-19717 l
- b. Do qualification methods conform ' $
co IEEE-323-747 .
. 9
- e. If analysis was performed in liet -
of te' sting, was justification .4 , 0-1 provided? .
- d. If analysis was perfo'rmsd in ,;
of testing, was partial type e dats previded to support analy @ tical assumptions and conclu-sions?
- o. If testing was performed, did tho test demonstrace the operability of the equipment for the time
- required in the environmental conditions resulting from the accident? .
- f. For equipment (safety related or non-safety related) that need not to function in order to miti- -
, gate any accident, but that sust act fail in a manner detrimental to plant safety, was it demon- ! strated that it is capable of l vithstanding any accident envi-roncent for the time during which it. must not fail? j 1
. g. For equip-ent that need not func< -
I tion to nitigste any accident, was it deconstested that the . equipr.ent would noe fail in a nsar.er detri macal to plant Revision 3 safetyt Page 17 of 21
. K1TAGttMt11 V u,Un ' UJ APPENDIX II w .
=
O a' VIRCIL C. SU:::'En ::UCL AR STA!!C:t C1tECK/SU:::!ARY SilEET TOR C:VIRC:::tI:!TAL QUALI71CATIO:: 07
. ELECTRICAL EQUI?::I:'T 70R ::UREG-0558 M:QTZ3 I:cc susvared "fo" must be justified.
J::0TE: Specific pago, sectioni., parsgraph, etc. to be entered if available. REPORT ftTEST EVALUATIO:t RE70RT REMARKS OR JUSTIFICATIO:IS
. HUREG-0588 YES l =NO REFERC:CE
.2 q'ualification by Tese
- c. Waii* failure criteria established i before the test?
b." Tor qualification inside contain-ment did test profile envelop a , con:posite LOCA/MSL3 profile? 1 )
. c. If equiprant could become submer-l god due to fleeding, has the ,
[
- ability or necessity for submer-god operation been demonstrated?
ds was simulated acciden temp a
\ G defined by thermocouples on a near the equipment or heat sis used? -
- c. Vere performance characteristics .
demenstrated before, during and , after the test? .
- f. Was the operability status of equipment monitored continuously c during esst or for long term test monitoring jusification provided?
3 Vas caustic st. ray of the proper concentration employed at the pro - per time and duration during the . ! test? - ; t . : h, Vere expected extremes in power , supply voltage range and frequen-
. cy applied during simulated event .
es.vironmental tesein37 i 1., Was Cobalt 60 employed for the gscma irradiation of the equip-ment?
. j' .
l Revision 3
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ATTACHMENT V (CONT'D) O - VIRCIL C. SU::*ER NUCLF.AR STATICN CHECX/ SCC!ARY SIIEET TCR E::VISON:E :TAL QUALIFICATIJN OF ELECTRICAL EQUI?:E'.:T,FOR NUREG-0533 , GOTIt Item ans ered "No" aust be justified. 3:*0TE: Specific page, section, paragraph, etc. to be entered if available. REPORT FIEST EVALUATION REPORT REMARKS OR NUREG-0538 , YES l at;o ' RITERI::CI JUSTIFICATIcNs
*. 3 Test Sequence
- c. Was the adequacy of the test sequence selected, justified?
- b. Did the test simulate as closely as practicable the postulated
- environment? g S
- s. Did the test procedure conform te the guidelines of Section 5 of
- IEEE-323?
- d. Vere sequential effects tes used as the qualification di k .
- .0 MARGINS
- o. Vere quantified margins applied to design parameters to assure enveloping of accident conditions? , -
- b. For equipment which performs its safety function within a short time period (seconds or minutes) was equipment demonstrated to re- ,
i main functione.1 in accident envi- ', roament for at least I hour in excess of the time assumed in the accidenet
- a. Yor all other equipment function within a long time period was equipment demonstrated to remain functional in accident environ- l ment within a 10% time sargint ACINC
- c. Does the qualifiestion program conform to requirements of IEEE-383-1972 for valve operstors and Revision 3 IEEE-334-1971 for motors? -- -
--Page 19 of 21
APPENDIX II ATTACIDIENT V (CONT'D) O
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VIRGIL C. SU:"!ER !'UCI.IAR STATIO:t CHECX/S:T.::uRY SHEIT TOR C: VIRO::::E::TAL QUALIFICATIO:t OF ELECTRICAL EQUIP::E::T FOR ::UREC-0583 . 6:*0TE: Ices casucred "No" must be justified. f30TE: Specific page, section, parsgraph, etc. to be entered if avail:ble. REPORI fTEST EVALUATIO:t REPORT REMArdtS OR
, NUREG-05SS YES *NO R:.e dlCE JUSTIFICATIONS
- b. For motors and valve operators were aging effects considered as >
per Tm-323-74? I c.. For other equipraent, does qualifd - cation address aging effects? l _
- d. If susceptible to aging how does y
- h this effect schedule of replac-ing? f
\
3.0 QUALIFICATION DOCU}ENTATION ,
- c. Does the' qualification documenta-tion verify that the equipment is qualified for its application anc meets its speicified performance requirements?
- b. Is qualification data used to ,
descastrate equipment qualifica-tion organized in an auditable formt
- c. Does qualification docu=entation meet the guidelines of IIII-3237 ,
i.'O EQUIP)ENT INTERFAt'E .
- c. Are there any special 'qualifica-tion configurstions such as mounting, viring, seals, etc.?
If any, identify or reference in
- I the remarks column.
l
'.0 EQUIP!ENT APPLICABILITT
- c. Is there a certifieste of con- .'
pliance from vendor which veri- , fios the qualification report _ Revision 3 i versus the equipment model num- Page 20 of 21 : . bers? . l t
ATTACIIMENT V (CONT'D) APPENDIX II
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. .- i
.O t
VIRGIL C. SU:OtF.R ::UCf. CAR STATICI CilECK/SCL\RY S11EIT 70R E:: VIRO:::CTAL QUALIFICATION OF
- ELECTRICAL EQUIP:cT FOR ::1 RIG-0588 .
*::0 It Itsu enssered "No" must be justified.
CCTZ3 .S;ccific page. section, parsgrcph, etc. to be entered if available. REFORT 77EST E7ALUAIIC:T REPORT REMARKS OR NURIG-0538 , YES l *NO ,RITERENCE JUSTIFICATIONS
- b. Were there any failures during -
qualification testing? If so. identify and is evidence provid- b ed justifying acceptar.ce? ,
. \
8.01TE :S TO BE CO:TLETID 3Y SCZ&G
- c. Is the test report applicable to as-installed equip: cent?
- b. Have the special qualifi'cacica configuration identified in item 6a. heen met for equipment k *-
installed, if applicablef l i i t 1 l , Revision 3
-~ ~ ~ Page 21 of 21
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