Text

Forwards Addl Info Providing Interim Operation Justification for Equipment Identified in 810901 Submittal as Needing Justification Prior to Fuel Load.Revision 1 to Section 6.0 of NUREG-0588 Submittal Introduction Document Also Encl
	ML20039B734
Person / Time
Site:	Grand Gulf
Issue date:	12/21/1981
From:	Dale L; MISSISSIPPI POWER & LIGHT CO.
To:	Tedesco R; Office of Nuclear Reactor Regulation
References
	RTR-NUREG-0588, RTR-NUREG-588 AECM-81-502, NUDOCS 8112230494
	Download: ML20039B734 (54)
	v • d • e

4 MISSISSIPPI POWER & LIGHT COMPANY Helping Build Mississippi P. O . B OX 1640, J AC K S O N, MIS SIS SIP PI 3 9 2 05 NUCLEM PRODUCTON DEPMTMENT

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8 R; Mr. Robert L. Tedesco N 4 Assistant Director of Licensing Division of Licensing OCp t> ,

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.-'s U.S. Nuclear Regulatory Commission -- 8 Washington, D. C. 20555 M \

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Dear Mr. Tedesco:

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SUBJECT:

Grand Gulf Nuclear ?

Units 1 and 2 Docket Nos. 50-416 and 50-417 File: 0260/0277/L-860.0/L-814.1 Re: AECM-81/231; July 1, 1981 AECM-81/335; September 1, 1981 Equipment Qualification NUREG-0588 Evaluation Supplement 2 AECM-81/502 Mississippi Power & Light Company's letter of July 1,1981 (AECM-81/231) provided evaluations of Class IF electrical equipment qualification to the requirecents of NUREG-0588. The results of Mississippi Power & Light Company's review indicates that the cajority of the Class IE electrical equiptent was fully qualified, or that testing perforced to date was sufficient to justify interin operation.

Since Mississippi Power & Light Company's July 1, 1981 submittal, a successful NRC audit was conducted during the week of October 19 to 22, 1981.

The purpose of this letter is to provide additional information to the Equipment Qualification Branch for equipment identified previously (AECM-81/335) as needing interin operation justification prior to fuel load.

With the attached information, qualification or interin operation justification will have been established on all equipment at Grand Gulf Nuclear Station, Unit I subject to the NUREG-0588 harsh environment review.

The following information is provided: 09 b A. Attachment No. 1 Provides interim operation justification for equipment previously

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identified as needing interim operation justification prior to fuel load.

B. Attachment No. 2 Attached is Revision 1 to Section 6.0 of the NUREG-0588 submittal introduction document. This revision clarifies radiation calculation methodologies as requested by the NRC November 10, 1981 audit of the containment dose model.

8112230494 811221 Member Middle South Utilities System DR ADOCK 05000416 PDR J

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MII0l?f!IPPI POWER O LIGHT COMPANY AECM-81/502 Page 2 If you have any questions regarding this information, please advise.

Yours truly, L. F. Dale Manager of Nuclear Services RAB/TMJ:dr Attachment cc: Mr. N. L. Stampley Mr. R. B. McGehee Mr. T. B. Conner Mr. G. B. Taylor Mr. Richard C. DeYoung, Director Office of Inspection & Enforcement .

U. S. Nuclear Regulatory Commission Washington, D. C. 20555 L

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ATTACHMENT 1 EQUIPMENT REVIEWED AND JUSTIFICATION FOR INTERIM OPERATION IS ATTACHED

1. ,N/A -Electric Interface 2.. J-301 Rosemount. Transmitter (GB9) 3.- J-359.1 CGC Heat Tracing

4. J-363 Area Radiation-Detectors 5.. M-190 Hydrogen Recombiner

6. M-632 SGTS Motor, Heater, and Heater Controls

7. M-50.1 Dryvell Purge Compressor

8. M-242 Air Operated Valves

9. ~ M-242/251 D. C. Motor Operated Valves

10. M-257/58 Air Operated Valves

11. .NSSS 1151 Rosemount Transmitters

12. NSSS 1152 Rosemount Transmitters 4

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SUPPLEMENT 2

1. EQUIPMENT DESCRIPTION Qualification of Class IE equipment has been done on a component basis, with little consideration by the manufacturer as to how their device would interface with other components. The method in which electrical circuits are connected to devices, including any ancillary equipment, is considered the " electrical interface".

To properly achieve a complete review of the electrical interface, it has been broken down into three areas:

1. Equipment wire entrance sealing Specification: 9645-E-062.3 a) Manufacturer: RAYCHDI Component: Heat Shrinkable Tubing Model #: Type WCSF-N Test Reports: RAYCHEM Repcrt II's EDR-2001, 5008, 5009, 5011, 5019, 5021, and 5040 - Wyle Laboratories Report #58442-1 b) Manufacturer: RAYCHEM Component: Nuclear Cable Breakout and end sealing kits Model: 403A112-52 (Cable Breakout) 101A021-52 (End Cap)

Test Report: Wyle Laboratories Report

58442-2, RAYCHEM Report 11 EDR-5043 c) Manufacturer: RAYCHEM Component: Nuclear Motor Connection Kits Model: N-MCK lest Report: 58442-3

2. Terminal Blocks a) Manufacturer: KULKA Component: Terminal Blocks w/ glass filled ALKYD material Model #: STB, 7TB, 17TB, & 27TB Test Report: IPS-586 b) Manufacturer: KULKA-DIALLYL PHATHALATE Component: Terminal Blocks w/GDI-30F glass-filled Diallyl Model #: 600J-J, 601J-5, 602J-J, 604J-J Test Report: IPS-675 c) Manufacturer: Buchanon Component: Terminal Blocks Model #: 0222, and 0524 Test Report: F-C 3441 v

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A d) Manufacturer: TRW-Cinch, Marathon Component: Terminal Blocks Model #: TRW-Cinch, 141 & 542 series Marathon - 300 series and 1433563 e) Manufacturer: General Electric Component: Terminal Blocks Model #: CR151B, CR151D, CR2960, EE-5, and EB-25 Test Report: P EN-TR-80-83

3. Moisture excursion within the wire strands Documents Reviewed: NRC Circular 79-05 Moisture leakage in stranded wire conductors Bechtel Power Corp. 's " Discussion of the Electrient Interface Review" (Ref. MPB-81/0616 dated December 10, 1981).

II. QUALIFICATION STATUS AT TIME OF ORIGINAL SUBMITTAL (July '31)

At the time of the original submittal, no test . reports were available.

It was determined, based on the above, that the equipment did not meet NUREG-0588 Category I requirements. However, operating experience from other plants has sho satisfactory use in normal environments. It was stated, therefore, t the equipment could be used for an interim period until it could be qualified.

III. QUALIFICATION STATUS AT TIME OF SUPPLEMENT 1 (Sept. '81)

No additional comments were added. No change in justification for interim operation was given.

IV. QUALIFICATION UPDATE A. Equipment Sealing:

It is recognized that equipment which has been LOCA tested has generally been sealed at the electrical supply entrance to prevent LOCA environments from entering the device. Field application however, may uti.ize a local junction, which has veep holes &/or is open via open conduit (See Figure 1). Equipment sealing is there-fore advisable whenever a device is located in a pressure harsh environment which would serve as a driving force for the LOCA environment to enter the device. The sealing material chosen is the RAYCHEM WCSF-N breakout assembly with heat shrink tubing.

Qualification of the RAYCHEM WCSF-N Compound, as used with

1) Nuclear in-line cable splice assemblies

2) Heat shrinkable tubing

3) Nuclear motor connection kits

4) Nuclear cable breakout and end sealing kits was documented by Wyle Labor-tories on three separate test reports.

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The actual testing, however, was conducted at one time, with four (4) specimens listed above included. Results of that test are as follows:

1) Test specimens were thermally aged for is10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months at 150*C-(302*F). Data was collected and an Arrhenius thermal plot was constructed. Based on a conventional Archenius analysis, with a continuous operating temperature of 91*C, a demonstration of 40 year qualified life was shown.

2) Test specimens were subjected to gamma radiation for a Cobalt-60 source. The total dose given ranged fron 200 MRADS to 290 MRADS, which is greater than the integrated normal and accident dose of 56.1 MRADS. (Seal system has sufficient thickness of RAYCHEM WCSF-N material to act as shield against beta radiation.)

3) Test specimens were subjected to a LOCA/MSLb event (See Figure 2 for temp./ pressure profile) which well enveloped the GGNS DBA profile.

B. Terminal Blocks One of the more common items in electrical construction ir the terminal block. This standard component is manufactured by a number of firms and is used practically everywhere in electrical circuits.

As shown on Figure 1, terminal boxes can be located with'.n a NEMA-4 box or supplied as part of the locally mounted equipmenc. The variety and type of terminal blocks supplied by the vendors is numerous, however test reports nave been received and are currently under review. 'A preliminary review of the subject test reports has shown the following:

1) Test samples have, at a minimum, been thermally aged for 100 hours0.00116 days 0.0278 hours 1.653439e-4 weeks 3.805e-5 months at 150"C. Application of Arrhenius methods have shown at least a 40 year qualified life.

