ML20023D233
| ML20023D233 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 05/18/1983 |
| From: | Harrington W BOSTON EDISON CO. |
| To: | Vassallo D Office of Nuclear Reactor Regulation |
| References | |
| 83-131, NUDOCS 8305200259 | |
| Download: ML20023D233 (184) | |
Text
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g BOSTON EpisON COMPANY 800 BOvtsTON STREET BOSTON. mas 5ACHUSETTs 02199 WILLIAM D. HARRlNGTON senson vees pasesosut NUTLsAR May 18, 1983 BECo Letter No.83-131 Mr. Domenic B. Vassallo, Chief Operating Reactors Branch #2 Division of Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C.
20555 I
License No. OPR-35 Docket No. 50-293
Subject:
Environmental Qualification Of Class-IE Electrical Equipment
References:
(1) Letter from D.B.
Vassallo (NRC) to A.V. Morisi (BECo) dated April 13, 1983, " Safety Evaluation for Environmental Qualifi-cation of Safety-Related Electrical Equipment" (BECo 1.83.074).
Dear Sir:
Boston Edison was requested in Reference 1 to provide justification for continued operation for Pilgrim Nuclear Power Station until the environmental qualifica-tion of electrical equipment in four categories is completed. These four equip-ment categories were identified as Categories I.b, II.a, II.b, and IV in the technical evaluation report (TER) attached to Reference 1.
The justification for continued operation for equipment in Categories I.b, II.a, and IV are provided as an attachment to this letter.
These justifications are j
l provided to reflect the concerns addressed in the TER.
The attached justifica-l tions for continued operation support the conclusion that the continued safe operation of Pilgrim is not jeopardized by the qualification deficiencies identi-(
fied in the TER. Additional justification will be prepared, as may be required, as new information is developed.
l l
No justification for continued operation is provided for equipment in Category j
II.b since no equipment in this category exists at Pilgrim.
The Reference 1 letter also requested that Boston Edison provide by May 20, 1983 our plans for qualification or replacement of equipment in Categories I.b, II.a, II.b, and IV and the schedule for accomplishing our proposed corrective actions in accordance with 10CFR50.49(g).
Boston Edison's response to this request is provided under separate cover.
In addition to the above requested information, the safety evaluation provided in l
l Reference 1 contains other items requiring our special attention.
These items shall be addressed in a future letter to the NRC.
Ok 8305200259 830518 PDR ADOCK 05000293 l
P PDR
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BOSTON EDISON COMPANY a
Mr. Domenic B. Vassallo, Chief May 1983 Page 2 As requested in the Reference 1 safety evaluation, Boston Edison performed a review of the TER to identify any portions of the report that still require proprietary protection.
It has been determined that the information in the TER proprietary summary data sheets may now be classified as non-proprietary and may be treated accordingly.
Very truly yours,
Attachment:
Justifications for Continued Operation for Equipment Categories I.b, II.a, and IV
Attachment to BECo letter No.83-131
i FRC EQUIPMENT NO.:
10-1 Boston Edison Equipment No.:
M01400-24B Justification for Continued Operation:
The motor brake does not have sufficient qualification documentation to establish qualification to all parameters.
However, this motor operated valve is not required to actively function (change position) during either a LOCA or a PBOC.
This motor operated valve remains in the open position during system operation and during standby.
Any functional difficulty with the motor brake will be identified during test operation of the valve and corrected, if necessary, at that time.
The lack of i
qualification data for the motor brake will therefore have no affect on system operation and continued plant operation is justified.
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FRC EQUIPMENT NO.'
10-2 Bs;ston Edison Equipment No..
M01400-25B Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Specimen" is because they did not have complete infor-mation regarding the component and the qualification documentation.
The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis) the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, provid-ing justification for specific parameters (if any) satisfies the require-ment for justification for continued operation.
Aging The harsh envi ronment for which this equipment must be qualified resultt from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe environment and therefore, less demanding service.
There was insuffi-cient test documentation to predict a qualified life for this component, however, we are csntinuing our aging evaluations for equipment and as additional components requiring periodic replacement or mairitenance are identified, they will be handled on a case by case basis.
Based on these facts, continued operation of the plant is justified.
Radiation Per Limitorque test report 600376A and accompanying Franklin Institute Report F-C344), and electrge motor with brake similar to this one has been irradiated to 2 x 10 rads with no deleterious effects on brakg operation.
The total integrated dose for this compartment is 1.80 x 10 rads in the service condition.
Based on the results of this test, con-tinued plant operation is justified.
Page 1 of 1
I FRC EQUIPMENT NO.:
11 i
Boston Edison Equipment No.:
H01001-23A l
M01001-26A Justification for Continued Operation:
The motor brake does not have sufficient qualification documentation to establish qualification to all parameters.
However, this motor operated valve is not required to actively function (change position) during a PBOC.
These valves are part of the containment spray mode of RHR, which is not an essential mode either during or post-PBOC.
These valves are normally closed and are required only to stay closed for a PB0C, therefore, it is not required to be qualified - for PBOC environmental conditions.
In the unlikely event of a LOCA, this valve would be available for actuation of p
containment spray before any significant radiation levels outside con-tainment are present. Therefore, continued plant operation is justified.
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FRC EQUIPMENT NO.:
12 Boston Edison Equipment No.:
M01400-25A Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Speciman" is because they did not have complete infor-mation regarding the component and the qualification documentation. The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis) the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, provid-ing justification for specific parameters (if any) satisfies the require-ment for justification for continued operation.
Aging The harsh environment for which this equipment must be qualified results from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe environment and theref ore, less demanding service.
There was insuffi-cient test documentation to predict a qualified life for this component, however, we are continuing our aging evaluations for equipment and as additional components requiring periodic replacement or maintenance are identified, they will be handled on a case by case basis.
Based on these facts, continued operation of the plant is justified.
Radiation Per Limitorque test report 600367A and accompanying Franklin Institute Report F-C3441, and electrge motor with brake similar to this one has been irradiated to 2x 10 rads with no deleterious effects on brakg operation.
The total integrated dose for this compartment is 3.0 x 10 rads in the service condition.
Based on the results of this test, con-tinued plant operation is justified.
Page 1 of 1
FRC EQUIPMENT NO.:
13 Boston Edison Equipment No.:
M01400-24A l
Justification for Continued Operation:
The motor brake does not have sufficient qualification documentation to establish qualification to all parameters.
However, this motor operated valve is not required to actively function (change position) during either a LOCA or a PE0C.
This motor operated valve remains in the open position during system operation and during standby.
Any functional difficulty with the motor brake will be identified during test operation of the valve and corrected, if necessary at that time.
The lack of qualification data for the motor brake will therefore have no affect on system operation and continued plant operation is justified.
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FRC EQUIPMENT NO.:
20 i
Boston Edison Equipment No.:
M01001-23B M01001-26B Justification for Continued Operation:
The motor brake does not have suf ficient qualification documentation to establish qualification to all the parameters listed here. However, this motor operated valve is not required to actively function during a PBOC.
This valve is part of the containment spray mode of RHR which is not an essential mode either during or post PBOC.
This valve is normally closed and required only to stay closed for a PB0C, therefore it is not required to be qualified for PBOC environmental conditions.
In the unlikely event of a LOCA, this valve would be available for actua-tion of containment spray before any significant radiation levels outside containment are present.
Therefore, continued plant operation is justified.
Page 1 of 1
FRC EQUIPMENT NO.:
48 Boston Edison Equipment No.:
SV302-19A l
SV302-19B l
l Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Specimen" is because they did not have complete infor-mation regarding the component and the qualification documentation. The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis), the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, pro-viding justification for specific pa ramete rs (if any) satisfies the requirement for justification for continued operation.
Aging The harsh environment for which this equipment must be qualified results from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe environment and therefore less demanding service. There was insufficient test documentation to predict a qualified life for this component, how-ever, we are continuing our aging evaluations for equipment and as addi-tional components requiring periodic replacement or maintenance are identified, they will be handled on a case by case basis.
Based on these facts, continued operation of the plant is justified.
Page 1 of 2
FRC EQUIPMENT NO.
_ 48 Justification For Continued Operation (Continued):
Radiation From an analysis of the materials of construction, the most limiting material contained in this solenoid is Buna N which has a threshold dose b
of I x 10 rads according to Appendix C of D0R Guidelines.
Based on die fact that the total integrated dose is 2.36 x 105 rads, significant de-gradation would not be expected. Also, extremely conservative assumptions have been used to calculate accident doses.
Based on these facts, con-tinued plant operation is justified.
Humidity In our engineering judgement, exposure to relatively high humidity levels will cause no functional disparities due to weathertight construction.
Therefore, continued plant operation is justified.
Temperature Previous analysis on other plants has shown that the surface temperature of equipment located in a harsh environment more closely follows the dew point temperature than the dry bulb temperature during the event.
This results from the fact that the dominant mode of heat transfer is through condensation. The internal temperature experienced by the component will be even less than the surface temperature due to the thermal resistance of the materials surrounding the critical parts.
Based on the short duration of the transient peak, component failure due to thermal effects is not expected.
Due to fail-safe design, failure of the solenoid valve, electric power, pneumatic device or loss of air pressure does not prevent the valve from moving to the safe position.
This design ensures a high degree of reliability of the valve function.
Based on the conclusions presented here, continued operation is justified.
Pressure The service profile reaches a peak pressure of 16.2 psia and decays to atmospheric pressure within 24 seconds.
In our engineering judgement, exposure to this pressure change will cause no functional disparities due to weathertight construction.
Therefore, continued plant operation is justified.
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FRC EQUIPMENT NO.:
49 Boston Edison Equipment No.:
SV302-20A SV302-20B Justification for Continued Operation:
Temperature / Steam Test / Functional Test The service profile is less severe than the test profile.
The service temperature profile shows a higher peak and faster ramp time than the test profile. The test profile consists of a rise to 212 F in an unspec-ified time with a dwell at 212 F, 100% humidity,.for 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The ser-vice conditions return to below 212 F within 48 seconds.
During the 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, the valve was operated every hour.
In our engineering judgement, the internal temperature of the component will be less during the pre-dicted service event than was experienced in the test.
This is based on preliminary calculations for similar components.
Therefore, the test temperature profile is actually more severe than the service conditions and continued operation of the plant is justified.
Aging The harsh environment for which this equipment must be qualified results from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe environment and therefore, less demanding service.
There was insuffi-cient test documentation to predict a qualified life for this component, however, we are continuing our aging evaluations for equipment and as additional components requiring periodic replacement or maintenance are identified, they will be handled on a case by case basis.
Based on these facts, continued operation of the plant is justified.
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FRC EQL:lP.'!ENT ?.0.
51 Boston Edison Equipment No.
Sol 17 l
S0118 l
l~
Justi f ication for Continued Operation:
Franklin Research Center's determination of a deticienc, in the cater i,
" Documented Evidence of Qualification" and " Adequate Similarity f etw ee:
Equipment and Test Specimen" is because they did not have complete in:.r-motion regarding the component and the qualification documentatio:.
The supporting documents that Boston Edison has listed in previous reports te the NRC do apply to this component.
When Boston Edison completr> t t, qualification of this item (s) (including any necessary analys:s the applicability of those documents vill be conc lusively proven.
I r. cur eneineering judgement, because this is not a hardware deficiency, pre-viding justification for specific parameters (if any) satisfies the requirement for justification f or centinued operation.
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FRC EQUIPMENT NO.:
76 Boston Edison Equipment No..
SV9007 SV9008 l
I Justification for Continued Operation:
These valves have been replaced by new valves (SV9007A&B, SV9008A&B).
Also, Boston Edison has conducted further reviews regarding these valves, which are in the Standby Gas Treatment Deluge System, and determined that they are not required to mitigate neither a LOCA nor a PBOC. Therefore, continued plant operation is justified.
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FRC EQUIPMEN'T NO.
81 Boston Edison Equipment No.:
SV 203-3A SV 203-3B SV 203-3C SV 203-3D Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Specimen" is oecause they did not have complete infor-mation regarding the component and the qualification documentation.
The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis), the applicability of those documents will be conelt:sively proven.
In our engineering judgement, because this is not a hardware deficiency, pro-viding justification for specific parameters (if any) satisfies the requirement for justification for continued operation.
Page 1 of 1
FRC EQUIPMENT NO.:
85 i
Boston Edison Equipment No.:
A0203-1A A0203-1B l
'A0203-1C A0203-1D l
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Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Specimen" is because they did not have complete infor-mation regarding the component and the qualification documentation. The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis), the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, pro-viding justification for specific parameters (if any) satisfies the requirement for justification for continued operation.
Functional Testing Rockwell Manufacturing Company Report No. 2792-03-02 documents that the test valves were cycled during the environmental testing.
The test-chamber was at 340 F and 103 psig.
The valves did cycle.
Therefore, continued operation is justified.
Aging Component materials in the Automatic Valve Corporation C5159 solenoid operated air valve assemblies have been identified.
The monmetallic materials have been evaluated per D0R Guidelines (79-01B) and by applying Arrhenius analysis techniques.
Results of this analysis indicate that the Viton component parts (seals, 0-rings, plungers, U-cups, and pop-pets), the nylon terminal strip, and the silicone rubber lead wire insulation all are insensitive to thermal aging at 152*F (67 C).
The l
Poly-Thermaleze solenoid coil magnet wire insulation is insensitive to thermal aging at its maximum rated temperature of 311*F (155 C).
This temperature was used to allow for heat rise in the normally energized coil.
Page 1 of 2
FRC EQUIPMENT NO.:
85 Justification For Continued Operation (Continued):
The epoxy solenoid coil encapsulant is rated by the manufacturer at 320 F (160 C) (includes 85*C heat rise). The encapsulant's expected life is 24 years and qualified life is 8 years (based on 1/3 expected life).
Re-maining qualified life is 4 years at the encapsulant rated temperature of 320*F (160*C) (
Reference:
Wyle Report No. 17536-3A).
Therefore, con-tinued operation is justified.
Page 2 of 2
FRC EQUIPMENT NO.:
86 Boston Edison Equipment No.:
A0203-2A' A0203-2B A0203-2C A0203-2D Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Specimen" is because they did not have complete infor-mation regarding the component and the qualification documentation. The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis), the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, pro-viding justification for specific parameters (if any) satisfies ' the requirement for justification for continued operation.
Functional Testing Rockwell Manufacturing Company Report No. 2792-03-02 documents that the test valves were cycled during the environmental testing.
The test-chamber was at 340 F and 103 psig.
The valves did cycle.
Therefore, continued operation is justified.
Aging Component materials in the Automatic Valve Corporation C5159 solenoid operated air valve assemblies have been identified.
The monmetallic materials have been evaluated per D0R Guidelines (79-01B) and by applying Arrhenius analysis techniques.
Results of this analysis indicate that the Viton component parts (seals, 0-rings, plungers, U-cups, and pop-pets), the nylon terminal strip, and the silicone rubber lead wire insulation all are insensitive to thermal aging at 152 F (67*C).
The Poly-Thermaleze solenoid coil magnet wire insulation is insensitive to thermal aging at its maximum rated temperature of 311 F (155*C).
This temperature was used to allow for heat rise in the normally energized coil.