2) Test samples were exposed to at least 200 MRADS, which is far greater than the 56.1 MRADS (gamma) taken to be the total integrated normal and accident gamma dose. Terminal boards are located inside metal NEMA boxes. The boxes are thick enough to shield the boards from beta radiation due to plateout and airborne sources external to the boxes. The boxes are small enough so that the beta dose due to the airborne cloud internal to the box does not cause total beta plus garma dose to exceed 200 megarads.

3) Under LOCA conditions, certain terminal blocks (Example: KULKA 600 series) had a decrease in insulation resistance. When used '

in current loop instrument circuits or high voltage power circuits (i.e. 480v and above), these terminal blocks will be replaced with in-line splices and sealed using qualified heat shrink materials, discussed in paragraph IV-A, prior to fuel load. The design documents which identifies equipment to be sealed and wiring to be spliced, in accordance with criteria discussed herein, is drawing E-0730 and field electrical termination cards.

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C. Moisture Leakage in Stranded Wire Conductors

.The IE Circular No. 79.05 dated March 20, 1979 referenced a checkout test for cable leaks performed at Sandia. Laboratories in August 1978. This test shows that most stranded wire conductors, when subjected to a differential pressure across the conductor. ends, will leak steam or moisture between the strands of wire. The test :as also shown that solid conductors, under similar conditions, do not leak. The circular also stated that moisture incursion into a qualified splice is not possible.

The Sandia report also indicates that moisture incursion is dependent on duration and pressure difference. For the duration and magnitude of the predicted LOCA/HELB pressure transient for Grand Gulf, only stranded wire with an unsealed end a distance (defined by note below) from a sealed instrument will be affected by_ moisture incursion. A nominal distance of 50' was generally applied.

Stranded wires terminated in local terminal boxes adjacent to sealed equipment will be determinated and in-line spliced with a qualified splicing procedure as described in 15 A.

NOTE: "A Distance" was determined, on a case by case basis, using an engineering evaluation developed from the following:

1) Size of wire

2) rumber of strands

3) Size of strands

4) Type of wire-

5) NUREG/CR-1682 SAND 80-1957 RV

6) US NRC IE Circular No. 79-05

7) NUREG/CR-0696 SAND 79-2254 V. QUALIFICATION STATUS WITH REGARD TO INTERIM OPERATION JUSTIFICATION Justification Summarizing the above, equipment sealing methods reviewed should be able to meet NUREG-0588 Category I requirements, af ter : Jetailed test report review has been completed. The terminal blocks, af ter the required in-line splice replacement program has been completed, should also meet Category I or 11 requirements (depending on purchase date). A complete test report review is underway. _In-line splices will replace stranded wire terminations in areas adjacent to sealed equipment.

Based on the above, safe operation of the electrical interface in the plant until June 1982 is justified.

VI. FOLLOW UP PROGRAM The review of the subject test reports will be completed by June 1982.

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SUPPLEMENT NO. 2 Equipment Description A.- SPECIFICATION NO.: 9645-J-301.0A-B. ' COMPONENT: Level Transmitter ,

=C. MANJFACTURE: Rosemount-D. MODEL NO. 1153GB9 -

Qualification Status at Original Submittal (July 1981)

The original, testing of-the Rosemount Transmitter Model 1153GB9 demonstrated satisfactory operation under the required environments, llowever, during

-steam / temperature testing a similar transmitter, Model 115311B7,95, failed due loss of silicone oil in the "high" side of the' sensor module. This leakage was due to a solder failure which was the method of scaling the fill tube whereby the oil was inserted in the sensor cell. This failure was used to disqualify the 1153GB9 in the original submittal.

Qualification Status at Supplement 1 Submittal (September 1981)

Rosemount, Inc. was performing supplementary testing on redesigned Model 1153GB9.

Qualification Status Update (December 1981)

.In the interim period, Rosemcunt, Inc. has developed a new method of sealing the sensor oil fill tube employing spot welding and TIG welding. Rosemount has tested the new design per Rosemount procedure #48123. The results of the supplementary testing are described in Rosemount Test Report #88114. Rev. A.

The Supplementary test report #88114 Rev. A successfully proved the' adequacy of the redesign with no anomalies noted.

Qualification Status alth Regard to Interim Operation Justification No interim operation jtstification is needed because the combined results of Rosemount Test Reports #88114, Rev. A and #108025 adequately demonstrates that the Rosemount Model 1153GB9 electronic transmitter meets Category 1

= requirements of NJREG-0588.

Follow Up Program None

-SUPPLEMENf 2 I. Equipment Description SPECIFICATION NUMBER: 9685-J-359.1 COMPONENT: Comb. Cas Control; Heat Tracing System MANUFACTURER: Thermon Manufacturing Company PLANT I.D.; NUMBER: (See Attachment)

MODEL NUMBER: EQ-2399-80 Heat tracing: cable is located in containment for the purpose of maintaining hydrogen analyzer sample lines at 275'F, control panel is located in the Auxiliary Building II. Qualification Status at Time of Original Submittal (July 1981)

The equipment associated with this specification was still undergoing testing at the time of the July 81 submittal of " Response to NUREG-0588." No test data or status was available at that time.

III. Qualification Status at Time of Supplement 1 (September 1981)

Supplement 1 stated that a justification for interim operation ~would be provided prior to fuel load, based on a satisfactory completion of 30 days of a 100 day. LOCA test, due to be completed by January 1982.

IV. Qualification Status Update On November 5, 1981, the Southwest Research Institute provided-Thermon Manufacturing Company with an interim status report of the ,

nuclear component testing program underway at SWRI. >

The test was conducted in.two (2) separate parts, one covering the control panels (located outside containment), while the other ,

covered the heat tracing cable assemblies and RID's (both inside a.d I

outside containment).

Following a summary of the testing completed as of November 1981.

1. Heat tracing control panels (located outside containment):

Thermal Aging - All components of the panel were chermally aged at 120*C for from 1056 to 1138 hours0.0132 days 0.316 hours 0.00188 weeks 4.33009e-4 months with minimum activation energy of 0.71eV for all materials and maxinum normal temperature of 80*F (26.68'C), using the Arrhenius Method, the components of the heat tracing control panels have a qualificd life of 40 m years.

Irradiation - All gomponents of the subject panels have been exposed to 5.25x10- rads of gamma radiation. With the total of

'the 40 year normg1 and a 180. day integrated accident dosage.

equal to 5.54x10 rads, the test dosage envelopes the plant requirements with margin.

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. I LOCA Test - The control panel is currently being subjected to an accident environment simulation test. While exposed to 119'F at 90%

or greater humidity, the panel has completed 29 days of a 100 day LOCA test, remaining in a functional condition. Plant accident conditions around the panel installation location are non harsh therefore this test exceeds requirements.

2. Heat _ Tracing Cable Assembly and RTD's (Inside and Outside Containment):

Test were conducted using the worst case environments (inside containment)

Therral Aging - The cable assembly and RTD's were thermally aged at 590*F (310*C) for 143.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months . The normal operating temperature of the heat tracing cable is 275'F, with both the normal and accident rcom temperatures (Table B-2 and Figure B-8) at or below 200*F.

Using a 1.0eV activation energy and the Arrhenius Equation, the qualified life is 40 years with margin.

Irradiation - The ceble assembly and the RTD's have been exposed to 8.4x10" rads of gamma rao!ation with the total of the 40 ygar normal and a 180 day integrated ac ident dosage equal to 7.71x 10 rads, the test dosage envelopes the plant requirements with margin.

Beta radiation is of no concern as the cable assembly and RTD's are enclosed in stainless steel sheathing.

Functional Testing - Functional tests performed before, periodically during, and after both thermal and radiation aging ware successful.

Prior to the seismic testing however, an open circuit was found in the heat tracing cable. Investigations by Thermon, af ter the assembly was disassembled, determined the cable, at the point of failure,'had a manufacturing defect (conductors not spaced per specification). Since this type of cable has already passed similar j, testing programs for other utilities Thermon concluded this was a l random failure. A new cable assembly is currently undergoing l thermal and radiation aging testing, which will be followed by

j. vibration degradation (seismic tests).

V. Qualification Status with Regard to Interim Operation Justification:

Based upon the above information, safe operation of the plant until June 1982 is justified.

l l V1. Follow Up Program Equipment associaten with this specification is still in the testing I

I phase at this time. The equipment v.111 be qualified by test by June 1982, or as soon thereafter as possible.

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r-i ATTACHMENT I MPL Numbers: 1EG1-T003 Inside Containment 1EG1-T001 Inside Containment 1EG!-TE-N038 A&B Inside Containment IEG1-TE-N042 A&B Inside Containment 1EG1-T002 Outside Containment 1EG1-T004 Outside Containment

1EG1-TC06 Outside Containment IEG1-T008 Outside Containment 1H22-131' Outside Containment 1EG1-TE-N039 A&B Outside Containment 1EG1-TE-N040 Outside Containment IEG1-TE-N041 Outside Containment 1EG1-TE-N043 A&B Outside Containment IEG1-TE-N044 Outside Containment 1EG1-TE-N045 Outside Containment 1H22-P131B Outside Containment 1H22-P139 A&B Outside Containment 1H22-P143 Outside Containment 1H22-P144 Outside Containment KEY: P Denotes Panel T Denotes Cable N Denotes RTD 1

s SUPPLEMENT 2 I. EQUIPMENT DESCRIPTIJN Specification No.: 964S-J-363 Component: Area Radiation Monitoring Detector / Cable MP&L No.: 1021-RE-N048A,B.C,D/D21-T002 Manufacturer: Victoreen/ Boston Insulated Wire & Cable Co.

Model No.: 877-1/RG-59B/U Coaxial II. QUALTFICATION STATUS AT TIME OF ORIGINAL SUBMITTAL (July 1961)

The review on Specification 9645-J-363 was incomplete as testing was still under way.

III. QUALIFICATION STATUS AT TIME OF SUPPLEMENT 1 (Sept. 1981)

A test report was received from Victoreen involving the radiation detector and the cable assembly. A preliminary review of the report (Victoreen Report 950.301) was performed with the expectation that a complete review would yield qualification. The review was to be completed prior to fuel load.

IV. QUALIFICATION STATUS UPDATE Victorcen Qualification Report 950.301 has been reviewed for qualifica-tion of the Victoreen Model 877-1 Radiation Detector and Victorcen Model 878-1 cable assembly. The Model 877-1 Detector is the same model empicyed at GCNS. The 878-1 cable assembly involves the cable itself along with necessary connectors and seals. The CGNS cable is BIW Model RG-59 B/V coaxial. According to Section IV paragraph 3.2 of Report 950.301, the cable employed in the model 878-1 cable assembly is the cable described in BIW Report B913 of which the model RG-59 B/V coaxial is a member. Therefore, Victoreen Report 950.301 is used to qualify the detector and connector, and BIW Report B913 is used to qualify the cable itself.

A comparison of test ;rofiles as compared to required profiles reveals the following:

(1) detector and cable assembly were thermally aged to 40 years, and LOCA testing for 30 days reaghed peaks of 148 psia, 357'F, and radiation exposure of 2.2x10 rads. This compared t'av9rably with predicted environments of 44.7 psia, 330*F and 2.88x10 (2) cable was thermally aged to a 40 year qualified life, and LOCA tested for 159 dayg reaching peaks of 120 psia, 340*F, and radiation exposure of 200x10 RADS. This also compares favorablg with a predicted environment of 44.7 psia, 330*F, and 28.8x10 RADS.

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V. QUALIFICATION STATUS WITH REGARD TO INTERIM OPERATION JUSTIFICATION The equipment of specification 9645-J-363 is justified for interim operation to June 1982.

VI. FOLLOW UP PROGRAM A detailed research of the data in the above centioned test reports will be conducted to yield full qualification to June 1982.

NOTE: Test anomilies were experienced relative to moisture excursion into the electrical connector via telecon of 12/16/81 to Ajit Rawtani, Bechtel will ensure that equipment sealing is performed on this device to ensure this anomalie does not affect our qualification.

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b SUPPLEMENT 2 Equipment Description

-A. Specification No.: 9645-M-190.0 B. Component: Electric Hydrogen Recombiner/ Hydrogen Recombiner Power Supply C. Manufacture: Westinghouse D. Model No.: Model B Qualification Status of Original Submittal (July 1981)

A. Description of Extensive LOCA Testing The hydrogen recombiner has been extensively LOCA tested (pressure, temperature, and humidity) as follows by Westinghouse:

1. 0-4 hours: 316*F, 85 psia, saturated steam

2. 4-24 hours: 259'F, 35 psia, saturated steam

3. 1-22 day: 155'F, 20 psia, saturated steam

4.23-352 day: 155*F, 20 psia, saturated steam (with variations in tempe ature from 138"F to 209'F).

The Grand Gulf environments are as follows:

1. 0-1 hour: 125"F to 200*F, 30 psia, 100% humidity

2. 1-10 hour: 200*F, 30 psia, 100% humidity

3. 10-30 hour: 200*F to 176*F, 30 psia, 100% humidity

4.30-300 hour: 176*F to 125"F, 30 psia to 20 psia, 100% humidity

5. 300 hour-100 day: 125"F to.100*F, 20 psia to 14.7 psia, 100% humidity Comparison of the test profile'and.the Grand Gulf required profile illustrates the extensive amount of margin that exists between the tested and required profiles.

B. Hydrogen Recombiner Did not meet Category 1 requirements of NUREG-0588 for the following reasons:

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1. The affects of e a ra a 6

nn n gn (r qu re = x0 Rads 11x10 Rads (gamma) = 291x10 Rads TID) vs. (Tested =

(beta)6+

200x10 Rads TID)

2. Questionable aging data

3. Insufficient containment spray testing

4. Environmental conditions used in 330 day LOCA testing not clearly defined C. Hydrogen Recombiner Power Supply Did not meet Category 1 requirements of NUREG-0588 due to insufficieat radiation testing (radiation is the only harsh environment).

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Qualification Status at Supplement 1 Submittal (September 1981)

A. Hydrogen Recombiner Interim operation justification based on extensive LOCA testing at pressure, temperatures, and humidity that far exceed the required Grand Gulf profiles with the question of beta radiation tc be addressed prior to fuel load.

B. Hydrogen Recombiner Power Supply Interim operation justification based on temporary shiciding of power supply to remove radiation harsh environment.

Qualification Status Update (December 1981)

A. Hydrogen Recombiner

1. Beta Radiation Further design review has determined that all components except the metal sheated electrical heaters (which are not susceptible to beta radiation damage) are enclosed within a sealed terminal box. The conduit leading into this terminal box will be environmentally sealed with the Raychem NEIS kit.

Consequently, the components within the terminal box will not be exposed to beta radiation.

2. Containment Spray The hydrogen recombiner has been determined to be completely enclosed and that the internals are protected against impingement from containment spray. Also, calculated containment pressure drops from a peak of 9.5 psig to less than 5.0 psig within ten (10) seconds following the LOCA. Since containment spray is not initiated until 9.0 psig is exceeded after a ten (10) minute time delay period, spray is not expected following a DBA. Therefore, containment spray is considered not to be a problem with the Grand Gulf hydrogen recombiner.

B. Hydrogen Recombiner Power Supply

1. Radiation The radiation environment for the power supply has been re-evaluated using the exact location of the power supply rather than the room environment. The power supply is located behind a concrete wall inside room 1A306 and 1A309. Also, the penetrations to those rooms are shielded rather than open as assuged before. The radiation predictions are now less than 3x10 Rads which is essentially non-harsh.

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F 2. Materials Susceptible to Radiation The power supply consists essentiallf of an isolation transformer, SCR Module, Auxiliary control power transformer and a main line contactor. The power supply is located in the Auxiliary Building and is exposed to radiation as it's only 4

harsh environment at t level of 3x10 Rads which is essentially non-harsh.

The following is pertinent to the power supply relative to radiation tolerance:

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1. The SCR diodes have been successfully tested to 5x10 Rads per a November 20, 1981 letter fron Westinghouse to Bechtel, which qualifies the SCR controller.

2. Organic materials used in electrical equipment have been identified and extensively reviewed in EPRI Report NP-2129 (November 19g1). This report concludes that radiation levels of 10 Rads produces no significant degradation of mechanical or electrical properties (with the exception of Teflon and semiconductor devices) for the organic materials reviewed in the EPR1 Report NP-2129.

3. MP&L via Bechtel has confirmed through Westinghouse that the power supply contains no teflon or semiconductor devices.

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4. The 10 Rad threshold considers radiation tolerance of all known organic materials used in plant equipment, including: 1) 15 types of thermosetting plastic organic polymers; 2) 39 types of thermoplastic organic polymers;

3) 16 elastomers; 4) numerous lubricants, adhesives, and protective coatings.

Attachment 1 - Figure 1-4 (Power Supply Panel Drawing)

Attachment 2 - Figure 1-5 (Powe; Supply Schematic)

Attachment 3 - Figure 1-6 (Power Controller Bill of Materials)

Note: These attachments are not included they are retained in MP&L's central file Qualification Status with Regard to Interio Operations Justification A. Hydrogen Recombiner Interin operation is justified based on the extensive LOCA and the additional design review on the af fects of the beta radiation to the hydrogen recombiner.

B. Hydrogen Recombiner Power Supply

1. Radiation Interim operation is justified based on the re-evaluation of the actual radiation exposure the power supply is now expcsed g.110.0

p to. Radiation exposure is now less than 3x10 Rads which is considered to be non-harsh.