Page 1 of 2
FRC EQUIPMENT NO.:
86 Justification For Continued Operation (Continued):
The epoxy solenoid coil en~capsulant is rated by the manufacturer at 320 F (160 C) (includes 85 C heat rise). The encapsulant's expected life is 24 years and qualified life is 8 years (based on 1/3 expected life).
Re-maining qualified life is 4 years at the encapsulant rated temperature of 320*F (160 C) (
Reference:
W le Report No. 17536-3A).
Therefore, con-y tinued operation is justified.
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l FRC EQUIPMENT NO..
_ _8 7 Boston Edison Equipment No.:
P203A P203B P203C P203D Justification for Continued Operation:
These pumps have been environmentally qualified by a combination of testing and analysis, as documented in General Electric Report 492HA166.
Boston Edison retains a copy of the General Electric Report 492HA16.;
which qualifies the G.E.
motors.
It is considered adequate to justify continued operation.
Page 1 of 1
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l FRC EQUIPMENT NO.:
88 4
t Boston Edison Equipment No.:
D7 D8 D9
't
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]
Justification for Continued Operation:
Radiation The Motor Control Center forty year total integrated dose for normal 5
condition plus accident event is 1.3 x 10 rads.
The Motor Control Center has been qualified to a radiation dosage of 4.6 x 10' rads.
The-radiation limiting material in the Motor Contrgl Center is nylon which has a permissible tolerance level of 4.0 x 10 rads.
Based on these
. facts, continued operation of the plant is justified.
Aging The harsh environment for which this equipment must be qualified results from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe environment and therefore less demanding service. There was insufficient test documentation to predict a qualified life for this component, how-ever, we are continuing our aging evaluations for equipment and as addi-tional components requiring periodic replacement or maintenance are identified, they will be handled on a case by rase basis.
Based on these facts, continued operation of the plant is justified.
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FRC EQUIPMENT NO.-
89 Boston Edison Equipment No.':
B17 B20 Justification far Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and "Adequ,te Similarity Between Equipment and Test Specimen" is because they did not have complete infor-mation regarding the component and the qualification documentation.
The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis), the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, pro-viding justification for specific pa rameters (if any) satisfies the requirement for justification for continued operation.
Radiation The Motor Control Center forty year total integr ted dose for normal S
condition plus accident event is 2.7 x 10 rads.
The Motor Control Center Las been qualified to a radiation dosage of 4.6 x 10* rads.
The radiation limiting material in the Motor Contrgl Center is nylon which has a permissible tolerance level of 4.0 x 10 ra ds.
Based on these facts, continued operatien of the plant is justified.
d.ging The harsh environment for which this equipment must be qualified results from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe environment and therefore less demanding service.
There was insufficient test documentation to predict a qualified life for this component, how-ever, we are continuing our aging evaluations for equipment and as addi-tional components requiring periodic replacement or maintenance are identified, they will be handled on a case by case basis.
Based on these i
facts, continued operation of the plant is justified.
Page 1 of 1
FRC EQUIPMENT NO.:
90 Boston Edison Equipment No.:
B18 Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Specimen" is because they did not have complete infor-mation regarding the component and the qualification documentation.
The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis), the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, pro-viding justification for specific parameters (if any) satisfies the requirement for justification for continued operation.
Radiation The Motor Control Center forty year total yntegrated dose for normal condition plus accident event is 1.02 x 10 rads.
The Motor Control Center has been qualified to a radiation dosage of 4.6 x 10" rads. The radiation limiting material in the Motor Contrgl Center is nylon which has a permissible tolerance level of 4.0 x 10 rads.
Based on these facts, continued operation of the plant is justified.
Aging The harsh environment for which this equipment must be qualified results from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe environment and therefore less demanding service. There was insufficient test documentation to predict qualifhJ life for this component, how-a ever, we are continuing our aging evaluations for equipment and as addi-tional components requiring periodic replacement or maintenance are identified, they will be handled on a case by case basis.
Based on these facts, continued operation of the plant is justified.
Page 1 of 1
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FRC EQUIPMENT NO.:
92 i
l Boston Edison Equipment No.:
VAC204A l
VAC204B VAC204C VAC204D Justification for Continued Operation:
Temperature i
The harsh environment in which this equipment must be qualified results from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe environment and, therefore, less demanding service.
The predicted ser-vice conditions following a PBOC are a temperature spike of 248 F at 24 seconds following the break, decaying to 180 F at 2 minutes, 160 F at 8 minutes and stabilizing for 10 minutes before decaying to normal condi-tions.
The motor is a standard A.C.
induction motor with class B insulation having a NEMA standard maximum continuous operating rating of 130 C (266 F).
Due to the short duration of the extreme peak service tempera-ture and rapid decay of the service conditions to normal, it is our engineering judgement that the motor will not exceed the maximum contin-uous operation rating.
Based on this fact, the predicted service condi-tion profile will have little or no effect upon motor operation.
Therefore, continued operation is justified.
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FRC EQUIPtfENT NO :
92 Justification For Continued Operation (Continued):
Radiation l
The harsh environment in which this equipment must be qualified results l
from low probability events.
Events which might reasonably be antici-l pated during this very limited period would lead to a less severe environment and, therefore, less demanding service.
l The materials used for the construction of this motor has been identi-i fied.
The radiation limiting materials are the Polyester enamel and Polyester varnish used as the insulating materials for the motor wind-ings.
These materials constitute the construction of a class B insulat-j ing system.
Class B insulating system for various types of gotors have l
been shown by testing to be capable of withstanding 2 x 10 rads when used in this application.
Based on these facts, continued operation is justified.
Pressure The harsh environment in which this equipment must be qualified results I
from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe environment and, therefore, less demanding service.
The maximum pressure during the accident is 16.2 psia which returns to normal conditions within 15 seconds after the event.
The motor is a dripproof, open case motor which has no pressure retaining parts.
Based on these facts, it is our engineering judgement that no functional dis-parities will occur due to the 16.2 psia pressure spike.
Therefore, continued operation of the plant is justified.
Humidity The harsh environment in which this equipment must be qualified results from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe environment and, therefore, less demanding service.
I The motors are standard class B insulated motors.
Based on the standard type construction of a Polyester enamel coated magnet wire which is then dipped twice in a Polyester varnish after winding, the motors are suit-able for moderate humidity levels.
Once the motors are operating, the stator temperature rise will evaporate any moisture which may collect on i
the windings and preclude the build-up of additional moisture.
Based on these facts, continued operation is justified.
i Page 2 of 3
s FRC EQUIPMENT NO.:
92 i
Justification For Continued Operation (Continued):
Aging The harsh environment for which this equipment must be qualified results from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe environment and therefore less demanding service. There was insufficient test documentation to predict a qualified life for this component, how-ever, we are continuing our aging evaluations for equipment and as addi-tional components requiring periodic replacement or maintenance are identified, they will be handled on a case by case basis.
Based on these facts, continued operation of the plant is justified.
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FRC EQUIPMENT NO.
93 Boston Edison Equipment No.:
VtX210A VEX 210B Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Specimen" is because they did not have complete infor-mation regarding the component and the qualification documentation.
The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis), the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, pro-viding justification for specific parameters (if any) satisfies the requirement for justification for continued operation.
Radiation i
Per information furnished by the motor manufacturer, this motor will per-form its function at a radiation level greater than 5 x 105 rads.
Based on the fact that the total integrated dose is 5.0 x 105 rads, continued plant operation is justified.
Page 1 of 1
FRC EQUIPMENT NO.-
94 Boston Edison Equipment No.:
P215A P215B Justification for Continued Operation:
These pumps have been environmentally qualified by a combination of testing and analysis, as documented in General Electric Report 492}iA166, Boston Edison retains a copy of the General Electric Report 49211A166, which qualifies the G.E.
motors.
It is considered adequate to justify continued operation.
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FRC EQUIPMENT NO.:
98 Boston Edison Equipment No.:
ZT203-1 ZT203-2 ZT203-3 ZT203-4 ZT203-5 ZT203-6 Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Specimen" is because they did not have complete infor-mation regarding the component and the qualification documentation.
The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis', the
)
applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, pro-viding j us t ifica t ion for specific pa ramet ers (if any) satisfies the requirement for justification for continued operation.
Aging The harsh environment for which this equipment must be qualified results from low probability events.
Events which might reasonably be antici-l pated during this very limited period would lead to a less severe environment and therefore less demanding service.
There was insufficient test documentation to predict a qualified life for this component, hov-ever, we are continuing our aging evaluations for equipment and as addi-l tional components requiring periodic replacement or maintenance are l
identified, they will be handled on a case by case liasis.
Based on these facts, continued operation of the plant is justified.
Page 1 of 1
FRC EQUIPMENT NO.:
99 Boston Edison Equipment No.:
Termination (4kV)
Justification for Continued Operation:
Franklin Institute Research Laboratories (FIRL) Test Report F-C3056 and Kerite Report dated June 11, 1971, detail tests on a number of Kerite cable splices that consisted of pre-aging in a hot air oven for 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> at 150*C, irradiation to a level of 100 megarads (1 x 108 rads), followed by a steam / chemical spray exposure lasting 7.5 days.
Based on the above, sound installation practices employed during construc-tion, the compatability of joint insulation with connecting cable materials, periodic megger testing and the fact that all 4kV joints are installed within terminal boxes, the 4kV splice terminations are considered justified for continued operation.
Page l of 1 i
1 FRC EQUIPMENT NO.
100 l
Boston Edison Equipment No.:
Terminations (Less than 4kV)
Justification for Continued Operation:
Ring-tongue terminations of less than 4 kV are metal, which is considered to be age insensitive, with an insulation material, if present, over the shank.
The insulation sleeve material is the only component prone to aging.
As long as the terminations are connected to qualified barrier type ter-minal blocks, insulating one terminal point from another, and installed with adequate electrical clearance between the shanks of terminations on adjacent terminals, failure of the shank insulation would not affect the terminal function.
All terminal blocks that have been identified are considered qualifiable.
Therefore, continued operation is justified.
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FRC EQUIPMENT NO.-
103 i
Boston Edison Equipment No.:
J212 J213 J214 J215 Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Specimen" is because they did not have complete infor-mation regarding the component and the qualification documentation. -The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the i
qualification of this item (s) (including any necessary analysis), the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, pro-viding justification for specific parameters (if any) satisfies the 1
requirement for justification for continued operation.
Page 1 of 1
._c..
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l 1
FRC EQUIPMENT NO.:
104-1 Boston Edison Equipment No.:
J208 J209 J210 J211 Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between
]
Equipment and Test Specimen" is because they did not have complete infor-mation regarding the component and the qualification documentation. The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis), the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, pro-viding justification for specific parameters (if any) satisfies the requirement for justification for continued operation.
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i Page 1 of 1
1 FRC EQUIPMENT NO.:
104-2 Boston Edison Equipment No.:
J216 l
l l
Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Specimen" is because they did not have complete infor-mation regarding the component and the qualification documentation. The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis), the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, pro-viding justification for specific parameters (if any) satisfies the requirement for justification for continued operation, j
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Page 1 of 1
~.
FRC EQUIPMENT NO.:
104-3 Boston Edison Equipment No.:
4 J43 t
344 355~
J56 4
Justification for Continued Operation:
Boston Edison has conducted further reviews regarding these junction boxes.
It has been determined that these junction boxes are not required to mitigate either a LOCA or a PBOC.
Therefore, these junction-boxes have been removed from the Environmental Qualification Master Equipment List.
Based on the above information, continued operation is justified.
i Page 1 of 1
FRC EQUIPMENT NO.:
110 Bosten Edison Equipment No..
C129A (Cable)
C129B (Cable I
Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Specimen" is because they did not have complete infor-mation regarding the component and the qualification documentation.
The supportine documents that Boston Edison maintains in the Central File do apply to this component.
When Boston Edison completes the qualification of this item (s)
(including any necessary analysis), the applicability of those documents will be conclusively proven.
In our engineering judee-ment, because this is not a hardware deficiency, providing justification for specific parameters (if any) satisfies the requirement for justification for continued operation.
Page 1 of 1
FRC EQUIPMENT NO.:
111 Boston Edison Equipment No.
C2256 (Cable)
C2257B (Cable)
Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Specimen" is because they did not have complete infor-nation recarding the component and the qualification documentation.
The supporting documents that Boston Edison maintains in the Central Tile do apply to this component.
When Boston Edison co=pletes the qualification of this item (s)
(including any necessary analysis), the applicabilit:.
of those documents will be conclusively proven.
In our engineering judge-ment, because this is not a hardware deficiency, providing justification for specific parameters (if any) satisfies the requirement for justification for continued operation.
?
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FRC EQUIPMENT NO.: 112 Boston Edison Equipment No.:
C2260 (Cable C2257A (Cable) l I
Justi fication f or Continued Operat ion:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Specimen" is because they did not have complete infor-mation regarding the component and the qualification documentation.
The supporting documents that Boston Edison maintains in the Central File do apply to this component. When Boston Edison completes the qualification of this item (s)
(including any necessary analysis), the applicability of those documents will be cenclusively proven.
In our encineering judee-nent, because this is not a hardware deficiency, providing justificatien f or specific parameters (11 any) satisfies the requirement for justification for continued operation.
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1 Page l of I
FRC EQUIPMENT NO.:
114 Boston Edison Equipment No.:
Cable-1 I
l l
Justification for Continued Operation:
Boston Edison has conducted further reviews on this cable.
This cable has been given an equipment identification number of CX2 Rockbestos.
After reviewing the test documentation supplied by the vendor, Boston Edison has determined that this cable has been environmentally qualified, therefore, continued operation is justified.
Page 1 of 1
FRC EQUIPMENT NO.:
115 Boston Edison Equipment No.:
1 Cable-2 l
l l
i j
Justification for Continued Operation:
i Boston Edison has conducted further reviews regarding this cable and has determined that this cable-is used only in mild environment areas.
]
Therefore, this cable has been removed from the Environmental-Qualifica-tion Master Equipment List.
Based on the above information, continued operation is justified.
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Page 1 of 1
FRC EQUIPMENT NO.:
116 Boston Edison Equipment No.:
i Cable-3 l
l Justification for Continued Operation:
Boston Edison has conducted further reviews regarding this cable and has determined that this cable is used only in mild environment areas.
Therefore, this cable has been removed from the Environmental Qualifica-tion Equipment Master Equipment List.
Based on the above information, continued operation is justified.
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Page 1 of 1
FRC EQUIPMENT NO.:
117 Boston Edison Equipment No.-
Cable-4 Justification for Continued Operation:
Boston Edison has conducted further reviews on this cable.
This cable has been given an equipment identification number of SC16 Rockbestos.
After reviewing the test documentation supplied by the vendor, Boston Edison has determined that this cable has been environmentally qualified, therefore, continued operation is justified.
Page 1 of I
118 FRC EQUIPMENT NO..
Boston Edison Equipment No..
C 2201 (Cable) l Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Specimen" is because they did not have complete infor-mation regarding the component and the qualificatien documentation.
The supporting documents that Boston Edison maintains in the Central File do apply to this component.
When Boston Edison completes the qualification of this item (s)
(including any necessary analysis), the applicabilit:.
of those documents will be conclusively proven.
In our engineering judge-ment, because this is not a hardware deficiency, providing justification for specific parameters (if any) satisfies the requirement for justificatien for continued operation.
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Pagel of1
FRC EQUIPMENT NO..
119 Boston Edison Equipment No..
C2205 (Cable) i l
Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Specimen" is because they did not have complete infor-mation regarding the component and the qualification documentation.