To further substaniate interim operation justification, the materials the power supply is composed of have been reviewed to determine their radiation tolerance. The review has concluded thatnomaterialsintheGrandGulfhydrogenrecombgrerpower supply is susceptible to radiation damage at the 10 Rag exposure level which exceeds our required level of 3x10 Rads.

Follow Up Program A. Hydrogen Recombiner Will be qualified to Category 1 of NUREG-0588 by June 1982 or as soon thereafter as possible. Further evaluation of test report and clarification documents from Westinghouse is expected to yield full qualification.

B. Hydrogen Recombiner Power Supply Will be qualified to Category 1 of liUREG-0588 by June 1982 or as soon thereafter as possible.

g.I90.D

e t

EXHIBIT 3-A

1. EQUIPMENT. DESCRIPTION Spec. No.: 9645-M-632 Component: SGTS Electric Motor / Heater and Heater Control MPL No.: Q1T48 D001 A-A, D001 B-B Manufacturer: Westinghouse /CVI hodel No.: 256T/20HP/460V/ unknown II .~ QUALIFICATION STATUS AT TIME OF ORIGINAL SUBMITTAL (July 1981)

The required environment is radiation harsh only at a level of 5.7x10 5 Rads. The motor qualification was based on Buffalo Forge test report DO-146F. This report demonstrated LOCA testing of 30 days at 3 psig and 212*F, and a radiation valvo of 1.13x108 Rads. The motor qualification was left open due to dissimilarities between the test unit and the Grand Gulf unit with regard to lead material and joint insulation material.

No IEEE-323 qualification data was submitted on the heater and control since Reg. Guide 1.52 governed standby gas treatment design. This reg

. guide referenced ANSI N-509-1976 as the design guidelines.

III. QUALIFICATION STATUS AT TIME OF SUPPLEMENT 1 (Sept. 1981)

Westinghouse notification of similarity was obtained to address differences in .the test motor as compared to the Grand Gulf motor.

Qualification of heater and heater controls remained open, to be addressed prior to fuel load.

IV. QUALIFICATION UPDATE

1) Motor qualification The Westinghouse qualification report WCAP-9112 has been evaluated relative to qualifi:ation of the Grand Gulf motor. Qualification has been demonstrated to a radiation level of 200 megarads based on motorette testing. In addition, Westinghouse has provided infoi'na-

~

tion which indicates that the motor grease is qualified to levels in excess of 100 megarads. Opgrability is thus assured for our required harsh environment of 5.7x10 Rads.

2) Qualification of SGTS heater and heater controls is as follows:

CVI Drawing B193-9900 illustrates the system layout. The system consists of a demister, heater, pre-filter, 2 HEPA filters, charcoal beds and exhaust fan arranged in the manner as shown on the referenced drawing.

E5rgl 2

e CV1 Drawing B193-5900 illustrates the control panels contained within the syster. These control panels are the heater control panel and the fire protection control panel. The humidity controls are located in the heater control panel.

CVI Drawing B'93-6000 demonstrates the corposition of the heater control panel. The panel consists of a transformer, humidity indicator and controls, air flow indicator and controls, temperature switch and controls, heater relay, and heater contactors.

CVI Drawing B193-6002 contains a bill of caterials for the heater control panel. This bill of uaterials cust be inspected to uncover any radiation susceptible caterials.

An inspection of the bill of caterials for the heater panel uncovers the organic caterials as listed in Attachtent 1. A review of Attachment 1 illustrates radiation tolerances for each of these caterials as 5

nea n ep rt -

. Our harsh environment is 5.7x10 Rads interin operation justification is thus demonstrated.

An in depth inspection of the fire protection panci is not necessary because the panel only provides an alarm upon high tecperature in the charcoal beds to the control room. For the water spray to be initiated, the operator cust operate one of two valves manually.

Both valves are located in the local area and with the high radiation conditions for this area icposed by a LOCA, the valves cannot be operated.

V. QUALIFICATION STATUS WITH REGARD TO INTERIM OPERATION JUSTIFICATION Based on the informaticn supplied in this review, interin operation to June 1982 is justified for the equipcent of 9645-M-632.

VI. FOLLOW UP PROGRAM Qualification docueentation will be upgraded prior to June 1982 yiciding full qualification to NUREG 0588 requirements.

%V E5rg2

s ATTACHMENT 1 A. Organic materials extracted f rom heater controls bill of material (Ref. :

CVI DWG. B193-6002)

ORGANIC RADIATION ITEM COMPONENT MATERIAL TOLERANCE 8 Microswiten Phenolic 2x10hRads Synthetic rubber 2x10 P#d8 6

Buna-N 6x10 Rada 10, 12, 14, Terminal Blocks Phenolic ? '. Pcds D

28, 29, 30 Fuse Blocks Phenolic >10 Rads 6

34, 36, 39, Westinghouse Similar to 1.4x10 Rads 42, 44, 45 Electrical Components MCC of Spec. (Noe IT E-018.0 6

48, 50, 52 Terminals Vinyl >10 Rads 54, 56, 58 60, 64, 100 Rockbestos cable ---

2x10 Rads 6

66 Stat-o-seal Buna-N tx10 Rads gh $

E5rg3

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B. Organic materials contained in heater control circuitry not found on CVI DWG. B193-6002.

ORGANIC RADIATION COMPONENT MATERIAL TOLERANCE 6

Watlow heater Silicone 10 ads Rubber 2x10 #

6 Ceramic > 10 Rads Dwyer 1900 Series Polyester Film 10 gads Air Flow Switch Polyvinyl Acetate 5x10 ads 6

Mica Filled 2x10 Rads Phenolic Polyester 10 gads Buna-N 6xg0 Rads Silicone 10 gads Acrylic 7xg0 gads Polyester Type 10 -10 Rads Resin g Cellulose fiber 10 Fads with zinc chloride Bisphenol A Type 10 -106Rads Nonylphenol 10 ^*

5 Diethylene 10 -10 Rads Triamine 0

Talc 10 Rads Mica 10

6 Trichloroethane 10 Rads 6

Eubber Base 10 Rads 6

Barksd41e Temp- Neoprene 1.7xg0 Rada erature Switch Buna-N 6x107 Rads Mylar 4x10 Rads 6

Phenolic 2xg0 Rads Thermoplastic 10 Rads (Note 2)

NOTES: 1) Westinghouse electrical components consist of a 480V/120V transformer and heater contactor similar to those provided in 480V. motor centrol centers, which have been tested to 1.4x10 6 Rads for Grand Gulf.

2) The thermoplastics exist in a micro switch sub-assembly within the Barksdale tenperature switcg. 'Ihis micro switch is a BZ series which has been tested to 10 Rads (Ref. EPRI E.Q. data bank). In addition, EPRI NP-2129 reports th t9 thermoplastics exhibit radiation tolerances up to 8.8x10 Rads.

E5rg4 f

s 1

1 SUPPLEMENT 2 I. EQUIPMENT DESCRIPTION Specification Nudber: M-050.1 l

Component: Drywell Purge Compressor Motors MPL Number: Q1E61-C001 A & B Manufacturer: Turbonetics i

Model Number: Frame: 445 TS

Enclosure:

TEFC-XT II. OUALIFICATION STATUS AT ORIGINAL SUBMITTAL !

Component was qualified to NUREG-0588 at the time of the original submittal (July 1981).

III. QUALIFICATION STATUS AT SUPPLEMENT 1 At this time no response was made concerning the Drywell Purge Compressor Motors since they are considered qualified.

IV. QUALIFICATION STATUS UPDATE During the NRC NUREG-0588 audit, the following questions were raised concerning the validity of the qualification of the drywell purge compressors.

1. What would be the expected compressor motor power consumption as a function of post-DBA containment temperature and pressure?

The compressor motor power consumption ir directly proportional to the mass being transported which is proportional to pressure. The drywell purge compressors will not automatically start until at least one minute into the accident, when the initiation setpoint

(LOCA plus 20 seconds) is reached. A review of attachment I demonstrates that pressure during compressor operation is 6.5 psig for a duration of 5.6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . Compressor operation with a containment pressure of 6.5 psig will require from 105% to 112% of the rated notor output. The 74.6 KW naneplate rating means that the expected power consumption will be from 78.3 KW to 83.5 KW as a result of conditions imposed by the DBA. This compares favorably to the test conditions of 15 psig which resulted in 22 hours2.546296e-4 days 0.00611 hours 3.637566e-5 weeks 8.371e-6 months of demonstrated operability at 143% load.

A27rgl

A

2. What would be the effects of 90% voltage per Reg. Cuide 1.9?

In the event the motor is required to operate at 90% voltage for the entire 5.6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months at peak operating pressure, the resulting motor temperatures would be increased by 23%. A review of test results reveals that peak temperatures expected at worst case suction conditions (6.5 psig) are 148*F, 145'F and 155'F for the Free end motor bearing, coupling end motor bearing, and motor winding respectively when compared to max test measurements of 260* f, 295*F, 305'F and max allowable value of 400*F, 400*F, 356*F, it can be seen that more than 23% margin exists.

3. Did testing monitor potential hot spots in the motor windings and bearings?

A total of six thermocouples were imbedded into the motor windings, and recorded an average motor winding temperature that varied only 5*F in the worst case. Six more thermocouples recorded the tempera-ture of bearings and drives. The excellent conduction within the motor windings and bearings make it extremely unlikely that hot spots would develop, much less go undetected, especially with the number of temperature measurements.

4. Could containment spray become entrained into the compressor, and impose excessive loads on the motor?

The attached profile shows that the peak 9.5 psig pressure falls to below 5.0 psig within five seconds following the DBA, while the compressor will not start until at least one minute into the accident when the initiation setpoint is reached. Because containment spray does not initiate until 9.0 psig is exceeded and maintained for a ten m.aute time delay, spray is not expected following a DBA.

In spite of the fact that no spray is expected, a canopy with a 2.5 foot radius will be installed over the compressor inlet. This will be completed prior to proceeding above 1% reactor power (vessel

. closed). Because the canopy will prevent spray entrainment, the 100% humidity test conditiens are considered bounding. The canopy will prevent the spray from being inducted into the compressor, using information obtained from " Industrial Ventilation", the Manual of Recommended Practice by the Committee on Industrial Ventilation (published by the American Conference of Governmental Industrial Hygienists, 1974 13th edition). Table 4-1, pages 4-5 presents a range of capture velocities (air flow) required to ensure entrainment of contaminants. Capture velocity for evaporation ranges from 50-100 ft/ min. The capture velocity required in spray booths is 100-200 ft/ min. With the canopy in place over the compressor inlets, the velocity at the edge of the canopy is conservatively predicted to be 27.5 f t/ min, well below the required velocity to entrain water droplets.

A27tg2 N'

s The containment spray is not expected to be initiated, but the addition of the canopy will ensure that water droplets will not be entrained by the compressor even in the unlikely event of containment spray initiation.

5. Will containcent SlT pressure adverrely impact motor seals?

In preparation for the containment SIT, all equipment manuf acturers were formally requested to identify whether special precautions would be required. Turbonic's (purge compressor vendor) reply was negative. The small pressure above that tested (17.25 vs. 15 psig) plus the slow rate of SIT pressurization poses no problems.

Similar compressors have been supplied by Turbonics which require continuous operation at 250 psig and 400*F.

V. STATUS WITH REGARD TO INTERIM OPERATION This item is qualified per NUREG-0588.

VI. FOLLUP UP PROGRAM None i

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O LD C' W O LD C N N e-- -

(blSd) 3 BASS 3dd

J SUPPLEMENT 2 I. EQUIP. DESCRIPTION Spec #: 9645-M-242.0 Component: Valves; Air actuated (in/out containment)

MPL Numbers: See Attachment la, Ib, Ic, ld Manufacturer: Will'am Powell Model No.: Solenoid (ASCO HTX 8320A20V)

Limit Switch (Micro LSQ-101)

Terminal Block (G.E. EB-25)

Position Switch (NAMCO EA740)

II. QUALIFICATION STATUS AT TIME OF ORIGINAL SUBMITTAL The original submittal separates these actuators by location; specific-ally, Auxiliary Building (51 valves) Room 1All2 (2 valves) and the containment (8 valves). The electrical components consist of an ASCO Solenoids, Micro Limit Switches, and a Terminal Block. NAMCO Position Switches were also identified on 32 of the actuator assemblics.

The actuators were listed as incomplete because no test reports had been received at that date, with the exception of the NAMCO Position Switch. The NAMCO test report did not address thermal aging for 40 years nor did it address flooding. However, operability during LOCA conditions and radiation exposure was addressed.

III. QUALIFICATION STATUS AT SUPPLEMENT 1 A. Terminal Blocks: the manufacturer was determined to be GE and the model number was found to be EB-25. The blocks are made of wood-fluor phenolic.

Justification of interin operation was to be done prior to fuel load and qualification completed by June 1982, or as soon thereaf ter as possible.

B. Micro-Switch (LSQ-101) A 3 page test report was received but radiation and thermal aging was not performed. The qualified life was unknown.

Justification of interin operation was to be done prior to fuel load and qualification completed by June 1982, or as soon thereaf ter as possible.

C. Sclenoid Valves (Model HTX) The test report for these valves was being acquired. The HTX valves contain Viton seals and discs. A qualified life of 41 years was calculated using an activation energy of 1.11 eV and data from a test report for model NP valves. The HTX valves are very similar to the NF valves differing only in the seal material, the disc holder material and the core guide material.

Pending completion of the evaluations the valves were considered justified for interim operation to June 1982. The equipment will be qualified by June 1982, or as soon thereafter as possible.

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_ _ _ - - _ - . - _ _ _ _ - - _ .. J

l l

l D.

NAMCO Position Switch (Model EA 740) which is greater than the previously usedThis .

value eV of 0.50 eV increased the qualified life to about 1 year. .

The flood level was revised from 130' l only one valve would be exposed to flooding.10" to 125' 4" which indicates The evaluation concerning flooding will be completed prior to fuel load.

The equipment will be qualified prior to June thereaf ter as possible. 1982 or as soon IV.

QUALIFICATION STATUS UPDATE A. Terminal Blocks _:_

This sub-component package. is being evaluated under the Electrical Interface The terminal blocks are justified for interim operation and will be qualified by June 1982 or as soon thereafter as possible .

,l B.

Micro-Switch (LSQ-101)

It has been determined that replacements for this switch.there are no qualified micro switch The Class lE circuits which are ~

attached to this switch will be swapped over to the NAMCO EA-740 switches which are already installed on 32 of the 61 valves The .

retaining valves will also be fitted with NAMCO EA-740 switches .

Qualification will of be the madeNAMCO EA-740 is addressed in section D be Modifications prior to fuel load.

C.

SOLEN 0ID VALVES (model HTX)

ASCO test report AQS21678/TR and Supplement

7 I has been submitted of 2). materials which envelope the Grand Gulf design (see um Ageing qualified at life. 268*F for 12 days has demonstrated on 8.2 year cycles and 30 days LOCA exposure at maximum values of 300 psig exceed qualification requirements.

backup files as Attachments 4A, 4B, 4C, SA, 5B, SC).(Profile comparisons are in the above, recent NRC infornation notices indicateInthat addition op to erability can not be materials areassured used. if radiation levels exceed 20 megarads and Viton findings: This has been reviewed with the following 1.

All air operated valves (in containment) at Grand Gulf are isolation valves which de-energize to perform their safety function, LOCA. with function times within seconds or minutes of a A 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months function time has conservatively been assumed .

2.

Only 12 valves are predicted to receive an accident dose in excess of 20 megarads over the 100 day accident.

in item 1 above, these valves have function times les As indicated "

hour. s than I dose 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months into the AccidentAttachment 3 demonstrates that the predicted ac is less than or equal to 13.6 MR.

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Flooding potential has been reviewed and it has been determined that two drywell isolation valves (P45 F003 and P45 F009) are subject to flooding. Attachment 4 is a failure mode and effects analysis which shevns that the valves will perform their safety related function prior to the flooding cor I tion. The failure modes identified will not cause the valve to change position.

D. NAMCO POSITION SWITCIIES (MODEL EA740)

Aging data is insufficient to determine an acceptable qualified life, however, LOCA testing for 30 days at maximum values of 80 psig and 346*F along with radiation exposure of 204 megarads compares very favorably with required accident profiles.

NAMCO Switches will be scaled as discussed in the electrical interface evaluation, therefore a momentary submergency of 10 seconds will not cause a circuit malfunction.

V. QUALIFICATION STATUS WITH R" GARD TO INTERIM OPERATION STATUS Based upon the above discussion and conclusions the components of the Bettis Air Operated Valves, which includes ASCO Model HTX Solenoid Valves, NAMCO Model EA-740 Position Switch and GE Model EB-25 Terminal Blocks, are justified for interim operation until June 1982.

V1. FOLLOW-UP PROGRAM The conversion from Micro Switch LSQ-101 to NAMCO EA-740 needs to be completed prior to fuel load.

The evaluation of the NAMCO position switch needs to be completed by June 1982 or as soon thereafter which should include additional testing to obtain a 1 cager qualified life.

The ASCO solenoids should only require a periodic maintenance program for Viton parts replacement be developed and that the evaluation be completed by June 1982 or as soon thereafter as possible.

B10rg3 M'

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Component

"*"" ***"#'#'Wm. Powell

__ Specification 9645-M-242.0 Valves with Hitler Pneumatic actuators

( EXHIBIT F Sheet 1 of 2

(~' -

Attachment la

(_Tri 4 0 4. I M9)

The Hiller Pneumatic Actuators are attached to the following Um, Powell valves:

Valve Hiller Location Se rvice* Model No. Room System P lant I .D .