The supporting docunents that Boston Edison maintains in the Central File do apply to this component.
When Boston Edison completes the qualification of this item (s)
(including any necessary analysis), the applicability of these documents will be conclusively proven.
In our engineerint judge-ment, because this is not a hardware deficiency, providing justification for specific parameters (if any) satisfies the requirement for justification for continued operation.
4 Page lof I
FRC EQUIPMENT NO.:
120 Boston Edison Equipment No.:
_C_2206 (Cable) l
{
l Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Specimen" is because they did not have complete infor-mation regarding the component and the qualification documentation.
The supporting documents that Boston Edison maintains in the Central Tile do apply to this component.
When Boston Edison completes the qualification of this itec(s)
(including any necessary analysis), the applicability of those documents will be conclusively proven.
In our engineerinc judge-ment, because this is not a hardware deficiency, providing justificatien for specific parameters (if any) satisfies the requirement for justification for continued operation.
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Pagel of 1
FRC EQUIPMENT NO.:
121 Boston Edison Equipment No..
C2207 (Cable) l l
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Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Sitt11arity Between Equipment and Test Specimen" is because they did not have complete infer-mation regarding the component and the qualification documentatien.
The supporting documents that Boston Edison maintains in the Central rile do apply to this component.
When Besten Edison completes the cualificatien of this item (s)
(including any necessary analysis), the applicabilit'.
of ' hose documents will ?>e conclusively proven.
In our engineering judge-ment, because this is not a hardware deficiency, providing justificatica for specific parameters (if any) satisfies the requirement for justification for centinued operation.
Pagel of 1
FRC EQUIPMENT NO.:
122 Boston Edison Equipment No.:
C2250 (Cable)
Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
'" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Specimen" is because they did not have complete infor-mation regarding the component and the qualification documentation.
The supporting documents that Boston Edison maintains in the Central File do apply to this component. Mien Boston Edison completes the qualification of this item (s)
(including any necessary analysis), the applicability of those documents will be conclusively proven.
In our engineering judge-ment, because this is not a tardware deficiency, providing justification for specific parameters (if any) satisfies the recuirement for justification for continued operation.
p Pagel of I
FRC EQUIPMENT NO.:
123 l
Boston Edison Equipment No.:
C2252 (Cable)
Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
'" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Specimen" is because they did not have complete infor-nation regarding the component and the qualification documentation.
The supporting documents that Boston Edison maintains in the Central Tile do apply to this component. When Bost on Edison completes the qualification of this item (s)
(including any necessary analysic), the applicability of those documents will be conclusively proven.
In our engineering judee-ment, because this is not a hardware deficiency, providing justification for specific parameters (if any) satisfies the requirement for justificatien for continued operation.
Page 1 of 1
FRC EQUIPMENT NO..
125 l
Boston Edison Equipment No.-
Q202A Q202B Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Specimen" is because they did not have complete infor-mation regarding the component and the qualification documentation. The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis), the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, pro-viding justification for specific parameters (if any) satisfies the requirement for justification for continued operation.
Page 1 of 1
FRC EQUIPMENT NO..
126
(
Boston Edison Equipment No.:
Q101A Q101C Justification for Continued Operation:
Franklin Research Center was unable to determine if this item (s) is qual-ified because they did not have complete information regarding the compo-nent and the qualification documentation.
The supporting documents that Boston Edison has listed in previous reports to the h3C do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis) the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, providing justification for specific parameters (if any) satisfies the requirement for justification for continued operation.
Page 1 of 1
FRC EQUIPMENT NO.:
127 l
Boston Edison Equipment No.:
Q101B Q102A 2
Q102B Q103A Q105A Q105B Q106B Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Specimen" is because they did not have complete infor-mation regarding the component and the qualification documentation. The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Poston Edison completes the qualification of this item (s) (including any necessary analysis), the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, pro-viding justification for specific parameters (if any) satisfies the requirement for justification for continued operation.
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j Page 1 of 1
FRC EQUIPMENT NO.
128 Boston Edison Equipment No.:
Q103B Q104J Q104A Q104G Q104B Q104C Q104D Q104E Q104F Q104H Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Specimen" is because they did not have complete infor-mation regarding the component and the qualification documentation. The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis), the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, pro-viding justification for specific parameters (if any) satisfies the requirement for justification for continued operation.
Page 1 of 3
FRC EQUIPMENT NO.:
129 l
l Boston Edison Equipment No..
Q100A Q100B Q100C Q100D Q100E Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Specimen" is because they did not have complete infor-mation regarding the cofr,ponent and the qualification documentation. The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to thi,s component.
Mien Boston Edison completes the qualification of this item (s) (including any necessary analysis), the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, pro-viding justification for specific parameters (if any) satisfies the requirement for justification for continued operation.
Page 1 of I
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l FRC EQUIPMENT NO.:
130 Boston Edison Equipment No.-
PSS16 Justification for Continued Operation:
Boston Edison has conducted further reviews regarding this pressure switch and determined that this pressure switch detects the existence of high or low pressure in the Drywell to help the operator determine when to vent or add nitrogen during normal operation. This pressure switch is not required to mitigate either a LOCA or a PBOC. Therefore, this pres-sure switch has been removed from the Environmental Qualification Master Equipment List.
Based on the above information, continued operation is justified.
Page 1 of 1
FRC EQUIPMENT NO.
131 Boston Edison Equipment No..
LT263-79 Justification for Continued Operation:
This level transmitter provides Reactor Level signal to LR640-28 through a selector switch on C-905.
This transmitter is not required to mitigate either a LOCA or a PBOC.
For reactor level indication, the operators can rely on DPT1001-650A,B which supplies a Reactor Level signal to the Post Accident Monitoring Panel in the Control Room.
DPT1001-650A,B are quali-fied transmitters, therefore, continued operation is justified.
Page 1 of 1
FRC EQUIPMENT NO..
132 Boston Edison Equipment No.-
RE1001-606A Justification for Continued Operation:
Boston Edison has received the applicable reports from General Electric and has determined that the radiation detector has been environmentally qualified.
Therefore, continued operation is justified.
Page 1 of 1
FRC EQUIPMENT NO..
133 l
Boston Edison Equipment No.:
PT654 Justification for Continued Operation:
This Pressure Transmitter does not have sufficient qualification docu-mentation to establish qualification to all the required parameters.
However, this transmitter is not required to mitigate either a LOCA or a PBOC, and therefore will be removed from the Equiprnent Qualification Master Equipment List.
This Pressure Transmitter, PT654, provides a signal to a recorder, PR640-28, for Reactor Pressure.
This recorder would be available for indication to the operator only af ter safe shut-down. Therefore, continued plant operation is justified.
Page 1 of 1
FRC EQUIPMENT NO.:
134 Boston Edison Equipment No..
PT649A PT649B PT649C PT649D Justification for Continued Operaticn:
Boston Edison has conducted further reviews regarding these prer.ure transmitters. These transmitters sense main steam line pressure and send signal, that when combined with the signal from FT645 provides indica-a tion and recording of main steam line flow in the Control Room. Accord-ing to the FSAR Sections 14.7.1.3.3.1 and 14.7.1.5.1.1 the design basis LOCA and PBOC assume that the main steam line isolation valves are com-pletely shut within 10.5 seconds of the accident initiation. Therefore, these transmitters are not required to mitigate either a LOCA or a PBOC and therefore has been removed from the Equipment Qualification Master Equipment List.
Based on the above information, continued plant opera-tion is justified.
Page 1 of 1
FRC EQU 9 MENT NO.:
135 l
Boston Edison Equipment No.:
l TE9019 TE9044 i
4
~
Justification for Continued Operation:
TE9019 4
I Boston. Edison has conducted further reviews regarding this temperature element.
This temperature element ' provides a drywell air temperature i
signal to gage TI-9019 in the Control Room.
It is not required to miti-gate either a LOCA or a PBOC and provides no automatic signals or alarms.
This temperature element will.be removed from the Equipment Qualification j
Master Equipment List.
Therefore, continued operation is justified.
TE9044 Boston Edison has conducted further reviews regarding this temperature element.
This temperature element provides a drywell air temperature j
signal to the red pen of recorder TRU-9044 ir the Control Room.
It is i
not required to mitigate either a LOCA or a PBOC and:provides no auto-matic signals or alarms.
This temperature element will be removed from the Equipment Qualification Master Equipment List.
Therefore, continued opera tion is justified.
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FRC EQUIPMENT NO.-
137 Boston Edison Equipment No.:
RE 1001-607A RE 1001-607B I
Justification for Continued Operation:
Boston Edison has received the applicable reports from General Electric and has determined that the radiation detectors have been environmentally qualified.
Therefore, continued operation is justified.
Page 1 of 1
i FRC EQUIPMENT NO.-
138 i
Boston Edison Equipment No.:
FT645A FT645B FT645C FT645D Justification for Continued Operation:
Boston Edison has conducted further reviews regarding these pressure transmitters.
These transmitters, sense main steam line pressure and send a signal that when combined with the signal from PT649 provides indication and recording of main steam line flow in the Control Room.
According to the FSAR Sections 14.7.1.3.3.1 and 14.7.1.5.1.1 the design basis LOCA and PBOC assume that the main steam line isolation valves are comple'ely shut within 10.5 seconds of the accident initiation.
There-fore, these transmitters are not required to mitigate either a LOCA or a PBOC and therefore, has been removed from the>'* Equipment Qualification Master Equipment List.
Based on the above information, continued plant operation is justified.
Page 1 of 1
l FRC EQUIPMENT NO.
139 Boston Edison Equipment No.:
TS1291-14C TS1291-14D Justification for Continued Operation:
Pressure A similar temperature switch was subjected to 24.7 psia during an en-vironmental test as documented in Fenwal Engineering Lab Report #6350.
That pressure is greater than the pressure to which the installed temper-ature switch might be subjected, therefore, continued operation is justified.
Steam Exposure A similar temperature switch was subjected to saturated steam during an environmental test that is documented in Wyle Report 43854-1. The switch continued to operate satisfactorily.
Therefore, continued operation is justified.
Functional Testing This temperature switch is only required to operate for 90 minutes post-accident.
A similar temperature switch remained functional during and after it was subjected to 575 F (5 times) and then 120 F for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Therefore, continued operation is justified.
Page 1 of 2
l FRC EQUIPMENT NO.:
139 Justification For Continued Operation (Continued):
Aging l
The harsh environment for which this equipment must be qualified results from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe environment and therefore, less demanding service.
There was insuffi-cient test documentation to predict a qualified life for this component, however, we are continuing our aging evaluations for equipment and as additional components requiring periodic replacement or maintenance are identified, they will be handled on a case by case basis.
Based on these facts, continued operation of the plant is justified.
Page 2 of 2
FRC EQUIPMENT NO.:
140 Boston Edison Equipment No.:
TS1360-15A TS1360-15B TS1360-17A l
TS1360-17B Justification for Continued Operation:
Pressure A similar temperature switch was subjected to 24.7 psia during an en-vironmental test as documented in Fenwal Engineering Lab Report #6350.
That pressure is greater than the pressure to which the installed temper-ature switch might be subjected, therefore, continued operation is justified.
Steam Exposure i
A similar temperature switch was subjected to saturated steam during an environmental test that is documented in Wyle Report 43854-1. The switch continued to operate satisfactorily.
Therefore, continued operation is l
justified.
I Functional Testing This temperature switch is only required to operate for 90 minutes post-accident.
A similar temperature switch remained functional during and after it was subjected to 575 F (5 times) and then 120 F for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Therefore, continued operation is justified.
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Page 1 of 2 t
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i FRC EQUIPMENT NO.
140 Justification For Continued Operation (Continued):
Aging The harsh environment for which this equipment must be qualified results from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe environment and therefore, less demanding service.
There was insuffi-cient test documentation to predict a qualified life for this component, however, we are continuing our aging evaluations for equipment and as additional components requiring periodic replacement or maintenance are identified, they will be handled on a case by case basis.
Based on these facts, continued operation of the plant is justified.
Radiation This component has been shown to be qualified to a dose of 1.7 x 10 rads.
An analysis of the material used in the construction of this com-ponent shows the limiting material to be teflon, which is used in the insulation of the lead wires. The lead wire insulation is constructed of four layers consisting of teflon, asbestos, glass, and teflon respective-ly.
Since the asbestos and glass retain 100% of their physical and insulating properties at the expected total integrated dose, and all other materials have a tolerance level of 1.0 x 10 rads or greater, no effect on component performance is anticipated and continued operation of the plant is justified.
Page 2 of 2
l FRC EQUIPMENT NO.-
142 l
Boston Edison Equipment No.:
TSD43 TSD44 Justification for Continued Operation:
The original temperature switches have been replaced by Fenwal tempera-ture switches.
The temperature switches are only required post-LOCA during the time when HPCI is in operation. Normal operation of the HPCI system will prevent fuel damage which would have to occur to obtain significant radiation levels in the HPCI equipment room. A LOCA accident of great enough severity to cause fuel damage woul preclude use of the HPCI system to mitigate this type of accident.
Therefore, the HPCI system will not be subjected to sufficiently high radiation levels to result in functional disparities.
Therefore, continued plant operation is justified.
Page 1 of 1
l FRC EQUIPMENT NO.:
143 Boston Edison Equipment No.
TS1291-14J TS1291-14K
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Justification for Continued Operation:
Pressure A similar temperature switch was subjected to 24.7 psia during an en-vironmental test as documented in Fenwal Engineering Lab Report !!6350.
That pressure is greater than the pressure to which the installed temper-ature switch might be subj ec ted, therefore, continued operation is justified.
Steam Exposure A similar temperature switch was subjected to saturated steam during an environmental test that is documented in Wyle Report 43854-1.
The switch continued to operate satisfactorily.
Therefore, continued operation is justified.
Functional Testing This temperature switch is only required to operate for 90 minutes post-accident.
A similar temperature switch remained functional during and after it was subjected to 575 F (5 times) and then 120 F for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Therefore, continued operation is justified.
Page 1 of 2
FRC EQUIPMENT NO.:
143 Justification for Continued Operation (Continued):
Aging The harsh environment for which this equipment must be qualified results from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe environment and therefore, less demanding service.
There was insuffi-cient test documentation to predict a qualified life for this component, however, we are continuing our aging evaluations for equipment and as additional components requiring periodic replacement or maintenance are identified, they will be handled on a case by case basis.
Based on these facts, continued operation of the plant is justified.
r Radiation The total integrated dose that this component will be exposed to over the 40 year life of the plant is 1.2 x 10' rads.
However, the integrated dose due to plant operation from 1972 to 1985, will be approximately 4.g x 10 rads.
The component has been successfully tested to 1.7 x 10 rads.
The most limiting material in the construction of this component is Teflon which is used for the lead wire insulation.
The Teflon, how-ever has been reinforced by asbestos and glass layers therefore, in-creasing its radiation tglerance level.
All other materials have a tolerance level of I x 10 rads or greater.
Based on these facts, de-gradation due to radiation exposure is not anticipated.
Also, Boston l
Edison performs periodic surveillance on these switches to ensure proper operatio:.
Therefore, continued operation is justified.
i Page 2 of 2
FRC EQUIPMENT NO.:
144 Boston Edison Equipment No.:
TSD47 TSD48 Justification for Continued Operation:
Pressure A similar temperature switch was subjected to 24.7 PSIA during an envi-ronmental test as documented in Fenwal Engineering Lab Report i6350.
That pressure is greater than the pressure to which the installed temper-ature switch might be subjected, therefore, cotinued operation is justified.
Steam Exposure A similar temperature switch was subjected to saturated steam during an environmental test that is documented in Wyle Report 43854-1. The switch continued to operate satisfactorily.
Therefore, continued operation is justified.
Functional Testing A similar temperature switch remained functional during and af ter it was subjected to 575 F (5 times) and then 120 F for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Therefore, continued operation is justified.
Page 1 of 2
FRC EQUIPMENT NO.:
144 _
Justification For Continued Operation (Continued):
Aging The harsh environment for which this equipment must be qualified results from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe environment and therefore, less demanding service.
There was insuffi-cient test documentation to predict a qualified life for this component, however, we are continuing our aging evaluations for equipment and as additional components requiring periodic replacement or maintenance are identified, they will be handled on a case by case basis.
Based on these facts, continued operation of the plant is justified.
Radiation 5
This component has been shown to be qualified to a dose of 1.7 x 10 rads.
An analysis of the material used in the construction of this component shows the limiting material to be teflon, which is used in the insulation of the lead wires. The lead wire insulation is constructed of four layers consisting of teflon, asbestos, glass, and teflon respective-ly.
Since the asbestos and glass retain 100% of their physical and insulating properties at the expected total integrated dose, and all other materials have a tolerance level of 1.0 x 10 rads or greater, no effect on component performance is anticipated and continued operation of the plant is justified.
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FRC EQUIPMENT NO.:
145 Boston Edison Equipment No.:
TS2371A TS2371B TS2373A TS2373B l
i Justification for Continued Operation:
Pressure A similar temperature switch was subj ected to 24.7 psia during an en-vironmental test as documented in Fenwal Engineering Lab Report #6350.
That pressure is greater than the pressure to which the installed temper-ature switch might be subjected, therefore, ~ continued operation is justified.
Steam Exposure A similar temperature switch was subjected to saturated steam during an environmental test that is documented'in Wyle Report 43854-1. The switch continued to operate satisfactorily.
Therefore, continued operation is justified.
Functional Testing This temperature switch is only required to operate for 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> post-accident.
A similar temperature switch remained functional during and after it was subjected to 575 F (5 times) and then 120*F for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Therefore, continued operation is justified.
i Page 1 of 2
FRC EQUIPMENT NO.:
145 l
Justification For Continued Operation (Continued):
i Aging The harsh environment for which this equipment must be qualified results from low probability events.
Events which might reasonably be antici-j pated during this very limited period would lead to a less severe environment and therefore, less demanding service.
There was insuffi-l
_cient cest documentation to predict a qualified life for this component, l
however, we are continuing our aging evaluations for equipment and as additional components requiring periodic replacement or maintenance are identified, they will be handled on a case by case basis.
Based on these facts, continued operation of the plant is justified.
r
. Radiation 5
This component has been shown to be qualified to a dose of 1.7 x 10 rads.
An analysis of the material used in the construction of this component shows the limiting material to be teflon, which is used in the insulation of the lead wires.
The lead wire insulation is constructed of four layers consisting of teflon, asbestos, glass, and teflon respective-ly.
Since the asbestos and glass retain 100% of their physical and insulating properties at the expected total integrated dose, and all other materials have a tolerance level of 1.0 x 10 rads or greater, no effect on component performance is anticipated and continued operation of the plant is justified.
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FRC EQUIPMENT NO.
146 Boston Edison Equipment No.:
TE5047 TE5048 Justification for Continued Operation:
These temperature elements were repl. aced with environmentally qualified Conax temperature elements.
The new equipmerit I.D.
numbers are TE5021-02A and TE5022-04B.
The new temperature elements provide all the functions that TE5047 and TE5048 previously did, therrfore, continued operation is justified.
Page 1 of 1
FRC EQUIPMENT NO.:
147 Boston Edison Equipment No.:
TSD45 TSD46 Justification for Continued Operation:
Pressure A similar temperature switch was subjected to 24.7 PSIA during an envi-ronmental test as documented in Fenwal Engineering Lab Report #6350.
That pressure is greater than the pressure to which the installed temper-ature switch might be subjected, therefore, cotinued operation is justified.
Steam Exposure A similar temperature switch was subjected to saturated steam during an environmental test that is' documented in Wyle Report 43654-1.
The switch.
continued to operate satisfactorily.
Therefore, continued operation is justified.
Functional Testing
. A similar temperature switch remained functional during and af ter it was subjected to 575 F (5 times) and then 120 F for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Therefore, continued operation is justified.
Page 1 of 2
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FRC EQUIPMENT NO.-
147 Justification For Continued Operation (Continued):
Aging The harsh environment for which this equipment must be qualified results from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe environment and therefore, less demanding service.
There was insuffi-cient test documentation to predict a qualified life for this component, however, we are continuing our aging evaluations for equipment and as additional components requiring periodic replacement or maintenance are identified, they will be handled on a case by case basis.
Based on these facts, continued operation of the plsat is justified.
Radiation 5
This component has been shown to be qualified to a dose of 1.7 x 10 rads.
An analysis of the material used in the construction of this component shows the limiting material to be teflon, which is used in the insulation of the lead wires. The lead wire insulation is constructed of four layers consisting of teflon, asbestos, glass, and teflon respective-ly.
Since the asbestos and glass retain 100% of their physical and insulating properties at the expected total integrated dose, and all other materials have a tolerance level of 1.0 x 10 rads or greater, no effect on component performance is anticipated and continued operation of the plant is justified.
Page 2 of 2
FRC EQUIPMENT NO.:
148 l
l t
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Boston Edison Equipment No.:
l A0220-44 (L.S.)
Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Specimen" is because they did not have complete infor-mation regarding the component and the qualification documentation.
The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis), the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, pro-viding justification for specific parameters (if any) satisfies the requirement for justification for continued operation.
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l FRC EQUIPMENT NO.:
149 l
Boston Edison Equipment No.:
l l
HPCI Turb Cont 9 l
l l
Justification for Continued Operation:
The NAMCO D1200-G-2 limit. switch has been replaced with an environmental-ly qualified NAMCO EA180 limit switch. Therefore, continued operation is justified.
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FRC EQUIPMENT NO.:
150 l
Boston Edison Equipment No.:
3 C172 C173 Justification for Continued Operation:
i Aging The harsh environment for which this equipment must be qualified results from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe environment and therefore, less demanding service.
There was insuffi-cient test documentation to predict a qualified life for this component, however, we are continuing our aging evalu.stions for equipment and as additional components requiring periodic replacement or maintenance are identified, they will be handled on a case by case basis.
Based on these facts, continued operation of the plant is justified.
Radiation i
6 A prototype of these panels was irradiated to g value of I x 10 RADS.
The 40 year and LOCA dose is only 1.0 x 10 RADS total, therefore, i
continued operation is justified.
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FRC EQUIPMENT NO.:
152 Boston Edison Equipment No.:
HPCI Turb Cont 1 l
l l
i Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Specimen" is because they did not have complete infor-mation regarding the component and the qualification documentation.
The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison ccmpletes the qualification of this item (s) (including any necessary analysis), the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, pro-viding justification for specific parameters (if any) satisfies the requirement for justification for continued operation.
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FRC EQUIPMENT NO.:
153 Boston Edison Equipment No.:
HPCI Turb Cont 6 i
Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Specimen" is because they did not have complete infor-mation regarding the component and the qualification documentation. The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis), the applicability of those documents will be conclusively proven.
In'our engineering judgement, because this is not a hardware deficiency, prc-viding justification for specific p.a rameters (if any) satisfies the requirement for justification for continued operation.
Page 1 of 1
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FRC EQUIPMENT NO.:
154 Boston Edison Equipment N6.:
i HPCI Turb Cont 5 1
Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Specimen" is because they did not have complete infor-mation regarding the component and the qualification documentation.
The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis), the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, pro-viding justification for specific parameters (if any) satisfies the requirement for justification for continued operation.
T
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Page 1 of 1
FRC EQUIPMENT NO.:
155 Boston Edison Equipment No.:
HPCI Turb Cont 4 Justification for Continued Operation:
Franklin Re::earch Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Specimen" is because they did not have complete infor-mation regarding the component and the qualification documentation. The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis), the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, pro-viding justification for specific parameters (if any) satisfies the requirement for justification for continued operation.
Page 1 of 1
FRC EQUIPMENT NO.:
156 Boston Edison Equipment No.:
KPCI Turb Cont 3 Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Specimen" is because they did not have complete infor-mation regarding the component and the qualification documentation. The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis), the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, pro-viding justification for specific parameters (if any) satisfies the requirement for justification for continued operation.
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FRC EQUIPMENT NO.:
157 Boston Edison Equipment No.:
HPCI Turb Cont 2 Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Specimen" is because they did not have complete infor-mation regarding the component and the qualification documentation. The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis), the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, pro-viding justification for specific parameters (if any) satisfies the requirement for justification for continued operation.
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4 FRC EQUIPMENT NO.:
158 Boston Edison Equipment No.:
HPCI Turb Cont i
Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Specimen" is because they did not have complete infor-mation regarding the component and the qualification documentation.
The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis), the applicability of those documents will be conclusively proven.
In our I
engineering judgement, because this is not a hardware deficiency, pro-viding justification for specific parameters (if any) satisfies the requirement for justification for continued operation.
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FRC EQUIPMENT NO.:
159 Boston Edison Equipment No.:
TS1291-14E TS1291-14F Justification for Continued Operation:
Pressure A similar temperature switch was subjected to 24.7 psia during an en-vironmental test as documented in Fenwal Engineering Lab Report #6350.
That pressure is greater than the pressure to which the installed temper-ature switch might be subjected, therefore, continued operation is justified.
Steam Exposure j
A similar temperature switch was subjected to saturated steam during an environmental test that is documented in Wyle Report 43854-1.
The switch continued to operate satisfactorily.
Therefore, continued operation is justified.
1 Functional Testing This temperature switch is only required to operate for 90 minutes post-accident.
A similar temperature switch remained functional during and after it was subjected to 575 F (5 times) and then 120*F for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Therefore, continued operation is justified.
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FRC EQUIPMENT NO.:
159 Justification For Continued Operation (Continued):
Aging The harsh environment for which this equipment must be qualified results from low probability events.
Events which might reasonably be antici-pated during this very li:aited period would lead to a less severe environment and therefore, less demanding service.
There was insuffi-cient test documentat'en to predict a qualified life for this component, however, we are continuing our aging evalustions for equipment and as additional components requiring periodic replacement or maintenance are identified, they will be handled on a case by case basis.
Based on these facts, continued operation of the plant is justified.
}
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FRC EQUIPMENT NO.:
160 Boston Edison Equipment No.:
TS261-15A TS261-15B TS261-15C TS261-15D Justification for Continued Operation:
Pressure A similar temperature switch was subjected to 24.7 psia during an en-vironmental test as documented iu Fenwal Engineering Lab Report #6350.
That pressure is greater than the pressure to which the installed temper-ature switch might be subj ected, therefore, continued operation is justified.
Steam Exposure A similar temperature switch was subjected to saturated steam during an I
environmental test that is documented in Wyle Report 43854-1. The switch l
continued to operate satisfactorily.
Therefore, continued operation is justified.
i 1
I Functional Testing This temperature switch is only required to operate for 90 minutes post-l accident.
A similar temperature switch remained functicpal during and after it was subjected to 575 F (5 times) and then 120 F for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Therefore, continued operation is justified.
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Page 1 of 2
FRC EQUIPMENT NO.
160 Justification For Continued Operation (Continued):
Sging The harsh environment for which this equipment must be qualified results from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe environment and therefore, less demanding service.
There was insuffi-cient test documentation to predict a qualified life for this component, however, we are continuing our aging evaluations for equipment and as additional components requiring periodic replacement or maintenance are identified, they will be handled on a case by case basis.
Based on these facts, continued operation of the plant is justified.
Radiation Thp 40 year normal operating dose for this component is shown as 3.2 x 10 rads.
Ilowever, Pilgrim #1 has only been operating since 1972, so the maximum radiation exposure hat will be seen by uis coniponent from 1972 5
to 19R5 would be 1.0 x 10 rads.
This component has been tested to 1.7 x 10' rads without significant loss of function.
Therefore, continued plant operation is justified.
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FRC EQUIPMENT NO.:
161 Boston Edison Equipment No.:
TS1360-14C TS1360-14D TS1360-15C TS1360-15D TS1360-16C TS1360-16D TS1360-17C TS1360-17D Justification for Continued Operation:
Pressure A similar temperature switch was subjected to 24.7 psia during an en-vironmental test as documented in Fenwal Engineering Lab Report #6350.
That pressure is greater than the pressure to which the installed temper-ature switch might be subj ected, therefore, continued operation is justified.
f Steam Exposure A similar temperature switch was subjected to saturated steam during an environmental test that is documented in Wyle Report 43854-1. The switch continued to operate satisfactorily.
Therefore, continued operation is justified.
Functional Testing This temperature switch is only required to operate for 90 minutes post-accident.
A similar temperature switch remained functional during and after it was subjected to 575 F (5 times) and then 120*F for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Therefore, continued operation is justified.
Page 1 of 2
FRC EQUIPMENT NO.:
161 Justification For Continued Operation (Continued):
Aging The harsh environment for which this equipment must be qualified results from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe environment and therefore, less demanding service.
There was insuffi-cient test documentation to predict a qualified life for this component, however, we are continuing our aging evaluations for equipment and as additional components requiring periodic replacement or maintenance are identified, they will be handled on a case by case basis.
Based on these facts, continued operation of the plant is justified.
Radiation 5
This component has been shown to be qualified to a dose of 1.7 x 10 rads.
An analysis of the material used in the construction of this com-ponent shows the limiting material to be teflon, which is used in the insulation of the lead wires. The lead wire insulation is constructed of four layers consisting of teflon, asbestos, glass, and teflon respective-ly.
Since the asbestos and glass retain 100% of their physical and insulating properties at the expected total integrated dose, and all other materials have a tolerance level of 1.0 x 10 rads or greater, no effect on component performance is anticipated and continued operation of the plant is justified.
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Page 2 of 2
FPC EQUIPMENT NO.:
162 Boston Edison Equipment No..
TS2371C TS2371D TS2373C TS2373D Justification for Continued Operation:
Pressure A similar temperature switch was subj ected to 24.7 psia during an en-vironmental test as documented in Fenwal Engineering Lab Report #6350.
That pressure is greater than the pressure to which the installed temper-ature switch might be subj ected, therefore, continued operation is justified.
Steam Exposure A similar temperature switch was subjected to saturated steam during an environmental test that is documented in Wyle Report 43854-1.
The switch continued to operate satisfactorily.
Therefore, continued operation is justified.
Functional Testing This temperature switch is only required to operate for 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> post-accident.
A similar temperature switch remained functional during and subjected to 575 F (5 times) and then 120 F for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
after it was Therefore, continued operation is justified.
/
Page 1 of 2
FRC. EQUIPMENT NO.:
162 l
Justification For Continued Operation (Continued):
l Aging The harsh environment for which this equipment must be qualified results from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe i
environment and therefore, less demanding service.