3 12SA-A015 1A305/

Nuclear Boiler B21 F113 3 10SA-A044 1A111 RHR E12 F203

3 16SA-A014 1A305' RWCU G33 F235 2 10SA-A024 1A204 Filt. Demin. G36 F101 3 10SA-A024 1Alli G36 F108 3 10SA-A024 1Alli G36 F109 3 10SA-A021 1A111 Filt. Demin.(FPCC) G46 F253 Condensate & 3 16SA-A008 1A222 P11 F047 e uel ng ater 16SA-A008 1A222 Pil F061 3 St rage and Pil F066 3 16SA-A008 1A201 ransfer 16SA-A008 1A201 Pll F067 3 1A201 Pll F062 3 14SA-A010

( 2 12SA-A015 1A319 P11 F075 P-i- P11 F064 3 16SA-A008 1A201 16SA-A-08 1A201 Pil F065 3 3 10SA-A018 1A301 Makeup Water P21 F024 1 10SA-A015 1A215 Standby Service P41 F239 1 10SA-A015 1A215 Water P41 F240 2 12SA-A014 1A111 Drainage System P45 F062 2 12S A- A014 LAlli P45 F068 2 10SA-A015 1A215 P45 F099 2 14SA-A004 1Alli P45 F159 2 14SA-A004 1Alli P45 F160 2 14SA-A004 1A111 P45 F161 2 10SA-A014 1A111 P45 F163 l 2 14SA-A004 1Alli P45 F158 3 10SA-A016 1A401 Service Air PS2 F160A 2 10SA-A012 1A319 PS2 F105 3 10SA-A016 1A403 PS2 F221A I 1A319 P53 F001 2 10SA-A012 Instrument Air 3 10SA-A015 1A403 PS3 F026A 1 20SA-A009 1A220 Suppression Pool P60 F001 2 20SA-A011 1A205 Cleanup P60 F009

( 2 20SA-A011 1A205 P60 F010 pE P60 F021 1 20SA-A009 1A220 1A320 P60 F003 3 20SA-A010 3 20SA-A010 1A320 P60 F004 3 20SA-A010 1A301 P60 F007 1A301 20SA-A010 P60 F008 3

')

. . _ . .- = -

_ _ _ -_ . . . . . . . . w

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9645-M-242.0 Valves with Hiller -

' "" ** "#'# Wm. Powell --. SP ecification s Pneumatic actuators EXHIBIT F 2 Sheet 2 of 8F Attachment la (Continued)

Valve Hiller Location System ?lant I.D. Service

Model No. Room _

P64 F282A 3 16SA-A007 1A222 Fire Protection P64 F2828 3 I 16SA-A012 1A222 P64 F283A 3 16SA-A007 1A211 P64 F283B 3 16SA-A007 1A211

P64 F332A 3 Later LA201 P66 F029A 3 10SA-A014 1A302 Domestic Water Plant Chilled Water P71 F304 2 14SA-A008 1A302 P71 F306 2 14SA-A010 1A302 P71 F300 3 10SA-A015 1A322 P71 F302 2 10SA-A015 1A302 P71 F148 2 10SA-A018 1A319 P71 FISO 2 10SA-A018 1A319

' Service Code: 1 - System Isolation

( g 2 - Containment Isolation 3 - Auxiliary Bldg. Isolation i .

4 i

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, Valves with Hiller Pneumatic actuators EXHIBIT F *

Attachment Ib Sheet 1 of 1

..')

J dC$ Welt)

The Hiller Pneumatic Actuators are attached to the following Wm. Powell valves:

Valve Hiller System Plant-ID Service Model No. (Room) i Floor and P45F003 D-Well Iso. 10SA-A017 1A112 Equipment Drains P45F009 10SA-A017 1A112 9

' 8 t'eww-' -4,n ywn. m,-w 9 ra.C .n , yy. -m+ . , -

_ _ _ _ . . . _ _.e C9po n t Valves eith Pniumatic Manufacturcr ya, powell Specificcticn 9645-M-242.0

' Hiller Actuators EXHIBIT F

- -s. Attachment Ic ,

' Sheet 1 of I (L 0 on'4e A rwc,q)

The Hiller pneumatic actuators are attached to 'the following Wm. Powell valves:

Valve Hiller Location System Plant ID Se rvice* Model No. (Room)

Floor and Eouipment Drains P45F061 2 12SA-A013 A110 P45F067 7 12SA-A013 A110 P45F004 3 10SA-A017 A110 P45F010 3 10SA-A017 A110 P45F098 7 10SA-A017 A110 Plant Chilled P71F149 7 10SA-A022 .A313 Water Filter-DEMW (RWCU) G36F106 2 10SA-A023 A313 Combustible E61F020 3 12SA-A019 A509 Cas Control

?+,

'#

Service Code 1 - System Isolation 7 - Containment Isolation 3 - Drywell Isolation I

t The following Wm. Powell Valves are sabject to wetting:

l 1

1 Flood Froth Spray Valve (5 Sec.) (5 Sec.1 (17 Days) l '

P45F061 Yes No Yes P45F067 Yes No Yes P45F004 Yes No Yes P45F010 Yes No Yes P45F098 Yes No Yes

, P71F149 No Yes Yes

~~

G36F106 No Yes Yes

( ,) E61F070 No No Yes

, __.._____._ a u____-- -

/

es Exhibit F Attachment Id Position Switches Namco 9645-M-242.0 Namco EA740 Remote Position Switches are Mounted on the Following Air Actuated Valves:

System . Plant Room Actuator Cate- Wet-ID No. No. Type gory ting Service Floor and P45 F003 1A112 Air a 1 Drywell Isolation Equipment Drain P49 F009 1A112 Air -

a 1 Filt. Demin. G36 F106 1A3'13 Air a 1&3 Containment Isolation (RWCU) '

Floor & Equip. P45 F004 1A110 - Air a 163 Drywell Isolation Drain P45 F010 1A110 a 1&3 P45 F061 1A110 a P45 F067 1&3 Containment Isolation 1A110 a 163 P45 F098 1A110 a 1&3 Residual Heat

-Removal E12 F066B 1A105 b E12 F066C 1All8 b

-s E12 F203 1Alli Air a NA Aux. Bldg. Isolation

. Filter Demin. G36 F101 1A225 Air a (RWCU) G36 F108 NA Containment Isolation 1Alli Air a NA Aux. Bldg. Isolation C36 F109 1Alli a Filter Demin G46 F253 1Alli Air a NA Aux. Bldg. Isolation .

(FPCC)

Floor & Equip. P45 F062 1Alli Air a NA

Containment Isolation Drains' P45 F068 1A111 a P45 F099 1A215 a P45 F158 1Alli a P45 F159 1Alli a P45 F160 lAlll , a P45 F161 1Alli a .

i P45 F163 1Alli a Suppression P60 F001 1A220 Air a NA System Isolation Pool Cleanup P60 F003 1A320 a Aux. Bldg. Isolation l .P60 F004 1A320 a

! P60 F007 1A301 a P60 F008 1A301 a 1

l P60 F009 1A205 a containment Isol'ation P60 F010 1A205 a P60 F021 1A220 a System Isolation Domestic Water P66 F029A 1A302 Air a NA Aux. Bldg. Isolation

Wetting Code =1 - Flood 2 - Froth 3 - Spray L __. j

i ATTACHMENT 2 COMPARISON OF TEST VALVES TO HTX VALVES Vcive ID Function Disc & Seals Disc Holder Coil NP 8344 Tested Ethylene Propylene Stainless Steel Class H NP 8320 Tested Ethylene Propylene Stainless Steel Class H NP 8316 Tested Ethylene Propylene Stainless Steel Class H NP 8321 Tested Ethylene Propylene Stainless Steel Class H NP 8323 Tested Ethylene Propylene ' Stainless Steel Class H XFT 83165 Tested Viton-A Viton A Class H NP 8344 Tested Viton-A Viton A Class H HTX 8320 A20V In Plant Viten-A Stainless Steel Class H B10rg4 ,td

/-

ATTACHMENT 3 BETA & CAMMA CAMMA ACCIDENT DOSE NORMAL DOSE VALVE LOCATION (MEGARADS)* (MEGARADS) 1P45-F003 1 A112 (Drywell) 13.6 1.8 1P45-F009 1A112 (Dryvell) 13.6 1.8 1P45-F061 1A110 (Ctet Bldg) 2.6 0.0035 1P45-F067 1A110 (Ctat Bldg) 2.6 0.0035 1P45-F004 1A110 (Ctet Bldg) 2.6 0.0035 1P45-F010 1A110 (Ctet Bldg) 2.6 0.0033 1P45-F098 1A110 (Ctet Bldg) 2.6 0.0035 1P71-F149 1A313 (Ctet Bldg) 2.6 0.000035 1G36-F106 1A313 (Ctet Bldg) 2.6 0.000035 1E61-F020 1A509 (Ctet Bldg) 2.6 0.0035 IB21-F113 1A305 (Aux Bldg) 6.08 0.18 1C33-F235 1A305 (Aux Bldg) 6.08 0.18

based on 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months operability B10rg5 v[

Jh{bclt en eat h

/

FAILURE MODES AND EFFECTS ANALYSIS FOR 3XEMPTION FOR FLOODING DRYWELL ISOLATION VALVES FUNCTION:

The follots a air actuated valves provide drywell to containment isolation:

Valve System ~

IP45-F003 Floor and equipment drain system IP45-F009 Floor and equipment drain system FAILURE MODES:

The following electrical failure modes could occur due to the flooding conditions:

1. Short the device output

2. Open the device output

3. Short the device oatput to ground FAILURE EFFECTS:

These isolation valves receive an " auto close" signal upon a loss of coolant accident (LOCA), and remain closed. The effects of the above failure modes would not cause the actuation 'of these valves to the oper.

position. Only a LOCA, not a high energy line break, will flood these

' valves.