There was insuffi-cient test documentation to predict a qualified life for this component, however, we are continuing our aging evaluations for equipment and as additional components requiring periodic replacement or maintenance are identified, they will be handled on a case by case basis. Based on these i
facts, continued operation of the plant is justified.
Radiation 5
This component has been shown to be qualified to a dose of 1.7 x 10 rads.
An analysis of the material used in the construction of this component shows the limiting material to be teflon, which is used in the insulation of the lead wires. The lead wire insulation is constructed of four layers consisting of teflon, asbestos, glass, and teflon respec:.ive-ly.
Since the asbestos and glass retain 100% of their physical and insulating properties at the expected total integrated dose, and all other materials have a tolerance level of 1.0 x 10 rads or greater, no effect on component performance is anticipated and continued operation of the plant is justified.
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Page 2 of 2
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l FRC EQUIPMENT NO.:
163 Boston Edison Equipment No.:
TS2370C TS2370D l
TS2372C TS2372D 1
4 Justification for Continued Operation:
Pressure A similar temperature switch was subjected to 24.7 psia during an en-vironmental test as documented in Fenwal Engineering Lab Report #6350.
That pressure is greater than the pressure to which the installed temper-ature switch might be subjected, therefore, continued operation is justified.
Steam Exposure A similar temperature switch was subjected to saturated steam during an environmental test that is documented in Wyle Report 43854-1. The switch continued to operate satisfactorily.
Therefore, continued operation is justified.
Functional Testing This temperature switch is only required to operate for 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> post-l accident.
A similar temperature switch remained functional during and after it was subjected to 575 F (5 times) and then 120'F for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Therefore, continued operation is justified.
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FRC EQUIPMENT NO.:
163 Justification For Continued Operation (Continued):
Aging The harsh environment for which this equipment must be qualified results from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe environment and therefore, less demanding service.
There was insuffi-cient test documentation to predict a qualified life for this component, however, we - are continuing our aging evaluations for equipment and as additional components requiring periodic replacement or maintenance are identified, they will be handled on a case by case basis.
Based on these facts, continued operation of the plant is justified.
Radiation 5
This component has been shown to be qualified to a dose of 1. 7 x 10 rads.
An analysis of the material used in the construction of this component shows the limiting material to be teflon, which is used in the insulation of the lead wires. The lead wire insulation is constructed of four layers consisting of teflon, asbestos, glass, and teflon respective-ly.
Since the asbestos and glass retain 100% of their physical and insulating properties at the expected total integrated dose, and all other materials have a tolerance level of 1.0 x 10 rads or greater, no effect on component performance is anticipated and continued operation of the plant is justified.
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I FRC EQUIPMENT NO.:
164 i
Boston Edison Equipment No.:
TS261-16A
,TS261-16B TS261-16C TS261-16D i
Justification for Continued Operation:
Aging The harsh environment for which this equipment must be qualified results from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe environment and therefore, less demanding service.
There was insuffi-cient test documentation to predict a qualified life for this component, however, we are continuing our aging evaluations for equipment and as additional components requiring periodic replacement or maintenance are identified, they will be handled on a case by case basis.
Based on these facts, continued operation of the plant is justified.
Steam Exposure t
A similar temperature switch was subjected to saturated steam during an environmental test that is documented in Wyle Report 43854-1. The switch continued to opera te satisfactorily.
Therefore, continued operation is justified.
Functional Testing i
l This temperature switch is only required to operate for 90 minutes post-accident.
A similar temperature switch remained functional during and after it was subjected to 575*F (5 times) and then 120*F for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
l Therefore, continued operation is justified.
1 Page 1 of I I_
. = - -
FRC EQUIPr!ENT N9.:
165 Boston Edison Equipment No.:
T1
-s f
1 Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Speciman" is because they did not have complete infor-mal ion regarding the component and the qualification documentation.
The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis) the applicability of those documents will be conclusively proven. Also, this equipment has not yet been placed in operation.
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l FRC EQUIPMENT NO.:
166 l
l Boston Edison Equipment No.:
TS1291-14G TS1291-14H Justification for Continued Operation:
Pressure A similar temperature switch was subjected to 24.7 psia during an en-vironmental test as documented in Fenwal Engineering Lab Report #6350.
That pressure is greater than the pressure to which the installed temper-ature switch might be subjected, therefore, continued operation is justified.
_ Steam Exposure A similar temperature switch was subjected to saturated steam during an environmental test that is documented in Wyle Report 43854-1.
The switch continued to operate satisfactorily.
Therefore, continued operation is justified.
Functional Testing This temperature switch is only required to operate for 90 minutes post-l accident.
A similar temperature switch rwained functional during and L
after it was subjected to 575 F (5 times) and then 120 F for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Therefore, continued operation is justified.
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Page 1 of 2
FRC EQUIPr!ENT NO.
166 Justification For Continued Operation (Continued):
Aging The harsh envirorment for which this equipment must tw qualified results from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe envir-onment and therefore, less demanding service There was insufficient test documentation to predict a qualified life for this component, how-ever, we are continuing our aging evaluations for equipment and as addi-tional components requiring periodic replacement or maintenince are identified, they will be handled on a case by case basis.
Based on these f act s, continued operation of the plant is justified.
Radiation The total integrated dose that this component will be exposed to from 5
1972 to 1985 will be 2.&6 x 10 rads.
The component has been success-3 fully tested to 1.7 x 10 rads.
The most limiting material in the con-struction of this component is Teflon which is used for the lead wire insulation.
The Teflon, however, has been reinforced by asbestos and glass layers therefore, increasing its radiatign tolerance level.
All other materials have a tolerance level of I x 10 rads or greater.
Based on these facts, degradation due to radiation exposure is not anticipated.
Also, Boston Edison performs periodic surveillance on these temperature switches to ensure proper operation.
Therefore, continued operation is justified.
Page 2 of 2
FRC EQUIPMENT NO.:
172 i
Boston Edison Equipment No.:
I DPIS 261-2A DPIS 261-2J DPIS 261-2B DPIS 261-2K DPIS 261-2C DPIS 261-2L DPIS 261-2D DPIS 261-2M DPIS 261-2E DPIS 261-2N DPIS 261-2F DPIS 261-2P i
DPIS 261-2G DPIS 261-2R DPIS 261-2H DPIS 261-2S Justification for Continued Operation:
f The Differential Pressure Switches do not have sufficient qualification documentation for all parameters.
These switches have two possible modes of failure.
In the event the switches were to fail epen, the Main Steam Isolation Valves (MSIV's) would automatically close, causing an alarm and possible scram assuring safe plant shutdown.
4 Under a fail closed condition and a main steam line break (MSLB), area hi-temperature switches would close the MSIV's and cause a scram.
In addition, Area Radiation Monitors would also trip MSIV's if sufficiently high levels occured.
Based on these conclusions, the Differential Pressure Switches are justified for continued plant operation.
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FRC EQUIPMENT NO.-
174 Boston Edison Equipment No..
DPIS261-12A DPIS261-12B M=
Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the categery
- Do cumen t e d Evidence of Qualification" and " Adequate Similarity between Equipment and Test Speciman" is because they did not have complete infor-mation regarding the component and the qualificatica documentation.
Tne supporting documents that Boston Edison has listed in previous reports tc.
the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analys2s) the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, prcvid-ing justification for specific parameters (if any) satisfies the require-ment for justification for continued operation.
Page 1 of 1
FRC EQUIF?fENT NO.:
175 Boston Edison Equipment No.:
DPIS261-12D DPIS261-39B DPIS261-36A DPIS261-36B DPIS261-37A DPIS261-37B DPIS261-38A DPIS261-38B DPIS261-39A Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Speciman" is because they did not have complete infor-mation regarding the component and the qualification documentation. The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
Mien Boston Edison completes the qualification of this item (s) (including any necessary analysis) the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, provid-ing justification for specific parameters (if any) satisfies the require-ment for justification for continued operation.
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Page 1 of 1 I
I FRC EQUIPMENT NO.:
176 Boston Edison Equipment No.:
DPIS1001-79B 4
Justification for Continued Operation:
1 Aging The harsh environment for which this equipment must be qualified results from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe environment and therefore, less demanding service.
There was incuffi-cient test documentation to predict a qualified life for this component, however, we are continuing our aging evaluations for equipment and as additional components requiring periodic replacement or maintenance are identified, they will be handled on a case by case basis.
Based on these facts, continued operation of the plant is justified.
Pressure The service profile reaches a peak of 16.2 psia, whereas the test pres-sure reaches a maximum of 7" H O (14.95 psi).
The service profile is 2
above 14.95 psia for approximately 18 seconds.
Based on this fact and due to the weathertight construction of this instrument, in our engineer-ing judgement no functional disparities will occur.
Therefore, continued plant operation is justified.
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FRC EQUIPf!ENT NO..
1/6 Justification For Continued Operation (Continued):
Radiation The total integrated pccident dose plus 40 year normal dose for this component is 1.15 x 10 rads.
The test radiation exposure as reported in 6
the referenced test report is 3x 10 rads.
3ased on the successful results of this test and considering the extremely conservative assump-tions used in calculating the accident doses, significant radiation degrada tion is not anticipated.
Therefore, continued plant operation is justified.
Temperature The Service profile is less severe than test temperature profile.
Peak service temperature of 248*F is higher than the test tempe ra tu re of 212 F.
However, the time duration that the service temperature is above 212 F is less than one minute.
The test 'emperature is /. bout 40'E higher than the service profile for the remainder of the test period (6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />).
In our engineering judgement the internal ter.perature under the service condition will not reach the test temperature of 212 F.
This is based on preliminary calculations for similar components.
Therefore, the tempera-ture profile in the test report is actually more severe than the service tempera t u re profile and, continued operation of the plant is justified.
I Steam Exposure A prototype of this component iras subjected to 100% humidity for 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
In our engineering judgement, this test was more severe than the environ-ment to which this enmponent may be subjected to during an accdent, 1
therefore, ccntinued operation is justified.
Page 2 of 2
FRC EQUIPMENT NO.:
177 Boston Edison Equipment No.:
DPIS261-12C Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Speciman" is because they did_not have complete infor-mation regarding the component and the qualification documentation.
The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis) the applicability of those - documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, provid-ing justification for specific parameters (if any) satisfies the require-ment for justification for continued operation.
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l-l FRC EQUIPMENT NO.:
178 Boston Edison Equipment No.:
DPIS 2301-2352 DPIS 2301-2353 Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Specimen" is because they did not have complete infor-mation regarding the component and the qualification documentation.
The supporting docu.ments that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis), the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, pro-viding justification for specific pa rameters (if any) satisfies the requirement for justification for continued operation.
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FRC EQUIPMENT NO.:
179 Boston Edison Equipment No.:
i l
l DPIS12.43 l
l D__PIS 1244 i
Justification for Continued Operation:
Aging The harsh environment for which this equipment must be qualified results from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe environment and therefore, less demanding service.
There was insuffi-
)
cient test documentation to predict a qualified life for this component',
however, we are continuing our aging evaluations for equipment and as additional components' requiring periodic replacement or maintenance are identified, they.will be handled on a case by' case basis.
Based on these facts, continued operation of the plant is justified.
Steam Exposure i
A prototype of this component was subjected to 100% humidity for 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
In our engineering judgement, this test was more severe than the environ-ment to which this component may be subjected to during an accdent, therefore, continued operation is justified.
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t FRC EQUIPMENT NO.:
179 Justification For Continued Operation (Continued):
Temperature Service profile is less severe than test temperature profile.
Peak service temperature of 248*F is higher than the test temperature of 212 F.
However, the time duration that the service temperature is above 212*F is less than one minute. The test temperature is about 40*F higher than the service profile for the remainder of the test period (6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />).
12 our engineering judgement the internal temperature under the service condition will not reach the test temperature of 212*F.
This is based on preliminary calculations for similar components. Therefore, the tempera-ture profile in the test report is actually more severe than the service temperature profile and continued operation of the plant is justified.
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~_
rRC EQUIPMENT NO.:
180 i
4
-FRC EQUIPMENT NO.:
Boston Edison Equipment No.:
DPIS1001-79A l
4 i
o Justification for Continued Operation:
Aging The harsh environment for which this equipment must be qualified results from low probability evente.
Events which might reasonably be antici-pated during this very -limited period would lead to a less severe environment and therefore, less demanding service.
There was insuffi-i cient test documentation to predict a qualified life for this component, however, we are continuing our aging evaluations for equipment and as additional components requiring periodic replacement or maintenance are j
identified, they will be handled on a case by case basis.
Based on these l
facts, continued operation of the plant is justified.
Pressure The service profile reaches a peak of 16.2 psia, whereas the test pres-sure reaches a maximum of 7" HO (14.95 psi).
The service profile is 2
above 14.95 psia for approximately 18 seconds.
Based on this fact-and due to the weathertight construction of this instrument, in our engineer-l ing judgement no functional disparities will occur. Therefore, continued l
plant operation is justified.
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FRC EQUIPMENT NO.-
180 Justification For Continued Operation (Continued):
Radiation The total integrated, accident dose plus 40 year normal dose for this component is 1.14 x 10 rads.
The test radiation exposure as reported in 6
the referenced test report is 3x 10 rads.
Based on the successful results of this test and considering the extremely conservative assump-tions used in calculating the accident doses, significant radiation degradation is not anticipated.
Therefore, continued plant operation is justified.
Temperature Service profile is less severe than test t empe ra tu re profile.
Peak service temperature of 248 F is higher than the test temperature of 212 F.
However, the time duration that the service temperature is above 212 F is less than one minute. The test temperature is about 40 F higher than the service profile for the remainder of the test period (6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />).
In our engineering judgement the internal temperature under the service condition will not reach the test temperature of 212 F.
This is based on preliminary calculations for similar components. Therefore, the tempera-ture profile in the test report is actually mere severe than the service temperature profile and continued operation of the plant is justified.
Steam Exposure A prototype of this component was subjected to 100% humidity for 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
In our engineering judgement, this test was more severe than the environ-ment to which this component may be subjected to during an accdent, therefore, continued operation is justified.
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FRC EQUIPMENT NO.:
181 Boston Edison Equipment No.:
PS1451A PS1464A Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Speciman" is because they did not have complete infor-mation regarding the component and the qualification documentation. The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis) the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, provid-ing justification for specific parameters (if any) satisfies the require-ment for justification for continued operation.
Aging The harsh environment for which this equipment must be qualified results from low probability events.
Events which might rea.sonably be antici-pated during this very limited period would lead to a less severe environment and therefore, less demanding service.
There was insuf fi-cient test documentation to predict a qualified life for this component, however, we are continuing our aging evaluations for equipment and as additional components requiring periodic replacement or maintenance are identified, they will be handled on a case by case basis.
Based on these facts, continued operation of the plant is justified.
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FRC EQUIPMENT NO.-
181 Justification For Continued Operation (Continued):
Pressure The service profile reaches a peak of 16.2 psia, whereas the test pres-sure reaches a maximum of 7" H,30 (14.95 psia).
The service profile is above 14.95 psia for approximately 18 seconds.
Based on this fact and due to the weathertight construction of this instrument, in our engineer-ing judgement no functional disparities will occur. Therefore, continued plant operation is justified.
Radiation From an analysis of the materials for construction, the nonmetallic materials in these switches have been determined to have a threshold dose 6
of 1 x Ig rads. The 40 year normal operating dose for this component is 1.4 x 10 rads.