Drywell isolation is required to prevent bypass of the suppression pool during post-LOCA blowdown. Flooding of the 'dr' ywell is a consequence of A-the subsequent drywell negative pressure transient. At this point, and for the remainder of the accident, the drywell isolation function of these valves is not required. Therefore, these valves de not require qualification for flooding However, they must be evaluated for the other harsh parameters inside containment. The following evaluation

.already submitted to the NRC on July 1,1981, and September 1,1981, are applicable to these valves:

Spec. Manufacturer Component 9645-M-242.0 ASCO HTX 8320 A20V Solenoid Valves MICR0 Switch LSQ-101 Limit Switches NAMCO EA740 Limit Switches GE Terminal Blocks t CONCLUSION:

Based on the above discussion, ~it can be concluded that the failure of these valves in any mode described above would not adversely affect plant safety.

6e 4

/

SUPPLEMENT 2 I. EQUIPMENT DESCRIPTION Specification Number: M-242/M-251.0 Component: Valves- Limitorque D.C. Metor Actuated (Outside Ctat.) See Attachnent 1 Manufacturer: 1. Class B Insulation D.C. Motor - H.K.

Porter / Reliance 2, 4 T cin Limit and Torque Switches -

Limitorque

3. Hook-up Wiring - Flamtrol

4. Terminal Blocks - Marothon 300, Buchanon 0222/0524, GE-EBS (Qualification addressed in Electrical interface review Model Number: Series SMB II. QUALIFICATION STATUS AT ORIGINAL SUBMITTAL Incomplete due to fact that no test reports were available.

III. QUALIFICATION STATUS AT SUPPLEMENT ONE There was no change in qualification status at the time supplement one was released.

IV. QUALIFICATION STATUS UPDATE Discussions with the manufacturer revealed that the only difference between the DC Actuator and the AC Actuator is the DC or the AC motor.

The limit and torque switches, the hook up wiring, and the Class B motor insulation are all the same. The DC and AC actuators belong to tt- same generic group of Limitorque series SMB, which have been qualified for outside containment use per Limitorque Test Reports E0058 dated 1/11/80 and B003 dated 6/7/76. The Limitorque Test Report B0003 was performed using C motors, otherwise the same components as used in DC actuators were < sted. Both insulation systems are Class B, and identical materials were used in construction. All details of similarity will be documented in the Final Qualification documentation.

B9rgl

The maximum predicted environments to which the DC actuators are subjected 19 a maximum temperature of 312*F 100% humidity, 25 psia, and 1.28x10 RADS, with a noymal maximum service temperature of 105'F.

Test conditions include 2x10 RADS, 250*F for a period of approximately 22 hours2.546296e-4 days 0.00611 hours 3.637566e-5 weeks 8.371e-6 months and lower values for 16 days. The bounding temperature for the DC actuator switches outside of containment reaches 312*F, but holds at this temperature for only about 25-30 seconds, and drops sharply to about 220*F: holds there for less than en hour, and ramps to 105*F in less then 100 days. Because tha actuators are completely enclosed by metallic enclosures, the actual temperature to which the internal parts will be exposed is expected to be much smaller, as the enclosures will provide a buffer for temperature spikes for the shart duration.

The maximum pressure predicted at Grand Gulf is a 25 psia pressure spike for second duration, while the device was tested for over 0.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months at 39.7 psia. Based on this, the device is qualified for environmental pressure.

The bottom of the test chamber was filled with water, which would produce a 100% relative humidity for the duration of the test. This meets the bounding requirements for relative humidity.

Thermal aging tests ran for 199.8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months at 165*F and 0 psig pressure, with 100% humidity. Actuation and test motors cycling ran for 9 days, with a total of 176 cycles. (h1 the basis of report 30058, the DC motor should be considered qualified for the 40 year expected life.

The switches have been qualified under AC valve actuators, and being the same except for motors, the switches for DC actuators are qualified.

Hook-up wiring has been identified by Limitorque as Raychem Flamtrol.

The Raychem Flantrol Insulation System has been extensively tested and is qualified to IEEE 383-1974 for FIRL Report F-C4033-1 dated January 1975.

V. !UALIFICATION STATUS WITH REGARD TO INTERIM OPERATION On the basis that the AC motor actuated Limitorque valve is qualified, and this device is constructed of the same materials, this item should be qualified for Interio Operation. The differences in parts between an AC and a DC motor is small, the DC motor containing a few more moving parts, buc these parts are all metal. All details of similarity will be established in the ff nal qualification documentation.

Vi. FOLLOW UP PROGRAM The review to qualify Limitorque DC motor actuated valves will be completed by June 1982.

I g.tOltS B9rg2

. ATTACHMENT 1 8

Normal doce rate for all rooms listed is 5.3x10 RADS (Table B-2)

Room 1A104 Equipment No. Dosage (from Table B-8) 6 E51 F019 8.17x10 RADS 5

E51 F046 8.28x10 RADS 6

E51 F022 6.84x10 RADS 6

E51 F013 6.27x10 RADS 6

E51 F031 6.92x10 RADS E5.1 F045 1.0x10 RADS matimum temperature is 295'F (Figure B-25) ma:<imum pressure is 25 psia (Figure B-23)

Room 1A101 5

E51 F010 6.95x10 RADS (from Table B-8)

Room 1A121.

5 E51 F059 5.9x10 RADS (Table B-8)

Room 1A203 E51'F068 1.28x10 RADS (Table B-8) l maximum temperature is 312*F (Figure B-30) maximum pressure is 18.0 psia (Figure B-28) 1 B9rg3 p'd z--

1 SUPPLEMENT 2 I. Equipment Description SPECIFICATION NO.: 9645-M-257.0/M258.0 COMPONENT: Butterfly Valves with Bettim Air Actuators MPL NOS.: See Attachment la, Ib iANUFACTURER: Henry Pratt MODEL NO.: Solenoid (ASCO NP8321 NP8316)

Position Switch (Namco EA740)

Terminal Block (TNR/C inch 8-141)

II. Qualification Status at Time of Original Submittal Because no test report was submitted this review was considered incomplete.

III. Qualification Status ot' Supplement 1 None Submitted IV. Qualification Status Update A. Terminal Block:

This sub-component is being evaluated under the Electric Interface package. The terminal blocks are justified for interim operation and will be qualified by June 1982 or as soon thereaf ter as possible.

B. Solenoid Valves (Model NP8321, NP8316)

Asco Test Report AQS21678/TR has been submitted demonstrating qualification for seven tested valves which are of the same type as used at Grand Gulf.

Aging at 268'F for 12 days has demonstrated a 20 year qualified life. Radiation exposure of 200er, near aging at. 40,000 cycles and 30 days LOCA esposure at maximum valves of 300*F and-110 ;

psig exceed qualification requirements (profile comparisons.are in backup files as attachments 2A, 2B, 3A,-33). In addition to the above, recent NRC informati a notices indicate that operability can not be assured if radiation levels exceed 20 magarads and viton materials are used. This has been reviewed with the following findings:

1. All air operated valves '(in containment) at Grand Gulf are isolation valves which de-energize to perform their safety function, with function times within' seconds or minutes of a LOCA. A 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months function time has conservatively been assumed.

2. Only 9 valves are cedicted to receive an accident dose in excess of 20 magarads over the 100 day accident, as J

O indicated in Item 1 above, these valves have function times less than I hour. Attachecnt 4 demonstrates that the predicted accident dose 1 hours1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months into the accident is less than or equal to 13.6 nr (Attachment 4 in qualification files).

C. Namco Position Switches (Model EA740)

Aging data is, insufficient to determine an acceptable qualified life, however LOCA testing for 30 days at maximum values of 80 psig and 346*F along with radiation exposure of 204 magarads compare very favorable with required accident profiles as shown in Attachments 2A, 2B, 3A, 3B (ir qualification files).

V. Qualification Status with Regard to Interim Operation Status Based upon the above discussion and conclusions the components of the Bettis Air Operated Valves which includes Asco nodels NP8321, and NP8316 solenoid valves, Namco model EA-740 position switch and TWR/ Cinch model 8-141 terminal blocks are justified for interim operaticn until June 1982.

VI. Follow Up Program The evaluation of the Namco position switch needs to be completed by June 1982 er as soon thereafter as possible.