However, the maximum expected 41ose due to normal oper-ation from 1972 to 1985 would be 4.6 x 10" rafs.
This radiation exposure, combined with an accident dose of 1.7 x 10 rads, results in a total integrated dose of 1.7 x 10* rads.
In our engineering judgement, sufficient degradation to cause a variation in component performance will not occur at a radiation level this close to the threshold dose of these materials.
Therefore, continued plant operation is justified.
Temperature The service profile is less severe than the test profile.
Tf.e peak service temperature of 248 F is higher than the test temperature of 212 F.
However, the titue duration that the service temperature is above 212 F is about 48 seconds.
In our engineering judgement, the internal temperature under the service condition will not reach the test t empe ra -
ture of 212 F.
Therefore, the test temperature profile in the test report is actually more severe and continued plant operation is justi-fied.
Steam Exposure / Functional Test A pressure switch similar to this component. was exposed to steam during environmental testing, and during that time was functionally tested, therefore, continued operation is justified.
Test Duration A pressure switch similar to this component was tested for approximately 6.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> at 212 F and another 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> at temperatures between ambient and 212 F.
The installed pressure switch is only required for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> post-accident, therefore, continued operation is justified.
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FRC EQUIPMENT NO.:
182 Boston Edison Equipment No.:
PS1001-104C PS1001-104A PS1001-93A PS1001-93C Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Specimen" is because they did not have complete infor-mation regarding the component and the qualification documentation.
The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis), the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, pro-viding justification for specific parameters (if any) satisfies the requirement for justification for co;1tinued operation.
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I FRC EQUIPMENT NO.-
183 Boston Edison Equipment No.:
PS261-23A PS261-23B Justification for Continued Operation:
Franklin kescarch Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Speciman" is because they did not have complete infor-mation regarding the component and the qualification documentation. The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis) the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, provid-ing justification for specific parameters (if any) satisfies the require-ment for justification for continued operation.
1 Aging The harsh environment for which this equipment must be qualified results from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe environment and therefore, less demanding service.
There was insuffi-cient test documentation to predict a qualified life for this component, however, we are continuing our aging evaluations for equipment and as additional components requiring periodic replacement or maintenance are i
identified, they will be handled on a case by case basis.
Based on these I
facts, continued operation of the plant is justified.
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Page 1 of 2
t FRC EQUIPMENT N0.:
183 Justification For Continued Operation (Continued):
Steam Exposure Pressure switches similar to these pressure switches were subjected to a steam environment during environmental. testing. 'The switches continued to function while in the steam environment, therefore, continued - opera-tion is justified.
-Temperature The service profile is less severe than the test profile.
The service temperature peak has a faster ramp time but returns to normal condition in approximately 6 minutes.
In our engineering judgement, the internal temperatue of the component will be less during the predicted service event than was experienced during the test.
This is based on preliminary calculations for similar components.
Therefore, the test temperature profile in the test is actually more severe than the service condition and continued oepration of the plant is justified, f
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FRC EQUIPMENT NG.
184 Boston Edison Equipment No..
PS8135 s'S8136 Justification for Continued Operation:
The function of these pressure switches is as follows:
Upon initiation of a Secondary Containment Isolation both trains of the Standby Gas Treatment System (SBGTS) are started.
After a preset time delay the appropriate switch upon sensing normal header pressure in the fan exhaust duct, automatically trips the selected standby fan.
The selected fan will remain in the standby mode and upon the pressure switch sensing low exhaust duct pressure, which is indicative of a loss of the selected operating train, a SBGTS trouble alarm will be initiated in the Control Rooat and the standby fan will be restarted.
Failure of this switch would require the standby fan to be tripped manually from the Control Room after system initiation and restarted manually from the Control Room on exhaust duct low pressure.
Failure of this switch would place the SBGTS in a more conservative situation since both trains will continue to operate af ter system initiation.
There is a separate indication in the Control Room for SBGTS filter overload and exhaust duct flow.
Therefore, this component is not required essential for SBGTS operati en and contin-ued plant opertion is justified.
Page 1 of 1
i FRC EQUIPMENT NO.-
185 i
Boston Edison Equipment No.:
HPCI TURB CONT 8 Justification for Continued Operation:
Franklin Research Cen'.er's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Speciman" is because they did not have complete infor-mation regarding the component and the qualification documentation. The supporting documents that Boston Fdison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any.ecessary analysis) the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, provid-ing justification for specific parameters (if any) satisfies the require-i ment for justification for continued operation.
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FRC EQU1PMENT NO.
186 Boston Edison Equipment No..
PS263-53A PS263-52A Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" a id " Adequate Similarity Betweer Equipment and Test Specimen" is because they did not have complete infor-mation regarding the component and the qualification documentation.
The supporting documents that Boston Edison has listed in previous reports te the NRC do apply to this component.
When Boston Edison completes the qualification of this ittm(s) (including any necessary analysis), the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, pro-viding justification for specific parameters (if any) satisfies the requirement for justification for continued operation.
Page 1 of 1
FRC EQUIPMENT NO.-
187 I
Boston Edison Equipment No.:
PS263-49A PS263-50A Justi.fication for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Speciman" is because they did not have complete infor-mation regarding. the component and the qualification documentation. The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis) the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, provid-ing justification for specific parameters (if any) satisfies the require-ment for justification for continued operation.
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188-1 FRC EQUIPMENT NO.:
Boston Edison Equipment No.:
PS263-51A PS263-51B Justification for Continued Operation:
Boston Edison has conducted further reviews regarding this pressure switches.
The function of these switches is to aid start-up and testing by preventing a scram, below 600 PSIG from Main Condenser Low Vacuum and Main Steam Isolation Valve Closure.
Therefore, these switches are not required to mitigate either a LOCA or a PBOC and therefore, they have been removed from the Equipment Qualification Master Equipment ' List.
Based on the above information, continued plant operation is justified.
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FRC EQUIPMENT NO :
188-2 Boston Edison Equipment No.:
PS263-55A PS263-55B Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Speciman" is because they did not have complete infor-mation regarding the component and the qualification documentation.
The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis) the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, provid-ing justification for specific parameters (if any) satisfies the require-ment for justification for continued operation.
Aging i
The harsh environment in which this equipment must be qualified results l
from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe environment and therefore, less demanding service.
There was insuffi-cient test documentation to predict a qualified life for this component, l
however, we are continuing our aging evaluations for equipment and as l
additional components requiring periodic replacement or maintenance are identified, they will be handled on a case by case basis.
Based on these facts, continued operation of the plant is justified.
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FRC EQUIPMENT NO.:
188-2 Justification For Continued Operation (Continued):
Steam Exposure Pressure switches similar to these pressure switches were subjected to a steam environment during environmental testing.
The switches continued to function while in the steam environment, therefore, continued opera-tion is justified.
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FRC EQUIPMENT NO..
189-1 Boston Edison Equipment No.:
PS1001-90A PS1001-90C Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Speciman" is because they did not have complete infor-mation regarding the component and the qualification documentation.
The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis) the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, provid-ing justification for specific parameters (if any) satisfies the require-ment for justification for continued operation.
Page 1 of 1
FRC EQUIPMENT NO.:
189-2 Boston Edison Equipment No.:
PS1001-89C Justification for Continued Operation:
Franklin Resear.h Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Speciman" is because they did not have complete infor-mation regarding the component and the qualification documentation.
The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessa ry analysis) the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, provid-ing justification for specific parameters (if any) satisfies the require-ment for justification for continued operation.
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l FRC EQUIPMENT NO.:
190 Boston Edison Equipment No.:
PS512A PSS12B Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similterity Between Equipment and Test Speciman" is because they did not have complete infor-mation regarding the component and the qualification documentation.
The supporting documents 'that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis) the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, provid-ing justification for specific parameters (if any) satisfies the require-ment for justification for continued operation.
Aging The harsh environment for which this equipment must be qualified results from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe environment and therefore, less demanding service.
There was insuffi-cient test documentation to predict a qualified life for this component, however, we are continuing our aging evaluations for equipment and as additional components requiring periodic replacement or maintenance are identified, they will be handled on a case by case basis.
Based on these facts, continued operation of the plant is justified.
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FRC EQUIPMENT NO..
190 Justification For Continued Operation (Continued):
Pressure The service profile reaches a peak of 16.2 psia, whereas the test pres-sure reaches a maximum of 7" H 0 (14.95 psia).
The service profile is 9
abov 14.95 psia for approximately 18 seconds.
Based on this fact and due so the weathertight construction of this instrument, in our engi-neering judgement, no functional disparities will occur.
Therefore, continued plant operation is justified.
Radiation 0
These components have been analyzed to be able to withstand,1 x 10 RADS.
1he 40 year dose plus the accident dose is only 7.5 x 10* RADS, there-fore, continued operation is justified.
Steam Exposure / Functional Test A pressure siwtch similar to this component was exposed to steam during environmental testing, and during that time it was functionally tested, therefore, continued operation is justified.
Test Duration A pressure switch similar to this component was tested for approximately 6.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> at 212 F and another 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> at temperatures between ambient and 212 F._
The installed pressure switch is only required for 90 minutes post-accident, therefore, continued operation is justified.
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i FRC EQUIPMENT NO.:
192 Boston Edison Equipment No.:
PS1001-83A Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Speciman" is because they did not have complete infor-mation regarding the component and the qualification documentation. The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis) the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, provid-ing justification for specific parameters (if any) satisfies the require-ment for justification for continued operation.
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i FRC EQUIPMENT NO.:
193 Boston Edison Equipment No.:
PS1001-83C Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Speciman" is because they did not have complete infor-mation regarding the component and the qualification documentation. The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessa ry analysis) the applicability of those documents will be conclusively preven.
In our engineering judgement, because this is not a hardware deficiency, provid-ing justification for specific parameters (if any) satisfies the require-ment for justification for continued operation.
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FRC EQUIPMENT NO..
195 l
Boston Edison Equipment No.-
l PS1360-9A PS1360-9B l
PS1360-9C 1
l PS1360-9D l
l Justificatior for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Speciman" is because they did not have complete infor-mation regarding the component and the qualification documentation. The supporting documents that Boston Edison has listed in previous reports ta the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis) the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, provid-ing justification for specific parameters (if any) satisfies the require-ment for justification for continued operation.
di! ng i
The harsh environment for which this equipment must be qualified results from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe environment and therefore, less demanding service.
There was insuffi-cient test documentation to predict a qualified life for this component, however, we are continuing our aging evaluations for equipment and as additional components requiring periodic replacement or maintenance are
)
identified, they will be handled on a case by case basis.
Based on these facts, continued operation of the plant is justified.
1 4
Page 1 of 2
i FRC EQUIPMENT NO..
194 Justification for Continued Operation (Continued):
Steam Exposure Pressure switches similar to these pressure switches were subjected to a steam environment during environmental testing.
The switches continued to function while in the steam environment, therefore, continued opera-tion is justified.
Temperature The service profile is less severe than the test profile.
The service temperature peak has a faster ramp time but returns to normal condition in approximately 6 minutes.
In our engineering judgement, the internal temperature of the component will be less during the predicted accident than was experiened during the test.
This is based on preliminary cal-culations for similar components.
Therefore, the test temperature profile in the test is actually more se* vere than the service condition and continued operation of the plant is justified.
Radiation 6
Thesecomponentshavebeenanalyzedtobeabletowithstang2x10 RADS.
The 40 year dose plus the accident dose is only 7.9 x 10 RADS, there-fore, continued operation is just ified.
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l FRC EQUIPMENT NO.:
195 l
Boston Edison Equipment No.:
PS2301-2368A PS2301-2368B Justification for Continued Operatica:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Speciman" is because they did not have complete infor-mation regarding the component and the qualification documentation.
The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis) the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, previd-ing justification for specific parameters (if any) satisfies the require-ment for justification for continued operation.
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N s-t C'
FRC EQUIPMENT NO.-
19_6 _
s s.
s.
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/s Boston Edison Equipment No.:
PS2360 1 en
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i IJdstification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence.:if Qualification" and " Adequate Similarity Between Equipment and. Test Spec 2 man" is because they did not have complete infor-mation regarding the ' component and the qualification documentation.
The 4-supporting doct. cents that Boston Edison has listed in previous reports to
. the NRC do apply to this component.
When Boston Edison completes the
^ qualificatien of this item (s) (including any necessary analysis) the applicability of those documents will be conclusively proven.
In our-j engineering judgement, because this is not a hardware deficiency, provid-Ing-justification for specific parameters (if any) satisfies the require-l ment for justification for continued operation.
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FRC EQUIPMENT NO.:
197 Boston Edison Equipment No.i PS1001-89D Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment nd Test Speciman" is because they did not have complete infor-mation regarding the component and the qualification documentation.
The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis) the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, provid-ing justification for specific parameters (if any) satisfies the require-ment for justification for continued operation.
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I FRC EQUIPMENT NO.-
(
~ 196 Boston Edison Equipment No.-
PS1001-83D Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Speciman" is because they did not have complete infor-mation regarding the component and the qualification documentation. The supporting docum.'nts that Boston Edison has listed in previous reports to the Nhc do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis) the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, provid-ing justification for specific parameters (if any) satisfies the require-ment for justification for continued ope ration.
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FRC EQUlPMENT NO.:
149 Boston Edison Equipment No.:
PS263-50B PS263-49B Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity between Equipment and Test Speciman" is becaase they did not have complete infor-mation regarding the component and the qualification documentation. The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis) the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, provid-ing justification for specific parameters (if any) satisfies the require-ment f or justification for continued operation.
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FRC EQUIPMENT NO.:
200 Boston Edison Equipment No.:
PS263-53B Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Specimen" is because they did not have complete infor-mation regarding the component and the qualification documentation. The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis), the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, pro-viding justification for specific parameters (if any) satisfies the requirement for justification for continued operation.
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FRC EQUIPMENT NO.:
201-1 Boston Edison Equipment No.:
PS263-51C PS263-51D 3
Justification for Continued Operation:
Boston Edison has conducted further reviews regarding these pressure switches.
The function of these switches is to aid start-up and testing by preventing a scram, below 600 PSIG from Main Condenser Low Vacuum and i
Main Steam Isolation Valve Closure.
Therefore, these switches are not required to mitigate either a LOCA or a PBOC and therefore, they have been removed from the Equipment Qualification Master Equipment List.
Based on the above information, continued plant operation is justified.
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FRC EQUIPMENT NO.:
201-2 Boston Edison Equipment No.:
PS263-55C l
PS263-55D i
4 Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category 2
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Speciman" is because they did not have complete infor-mation regarding the component and the qualification documentation. The i
supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis) the applicability of those documents will be conclusively proven.
In our i
engineering judgement, because this is not a hardware deficiency, provid-ing justification for specific parameters (if any) satisfies the require-ment for justification for continued operation.
Aging 1
The harsh environment for which this equipment must be qualified results l
from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe I
environment and therefore, less demanding service.
There was insuffi-cient test documentation to predict a qualified life for this component, however, we are continuing our aging evaluations for equipment and as i
additional components requiring periodic replacement or maintenance are identified, they will be handled on a case by case basis. Based on these facts, continued operation of the plant is justified.
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l FRC EQUIPMENT NO.:
201-2 Justification For Continued Operation (Continued):
Steam Exposure Pressure switches similar to these pressure switches were subjected to a steam environment during environmental testing.
The switches continued to function while in the steam envirotunent, therefore, continued opera-tion is justified.
Pressure The service profile reaches a peak of 16.2 psia, whereas the test pressure reaches a maximum of 7" H 0 (14.95 psia).
The service profile 3
is above 14.9 psia for only about 24 seconds.
Based on this fact and due to weathertight construction of this instrument, in our engineering judgement, no functional disparities will occur.
Therefore, continued plant operation is justified.
Radiation This component has been analyzed to be able to withstand 2 x 10 rads.
The 40 year dose, plus the accident dose combined is only 8.2 x 10 rads, therefore, this component is qualified for radiation.
Page 2 of 2
FRC EQUIPMENT NO.:
202 Boston Edison Equipment No.:
PS512C PS512D Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Speciman" is because they did not have complete infor-
- ation regarding the component and the qualification documentation.
The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis) the applicability of those documents will be conclusively proven.
In our eagineering judgement, because this is not a hardware deficiency, provid-ing justification for specific parameters (if any) satisfies the require-ment for justification for continued operation.
Aging The harsh environment for which this equipment must be qualified results from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe environment and therefore, less demanding service.
There was insuffi-cient test documentation to predict a qualified life for this component, however, we are continuing our aging evaluations for equipment and as additional components requiring periodic replacement or maintenance are identified, they will be handled on a case by case basis.
Based on these facts, continued operation of the plant is justified.
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FRC EQUIPMENT NO.:
202 Justification for Continued Operatien (Continued):
Pressure The service profile reaches a peak of 16.2 psia, whereas the test pres-sure reaches a maximum of 7" 11 0 (14.95 psia).
The service profile is 9
above 14.95 psia for approximately 18 seconds.
Based on this fact and due to the weathertight construction of this instrument, in our engin-eering judgement, no functional disparities will occur.
Therefore, continued plant operation is justified.
Radiation 6
Thesecomponentshavebeenanalyzedtobeabletowithstang1x10 RADS.
The 40 year dose plus the accident dose is only 1.4 x 10 RADS, there-fore, continued operation is justified.
Steam _ Exposure / Functional Test A pressure switch similar to this component was exposed to steam during environmental testing, and during that time it was functionally tested, therefore, continued operation is justified.
Test Duration A pressure switch similar to this component was tested for approximately 6.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> at 212 F and another 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> at temperatures between ambient and 212 F.
The installed pressure switch is only required for 90 minutes post-accident, therefore, continued operation is justified.
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FRC EQUIPMENT NO..
204 _
Boston Edison Equipment No.:
PS1001-83B Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Speciman" is because they did not have complete infor-mation regarding the component and the qualification documentation.
The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis) the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not. a hardware deficiency, provid-ing justification for specific parameters (if any) satisfies the require-ment for justification for continued operation.
Ag_i n.13 The harsh environment for which this equipment must be qualified results from low probability events.
Events which might reasonably be ant ici-pated during this very limited period would lead to a less severe environment and therefore, less demanding service.
There was insuffi-cient test documentation to predict a qualified life for this component, however, we are continuing our aging evaluations for equipment and as additional components requiring periodic replacement or maintenance are identified, they will be handled on a case by case basis.
Based on these facts, continued operation of the plant is justified.
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l FRC EQUIPMENT NO.:
205 Boston Edison Equipment No.:
PS1001-89B Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Speciman" is because they did not have complete infor-mation regarding the component and the qualification documentation.
The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis) the applicability of those documents - will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, provid-ing justification for specific parameters (if any) satisfies the require-ment for justification for continued operation.
Page 1 of I
FRC EQUlPMENT NO.
206 Boston Edison Equipment No.:
PS263-52B em.-a Justification for Continued Operation:
Franklin Fesearch Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Simila rity betwee::
Equipment and Test Specimen" is because they did not have complete infer-mation regarding the component and the qualif2 cation documentation. The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
k' hen Boston Edison completes the qualification of this item (s) (includ2ng any necessary analysis), the applicability of those documents will be conclus2vely proven.
In our engineering judgement, because this is not a hardware deficiency, l're-viding justification for specific parameters (if any) satisfies the requirement fcr justification for continued operation.
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FRC EQUIPMENT NO.:
207 Boston Edison Equipment No.:
PS2301-2389A PS2301-2389B PS2301-2389C PS2301-2389D Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Specimen" is because they did not have complete infor-mation regarding the component and the qualification documentation. The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis), the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, pro-viding justification for specific parameters (if any) satisfies the requirement for justification for continued operation.
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FRC EQUIPHENT N0.:
208 l
Boston Edison Equipment No.:
PS1451B PS1464B
\\
Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category I
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Speciman" is because they did not have complete infor-mation regarding the component and the qualification documentation. The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis) the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, provid-ing justification for specific parameters (if any) satisfies the require-ment for justification for continued operation.
Aging The harsh environment for which this equipment must be qualified results from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe i
environment and therefore, less demanding service.
There was insuffi-cient test documentation to predict a qualified life for this component, however, we are continuing our aging evaluations for equipment and as i
additional components requiring periodic replacement or maintenance are identified, they vill be handled on a case by case basis. Based on these l
facts, continued operation of the plant is justified.
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1 FRC EQUIPMENT NO.:
208 Justification For Continued Operation (Continued):
Pressure The service profile reaches a peak of 16.2 psia, whereas the test pres-sure reaches a maximum of 7" H 0 (14.95 psia).
The service profile is 3
above 14.95 psia for approximately 18 seconds.
Based on this fact and due to the weathertight construction of this instrument, in our engineer-l ing judgement no functional disparities will occur. Therefore, continued plant operation is justified.
Radiation From an analysis of the materials for construction, the nonmetallic materials in these switches have been determined to have a threshold dose 6
of 1 x IQ rads. The 40 year normal operating dose for this component is 1.4 x 10 rads.
However, themaximumexpectedgoseduetonormaloper-ation from 1972 to 1985 would be 4.6 x 10 rags.
This radiation exposure, combined with an accidegt dose of 1.7 x 10 rads, results in a total integrated dose of 2.2 x 10 rads.
In our engineering judgement, sufficient degradation to cause a variation in component performance will not occur at a radiation level this close to the threshold dose of these materials. Therefore, continued plant operation is justified.
Temperature The service profile is less severe than the test profile.
The peak service temperature of 248 F is higher than the test temperature of 212 F.
Iloweve r, the time duration that the service temperature is above 212 F is about 48 seconds.
In our engineering judgement, the internal temperature under the service condition will not reach the test tempera-ture of 212*F.
Therefore, the test temperature profile in the test l
report is actually more severe and continued plant operation is justi-i fied.
Steam Exposure / Functional Test A pressure switch similar to this component was exposed to steam during environmental testing, and during that time was functionally tested, therefore, continued operation is justified.
Test Duration A pressure switch similar to this component was tested for approximately l
6.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> at 212 F and 'another 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> at temperatures between ambient l
and 212*F.
The installed pressure switch is only required for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> post-accident, therefore, continued operation is.justifid.
Page 2 of 2
i FRC EQUIPMENT NO.:
209 i
l Boston Edison Equipment No.:
.PS1001-93D PS1001-93B PS1001-104D l
PS1001-104B I
Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate. Similarity Between Equipment and Test Specimen" is because they did not have complete infor-mation regarding the component and the qualification documentation.
The l
supporting documents that Boston Edison has listed in previous reports to i
the NRC do apply to this component.
When Boston Edison completes the j
qualification of this item (s) (including any necessary analysis), the applicability of those documents will be conclusively prosen.
In our engineering judgement, because this is _ not a hardware deficiency, pro-viding justification for specific parameters (if any) satisfies the requirement for justification for continued operation.
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FRC EQUIPMENT NO.:
210 Boston Edison Equipment No.:
LIS263-58A Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Speciman" is because they did not have complete infor-mation regarding the component and the qualification documentation. The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis) the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, provid-ing justification for specific parameters (if any) satisfies the require-ment for justification for continued operation.
Aging The harsh environment for which this equipnent must be qualified results from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe environment and therefore, less demanding service.
There was insuffi-i cient test documentation to predict a qualified life for this component, l
however, we are continuing our aging evaluations for equipment and as additional components requiring periodic replacement or maintenance are
(
identified, they will be handled on a case by case basis. Based on these facts, continued operation of the plant is justified.
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FRC EQUIPMENT NO.-
210 Justification For Continued Operation (Continued):
Pressure The service profile reaches a peak pressure of 16.2 psia and decays to atmospheric pressure within 24 seconds.
In our engineering judgement, exposure to this pressure transient will cause no functional disparities due to NEMA 3 construction.
Therefore, continued plant operation is justified.
Test Duration The harsh environment in which this equipment must be qualified results from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe environment and therefore, less demanding service.
In our engineering judgement, " test duration" is not a hardware deficiency.
Based on these facts, continued plant operation is justified.
Radiation 6
These components have been analyzed to be able to withstand 2 x 10 RADS.
6 The 40 year dose plus the accident dose is only 1.86 x 10 RADS, there-fore, continued operation is justified.
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i FRC EQUIPMENT NO.:
211 Boston Edison Equipment No.:
t LIS263-58B Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Speciman" is because they did not have complete infor-mation regarding the component and the qualification documentation. The supporting documents that. Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis) ' the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, provid-ing justification for specific parameters (if any) satisfies the require-ment for justification for continued operation.
Aging The harsh environment for which this equipment must be qualified results from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe environment and therefore, less demanding service.
There was insuffi-cient test documentation to predict a qualified life for this component, however, we are continuing our aging evaluations for equipment and as additional components requiring periodic replacement or maintenance are L
identified, they will be handled on a case by case basis.
Based on these facts, continued operation of the plant is justified.
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1 FRC EQUIPMENT NO.:
211 Justification For Continued Operation (Continued):
Pressure The service profile reaches a peak pressure of 16.2 psia and decays to atmospheric pressure within 24 seconds.
In our engineering judgement,
exposure to this pressure transient will cause no functional disparities due to NEMA 3 construction.
Therefore, continued plant ope ra t ion is justified.
Test Duration The harsh environment in which this equipment must be qualified results from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe environment and therefore, less demanding service.
In our engineering judgement, " test duration" is not a hardware deficiency.
Based on these facts, continued plant operation is justified.
Radiation 6
These components have been analyzed to be able to withstand 2 x 10 RADS.
6 The 40 year dose plus the accident dose is only 1.86 x 10 RADS, there-fore, ccntinued operation is justified.
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FRC EQUIPMENT NO.:
212 Boston Edison Equipment No.:
LIS263-72B LIS263-72D l
l l
Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Speciman" is because they did not have complete infor-mation regarding the component and the qualification documentation. The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis) the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, provid-ing justification for specific parameters (if any) satisfies the require-ment for justification for continued operation.
Aging i
l The harsh environment for which this equipment must be qualified results from low probability events.
Events which might reasonably be antici-l pat-'
during this very limited period would lead to a less severe l
enu ronment and therefore, less demanding service.
There was insuffi-cient test documentation to predict a qualified life for this component, however, we are continuing our aging evaluations for equipment and as additional components requiring periodic replacement or maintenance are l
identified, they will be handled on a case by case basis. Based on these facts, continued operation of the plant is justified.
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I FRC EQUIPMENT NO.-
212 Justification For Continued Operation (Continued):
Pressure The service profile reaches a peak pressure of 16.2 psia and decays to atnospheric pressure within 24 seconds.
In our engineering judgement, exposure to this pressure transient will cause no functional disparities due to NEMA 3 construction.
Therefore, continued plant operation is justified.
Test Duration The harsh environment in which this equipment must be qualified results from low probability events.
Events which might reasorably be antici-pated during this very limited period would lead to a less severe environment and therefore, less demanding service.
In our engineering judgement, " test duration" is not a hardware deficiency.
Based on these facts, continued plant operation is justified.
Radiation 6
These components have been analyzed to be able to withstand 2 x 10 RADS.
6 The 40 year dose plus the accident dose is only 1.86 x 10 RADS, there-fore, continued operation is justified.
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i FRC EQUIPMENT NO.:
213 1
Boston Edison Equipment No.:
I LIS263-72A LIS263-72C Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Speciman" is because they did not have complete infor-mation regarding the component and the qualification documentation. The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis) the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, provid-ing justification for specific parameters (if any) satisfies the require-ment for justification for continued operation.
Aging The harsh environment for which this equipment must be qualified results from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe i
environment and therefore, less demanding service.
There was insuffi-cient test documentation to predict a qualified life for this component, however, we are continuing our aging evaluations for equipment and as additional components requiring periodic replacement or maintenance are identified, they will be handled on a case by case basis. Based on these 3
facts, continued operation of the plant is justified.
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FRC EQUIPMENT NO.:
213 t
Justification For Continued Operation (Continued):
Pressure The service profile reaches a peak pressure of 16.2 psia and decays to atmospheric pressure within 24 seconds.
In our engineering judgement, exposure to this pressure transient will cause no functional disparities due to NEMA 3 construction.
Therefore, continued plant operation is justified.
Test Duration The harsh environment in which this equipment must be qualified results from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe envi ror, ment and therefore, less demanding service.
In our engineering judgement, " test duration" is not a hardware deficiency.
Based on these facts, continued plant operation is justified.
Radiation 6
These components have been analyzed to be able to withstand.2 x 10 RADS.
3 i
The 40 year dose plus the accident dose is only 4.4 x 10 RADS, there-fore, continued operation is justified.
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FRC EQUIPMENT NO.:
214 Boston Edison Equipment No.:
LIS263-57A LIS263-57B Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Speciman" is because they did not have complete infor-mation regarding the component and the qualification documentation.
The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis) the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, provid-ing justification for specific parameters (if any) satisfies the require-ment for justification for continued operation.
Aging The harsh environment for which this equipment must be qualified results from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe environment and therefore, less demanding service.
There was insuffi-cient test documentation to predict a qualified life for this component, however, we are continuing our aging evaluations for equipment and as additional components requiring periodic replacement or maintenance are identified, they will be handled on a case by case basis.
Based on these facts, continued operation of the plant is justified.
Page 1 of 2
FRC EQUIPMENT NO.:
214 Justification For Continued Operation (Continued):
Pressure The service profile reaches a peak pressure of 16.2 psia and decays to atmospheric pressure within 24 seconds.
In our engineering judgement, exposure to this pressure transient will cause no functional disparities due to NEMA 3 construction.
Therefore, continued plant operation is justified.
Test Duration The harsh environment in which this equipment must be qualified results from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe environment and therefore, less demanding service.
In our engineering judgement, " test duration" is not a hardware deficiency.
Based on these f acts, continued plant operation is justified.
Radiation 6
These component.s have been analyzed to be able to withstgnd 2 x 10 RALS.
The 40 ye,r dose plus the accident dose is only 4.4 x 10 RADS, therefore continued operation is justified.
k Page 2 of 2
FRC EQUIPMENT NO.:
215 Boston Edison Equipment No.:
LS9036A
~
LS9036B LS9038A LS9038B x
s m 1 Sh Justification for Continued Operation:
Boston Edison has conducted further reviews regarding thts'e level switch-es.
These level switches sense high and low level in the torus troughs.
It has been determined that these level switches' art ~ npt required to mitigate either a LOCA or a PBOC, therefore, they hav.- been, removed f rom the Equipment Qualification Master Equipment List.
Based,on the above information, continued plant operation is justified.
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N=i-FRC EQUIPf!ENT NO..
220 Boston Edison Equipment.%..
FT1461A FT1451B 4.-
f
_ ~ _
lust 1;i 'at ion for Continued Operation:
\\
These flow transmitters trancmit core spray flow, but do not perform en essential safety f tcie t i ori '
They are not required to achieve safe shaldown and do not perfot;n an c%ential safety function to mitigate an s
accident. ' Jn the event cf failure of these components as a result of expo ure to,the' postulated ha rch environment, no safety function or safety related equipment is degraded. The operator would have a comi>ina-
' N tion of valve po.U U ons indication,. pump discharge ;iressure and motor
{,
amperes, thich will allow him' to determi:
if there is proper core spray flow. Therefore, cont.(nued operation i:. justified.
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TkC EQUlpMENT NO.-
v,-3 Boston Edison Equipment No ;
FT2358 Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity between Equipment and Test Specimen" is because they did not have complete infor-mation regarding the component and the qualification documentation.
The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
khen Boston Edison completes the qualification of this item (s) (including any necessary analysis), the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, pro-viding justification for specific parameters (if any) satisfies the requirement for justification for continued operation.
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FRC EQUIPMENT NO.:
224 Boston Edison Equipment No.:
LITS 263-59B Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Speciman" is because they did not have complete infor-mation regarding the component and the qualification documentation.
The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis) the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, provid-ing justification for specific parameters (if any) satisfies the require-ment for justification for continued operation.
Aging The harsh environment for which this equipment must be qualified results from low probability events.
Events which might reasonably be antici-pated during this ve ry limited period would lead to a less severe environment and therefore, less demanding service.
There was insuffi-cient test documentation to predict a qualified life for this component, however, we are continuing our aging evaluations for equipment and as additional components requiring periodic replacement or maintenance are identified, they will be handled on a case by case basis.
Based on these facts, continued operation of the plant is justified.
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FRC EQUIPMENT NO.:
224 Justification For Continued Operation (Continued):
Pressure The service profile reaches a peak pressure of 16.2 psia and decays to atmospheric pressure within 24 seconds.
In our engineering judgement, exposure to this pressure transient will cause no functional disparities due to NEMA 3 construction.
Therefore, continued plant operation is justified.
Test Duration Tie harsh environment in which this equipment must be qualified results flom low probability events.
Events which might reasonably be antici-
.:ted during this very limited period would lead to a less severe c
environment and therefore, less demanding service.
In our engineering judgement, " test du ra ti oni" is not a hardware deficiency.
Based on these facts, continued plant operation is justified.
Radiation 0
These components have been analyzed to be able to withstand 2 x 10 RADS.
6 The 40 year dose plus the accident dose is only 1.86 x 10 RADS, there-fore, continued operation is justified.
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FRC EQUIPMENT NO.:
225 Boston Edison Equipment No.:
LITS 263-59A Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Speciman" is because they did not have complete infor-l mation regarding the component and the qualificatioa documentation. The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis) the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, provid-ing justification for specific parameters (if any) satisfies the require-ment for justification for continued operation.
Aging The harsh environment for which this equipment must be qualified results from low probability events. Events which might reasonably be anticipated during this very limited period would lead to a less severe environment and therefore, less demanding service.
There was insufficient test documentation to predict a qualified life for this component, however, we are continuing our aging evaluations for equipment and as additional components requiring periodic replacement or maintenance are identified, they will be handled on a case by case basis.
Based on these facts, continued operation of the plant is justified.
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l FRC EQUIPMENT No.:
225 Justification For Continued Operation (Continued):
Pressure The service profile reaches a peak pressure of 16.2 psia and decays to atmospheric pressure within 24 seconds.
In our engineering judgement, exposure to this pressure transient will cause no functional disparities due to NEMA 3 construction.
Therefore, continued plant operation is justified.
Test Duration The harsh environment in which this equipment must be qualified results 1
from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe environment and therefore, less demanding service.
In our engineering judgement, " test duration" is not a hardware deficiency.
Based on these facts, continued plant operation is justified.
Radiation 6
These components have been analyzed to be able to withstand 2 x 10 RADS.
5 The 40 year dose plus the accident dose is only 4.4 x 10 RADS, there-fore, continued operation is justified.
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l FRC EQUIPMENT No.:
226 Boston Edison Equipment No.:
i LITS 263-73B i
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l Justification for Continued Operation:
j The safety related display function of this level indicating transmitting switch is being accomplished by DPT1001-650A and B.
DPT1001-650A and B are environmentally qualified Rosemount model 1153 transmitters, which provide a level indication signal to the Post Accident Monitoring Panel in the Control Room. Therefore, continued operation is justified.
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FRC EQUIPMENT NO.:
227 Boston Edison Equipment No.-
LITS 263-73A Justification for Continued Operation:
The safety related display function of this level indicating transmitting switch is being accomplished by DPT1001-650A and B.
DPT1001-650A and B are environmentally qualified Rosemount model 1153 transmitters, which provide a level indication sigr.al to the Post Accident Monitoring Panel in the Control Room.
Therefore, continued operation is justified.
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l FRC EQUIPMENT NO.:
232 Boston Edison Equipment No.:
LS2301-2351A LS2301-2351B t
Justification for Continued Operation:
These level switches close on high suppression pool water level and signal valve M02301-36 to open.
This valve is located in the HPCI pump suction line from the suppressica pool.
The valve can also be opened 4
either remotely from the control room or on a signal of low Condensate Storage Tank level.
No mode of failure of these level switches can 4
prevent M02301-36 from opening if a signal to open is generated from another source, nor can failure of these switches cause the valve to close. Adequate suppression pool level display instrumentation is avail-able to' the operator (LIl001-604A,B) to indicate that opening of
-M02301-36 is required.
Therefore, continued operation of the plant is justified.
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FRC EQUIPMENT NO..
249 Boston Edison Equipment No.
S157279 Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the catecery
" Documented Evidence of Qualification" and " Adequate Similarity Bet ++n Equipment and Test Speciman" is because they did not have complete inf r-mation regarding the component and the qualification documentation.
The supporting documents that boston Edison has listed in previous repc rts to the NRC do apply to this component.
When Boston Edison completes th<
qualification of this item (s) (including any necessary analysis! the applicability of those documents will be cenclusively proven.
In our engineering judgement, because this is not a hardware deficiency, prt cid-ing justification f or specific parameters (if any) satisfies the require-ment for justification f or continued operation.
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l FRC EQUIPMENT NO.:
252 i
i Boston Edison Equipment No.-
S1 I
1 i
Justification for Continued Operation:
)
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Speciman" is because they did not have complete infor-mation regarding the component and the gnalification documentatior.. The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison cc,mpletes the qualification of this item (s)- (including any necessary analysis) the applicability of those documents will be conclusively proven.
In our
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engineering judgement, because this is not a hardware deficiency, provid-ing justification for. specific parameters (if any) satisfies the require-ment for justification for continued operation.
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l FRC EQUIPMENT NO.:
254 Boston Edison Equipment No.:
A0203-1A (L.S.)
A0203-1B (L.S.)
A0203-1C (L.S.)
A0203-ID (L.S.)
1 A
l Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category i
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Specimen" is because they did not have complete infor-mation regarding the component and the qualification documentation. The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis), the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, pro-viding justification for specific parameters (if any) satisfies the requirecant for justification for continued operation.
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FRC EQUIPMENT NO.:
255 Boston Edison Equipment No.:
A0203-2A (Limit Switch)
A0203-2B (Limit Switch)
A0203-2C (Limit Switch)
A0203-2D (Limit Switch)
Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Speciman" is because they did not have complete infor-mation regarding the component and the qualification documentation. The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis) the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, provid-ing justification for specific parameters (if any) satisfies the require-ment for justification for continued operation.
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FRC EQUIPMENT NO.:
257 Boston Edison Equipment No.:
VGTF201A (Carbon Temp Sw)
VGTF201B (Carbon Temp Sw)
Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Specimen" is because they did not have complete infor-mation regarding the component and the qualification documentation.
The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis), the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, pro-viding justification for specific parameters (if any) satisfies the requirement for justification for continued operation.
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l FRC EQUIPMENT NO.:
258 Boston Edison Equipment No.:
VGTF201A (HTR Temp SW)
VGTF201B (HTR Temp SW)
Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Specimen" is because they did not have complete infor-mation regarding the component and the qualification documentation. The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis), the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, pro-viding justification for specific parameters (if any) satisfies the requirement for justification for continued operation.
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FRC EQUIPMENT NO.:
259 i
Boston Edison Equipment No.:
VGTF201A (Wire)
VGTF201A (Wire) 1
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Justifi 2 tion for Continued Operation:
The functions for which this Bronco wire was supplied have been bypassed.
Therefore, this wire is not required and continued plant operation is l
justified.
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FRC EQUIPMENT.NO.:
260 Boston Edison Equipment No.:
C68 (Transformer)
C69 (transformer) l Justification ' for Continued Operation:
1 Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between j
Equipment and Test Speciman" is because they did not have complete infor-mation regarding the component and the qualification documentation. The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
Wen Boston Edison completes the qualification of this item (s) (including any necessary analysis) the applicability of those documents will be conclusively proven.
In our j
engineering judgement, because this is not a hardware deficiency, provid-ing justification for specific parameters (if any) satisfies the require-ment for justification for continued operation.
These components are not required to operate post-PBCC.
The re fo re, they only need to be qualif2ed for aging and radiation.
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FRC EQUIPMENT NO.
261 Boston Edison Equipment No.-
C68 (Contactor)
C69 (Contactor) h, Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the catercry
" Documented Evidence of Qualification" and " Adequate Similarity Be t' ee:.
Equipment and Test Speciman" is because they did not have complete infer-mation regarding the component and the qualification documentation.
The supporting documents that Boston Edison has listed in previous reports to the.NRi, do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis) the applicability of those documents will be conclusively proven.
In ca r engineering judgement, because this is not a hardware deficiency, provid-ing justification for specific parameters (if any) satisfies the require-for justification for continued operation.
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Page 1 of 1
FRC EQUIPMENT NO.:
262 Boston Edison Equipment No.:
C68 (Wire)
J C69 (Wire)
Justification for Continued Operation:
The functions for which this Bronco wire was supplied have been bypassed.
Therefore, this wire is not required and continued plant operation is justified.
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l FRC EQUIPMENT NO.:
263 Boston Edison Equipment No.:
ZT 203-1 (Cable)
ZT 203-2 (Cable)
ZT 203-3 (Cable)
ZT 203-4 (Cable)
ZT 203-5 (Cable)
ZT 203-6 (Cable)
Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of -Qualification" and " Adequate Similarity Between Equipment and Test Specimen" is because they did not have complete infor-mation regarding the component and the qualification documentation. The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
khen Boston Edison completes the qualification of this item (s) (including any necessary analysis), the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, pro-viding justification for specific parameters (if any) satisfies the requirement for justificatica for continued operation.
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FRC EQUIPMENT NO.:
264 i
Boston Edison Equipment No.:
C153 (Switch)
C155 (Switch)
C157 (Switch)
C158 (Switch)
C159 (Switch)
Justification for Continued Operation:
1 The alternate shutdown panels provide a means of accomplishing a safe shutdown of the plant from outside the main control room in the event of a ~ total loss of function of the cable spreading room due to a fire.
These panels are not required to operate during or after a PBOC or a LOCA.
The shutdown capability will be retained by controls in the main control room.
The reason that these panels are included in equipment qualification efforts is te ensure that the postulated harsh environment does not result in adverse effects on various safe shutdown circuits in the main control room.
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FRC EQUIPMENT NO.
266 Boston Edison Equipment No.:
C152 (Switch)
C156 (Switch)
C163 (Switch)
Justification for Continued Operation:
The alternate shutdown panels provide a means of accomplishing a safe shutdown of the plant from outside the main control room in the event of a total loss of function of the cable spreading room due to a fire.
Thse panels are not required to operate during or af ter a PBOC or a LOCA.
The shutdown capability will be retained by controls in the main cont rc 1 room.
The reason that these panels are included in equipment qualifica-tion efforts is to ensure that the postulated harsh environment does nc,t result in adverse effects on varicus safe shutdown circuits in the main control room.
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FRC EQUIPMENT NO.:
269 l
Borton Edison Equipment No.:
C61A (Switch)
C61B (Switch)
Justification for Continued Operation:
Aging The harsh environment for which this equipment must be qualified results from low probability events.
Events which might reasonably be antici-pated during this very limited period would lead to a less severe environment and therefore, less demanding service.
There was insuffi-cient test documentation to predict a qualified life for this.omponent, however, we are continuing our aging evaluations for equipment and as additional components requiring periodic replacement or maintenance are identified, they will be handled on a case by case basis.
Based on these facts, continued operation of the plant is justified.
Humidity Per EA&T Project 1035-1 Rev. 2 Report, this componet has been success-
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fully tested at 95% relative humidity.
In our engineering judgement, the test condition is sufficiently harsh to establish the ability of the component to withstand high humidity levels.
Based on this test, continued operation is justified.
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FRC EQUIPMENT NO.:
269 i
Justification For Continued Operation (Continued):
Pressure The rise time for the pressure environment of 16.4 pria during PBOC is 12 seconds and then the pressure stabilizes to atmosphere within 24 seconds.
The functional requirement of the switches is that the normally closed contacts, internal to the switches, which are inside the control panel, remains closed.
In our engineering judgement, exposure to this pressure transient within the short time interval will not cause the switches to change position.
Therefore, continued plant operation is justified.
Radiation The normal 40 year integrated dose for this component is 1.2 x 10 rads calculated by very conservative methods.
Post LOCA 30 days accumulated dose is 1.2 x 105 rads. IIence, total normal plus accident dose is 1.6 x 5 rads. 6 As per EA&T test report 1035-1, this component was irradiated 10 to 1x 10 rads.
The functional requirement of the switches is that the normally closed contacts, internal to the switches, which are inside control panel, remain closed.
In our engineering judgement, a slight increase of total (normal and accident) dose will not cause the switches to change position.
Therefore, continued plant operation is justified.
Temperature The rise time for the temperature environment of 235 F during PBOC is 24 seconds, then the temperature falls to 170 F within 2 minutes and then to 150 F within 6 minutes and stabilizes around 35*F within 20 minutes. As per EA&T Test Report 1035-1, switch was tested to a temperature of 150 F.
The functional requirement of the switches is that normally the closed contacts internal to the switches, inside the control panel, remain closed.
In our engineering judgement, exposure to the temperature transient within the short time interval will not cause the switch to change position.
Therefore, continued plant operation is justified.
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FRC EQUIPMENT NO.: __ 270 1
Boston Ed %on Equipment No.:
C61A (Cable)
C61B (Cable)
Justification for Continued Operation:
Franklin Research Center's determination of a deficiency in the category
" Documented Evidence of Qualification" and " Adequate Similarity Between Equipment and Test Specimen" is because they did not have complete infor-mation regarding the component 'and the qualification documentation.
The supporting documents that Boston Edison has listed in previous reports to the NRC do apply to this component.
When Boston Edison completes the qualification of this item (s) (including any necessary analysis), the applicability of those documents will be conclusively proven.
In our engineering judgement, because this is not a hardware deficiency, pro-viding justification for specific parameters (if any) satisfies the requirement for justification for continued operation.
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