M-251ltso

\

=Compod3nt Air actuatzd butterfly Phnufceturcr llenry Pratt Spscificati:n 9645-M-257.0 valvss 9645-M-258.0 Cp ,

~

. Attachment la ,

Sheet 1 of 1

.) .

ASCO Solenoid valves NP8321A6E, NP831655, and NP831654E and NAMCO EA170 position switches are used on the following Bettis actuators on Pratt valves:

Valve Location System Plant ID Se rvice M!Iekko. (Room)

Plant Service Water P44F117 Aux. Iso. T-316A-SR2 1A101 P44F118 1A120 P44F119 1A120 F44F120 T-420 -SR1 1A120 P44F121 1A120 P44F122 T-416S R3 1A101

P44F123 1A101 Aux. Bldg. Vent T41F006 /'. T-312B-S R3 1A527 T41F007 1A527

'; Fuel Handling Area Vent T42F019 T-412-S R4 1A519 T42F020 1A519 T42F003 T-420-SR1 1A606 T42rV04 1A606 Fuel Pool Cooling G41F019 521C-SR80 1A527

& Cleanup G41F043 732C-SR80 1A527 G41F045 1A527 Ctmt. Cooling M41F007 _ 1A405 M41F008 1A405 M41F036 1A405 M41F037 1A405 M41F011 Ctat. Iso. T-312B-S R3 1A405 M41F035 1A405 Fuel Handling' Area Vent T42F011 Aux. Iso. CB520-SR80 1A606 7427012 1A606 Co=bustible Gas Control E61F009 521C-SR80 1A405 E61F057 1A405 Condensate & Refueling P11F130 Ctmt. Iso. 721C-SR80 1A115 Water Transfer & Storage P11F131 , 1A115 f

~

. Comp'onsnt Nanufacturar Air cetuetta buttsrfly lianry Prctt SP:cificctisn_9645-M-257.0 C- valvso 9645-M-258.0

(- e -

Attachment Ib Sheet 1 of_ 1 ASCO Solenoid valves NP8321A6E, NP831655, and NP831654E and NAMCO EA170 position switches are used on the following Bettis actuators on Pratt valves:

Valve Bettis Location System Wetting, P,lant ID Service Model No. IRoom) 1 E61F007 D-Well Iso. 521C-SR80 1A509 Combustib1E Gas 1 E61F010 Cnfr. Iso. 521C-SR80 1A110 Control 1 E61F056 1A110 Containment 1 M41F012 Cnfr. Iso. T-3123-SR3 1A110 Cooling 1 M1F013 D-Well Iso. 1A110 NA MlF015 1All2 NA M41F016 1A112 1 M41F017 1A110 1 M lF034 CTMI. Iso. lA110 Wetting Spray (12 Days) 2 - Flood 3 - Froth e

l 6

e b

L

4

.1 I

(N SUPPLEMENT 2 T

NSSS 1

l l

Equipment Description l A. Purchase Part Drawing Nos.: 163C1559, 163C1560. 163C1561, 163C1563, i 163C1564 B. Component: Differential Pressure Transmitters, Gage Pressure Transmitters, and Absolute Pressure Transmitters C. Manufacture: Rosemount, Inc.

D. Model No.: 1151DP, 1151GP, 1151AP Qualification Status at Original Submittal (July 1981)

The initial NUREG-0588 review of the Rosemount Model 1151 transmitter was based on the worst case environment for each of the GE Purchase Part Drawing Number (PPD #) associated with the Model 1151's purchased for Grand Gulf by GE.

The end result of using this approach to review qualification status was that none of the Model 1151 transmitters met Category 11 of NUREG-0588.

The model 1151's did not meet Category II of NUREG-0588 because of the following reasons:

1. Aging was not adequately addressed

2. The impact of design changes made to Model 1152 relative to Model.

1151 as they impact radiation tolerance.

Qualification Status at Supplement 1 Submittal (September 1981)

In the supplement I submittal, MP&L noted that Model 1151's were not qualified to Category II of NUREG-0588 and that interim operation justification would be provided prior to fuel load.

Qualification Status Update (December 1981)

Since the original submittal and the supplement 1 submittal, an extensive re-evaluation of the Model 1151 transmitters at Grand Gulf has been conducted.

The results of this extensive evaluation has produced the following:

1. 19 Model 1151, transnitter MPL's have been replaced with Model 1152-

"T0280" transmitters.

2. 1 Model 1151 MPL has been replaced with a Gould Model PD-3018 transmitter.

3. 21 Model 1151 transmitter MPL's were changed.from NUREG-0588 Category "A" to Category "B" (Based on Appendix E of NUREG-0588) 4 1 Model 1151 transmitter MPL (B21-N078) must be replaced prior to uel load with a Model 1152 "T0280" transmitter.

?<

d' 5. Five (5) grouping of Ifodel 1151 transmitter MPL's was established:

1) pressure integrity only; 2) non-harsh pressure temperature and humidity; 3) function time less than 1.0 hour0 days 0 hours 0 weeks 0 months ; 4) exempt; 5) replace prior to fuel load

6. Failure Mode and Effects Analysis have been performed on all Model 1151 transmitters.

A. Gro'ip 1 (Pressure Integrity)

For this group, the re-evaluation established the only safety function served by the following Model 1151 transmitter MPL's was to maintain pressure integrity (Category B):

MPL# PPD # MPL# PPD #

B21-N027 163C1560 C34-N017 163C1560 B21-N032 163C1560 C41-N004 163C1563 B21-N044 163C1560 E12-N013 163C1560 B21-N058 163C1564 E12-N026 163C1563 B21-N099 163C1561 E12-N028 163C1563 B33-N011 163C1560 E12-N050 163C1564 B33-NO37 163C1560 E12-N051 163C1564 B33-NO38 163C1560 E12-N053 163C1563 B33-N040 163C1563 E12-N057 163C1563 C34-N003 163C1560 E12-N058 163C1564 C34-N004 163C1560 E22-N052 163C1563 C34-N008 163C1563 E51-N007 163C1563 C34-N005 163C1563 For this group of Model 1151 transmitter MPL's, a service life - 10 years was established by performing a detailed aging analysis on the materials B. Group 2 (Non-Harsh Pressure, Temperature, and Humidity)

The only harsh environment this group of Model 1151 transmitter MPL's were exposed to was radiation. This group of Model 1151 transmitters consists of the following MPL's:

MPL# PPD # MPL# PPD #

E12-N007 163C1561 E32-N054 163C1561 L E12-N015 163C1561 E51-N003 163C1561 E22-N005 163C1561 E51-NO35 163C1561 E22-N051 163C1564 E51-N050 163C1564 E32-N059 163C1561 E51-N052 163C1564 E32-N061 163C1564 E51-N056 163C1564 For this group of Model 1151 transmitter MPL's, a service lite = 5 years was established by performing a detailed aging analysis on the materials.

The mag predicted radiation exposure for ang one of these transnitters is 2.0x10 Rads and the tested value is 2.0x10 Rads.

4 C. Group 3 (Function Time Less Than One Hour)

For this group of Model 1151 transmitter MPL's, the function time for the transmitters to perform their safety function is one (1) hour or less.

This group of Model 1151 transmitters consists of the following MPL's:

MPL# PPD # MPL# PPD #

B21-N081 163C1561 E31-N088 163C1561 E31-N086 163C1561 E31-N089 163C1561 E31-N087 163C1561 For this group of Model 1151 transmitter MPL's, a service life = 5 years was established by performing a detailed aging analysis on the materials.

The required LOCA environments for Grand Gulf for a one (1) hour time period are as follows:

1. Pressure = 30 psia, max

2. Temperature = 200*F max

3. Humidity = 100% mag

4. Radiation = 1.2x10 Rads TID The test data / analysis demonstrates qualification of the Model 1151 as follows:

1. Pressure: The pressure integrity was established by the following:

a. Static Stress Analysis

b. Aging analysis on seal materials

c. Similarity of Model 1151 to Model 1152 (which was tested at 84.7 psia for one (1) hour)

2. Temperature: Tested at 300*F for four(4) hours

3. Humidity: Sinilarity of Model 1151 to Model .1152 (which was tested at 100% humidity for 50 hours5.787037e-4 days 0.0139 hours 8.267196e-5 weeks 1.9025e-5 months ) 6

4. Radiation: Tested at 2x10 Rads D. Group 4 (Exempt from NUREG-0588 Review)

For this group of Model 1151 transmitter MPL's, the re-evaluation established that they should be exempted from NUREC-0588 review because they were either exposed to a mild environment, Non-Class 1E, or not required post LOCA/HELB. This group of Model 1151 transmitters consists of the following MPL's:

MPL# PPD # Reason Enempted E21-N003 163C1561 Mild environment E21-K050 163C1564 Mild environment E21-N054 163C1563 Non-Class IE G41-N011 163C1559 Not required Post LOCA/HELB G41-N012 163C1559 Not required Post LOCA/HELB G41-N024 163C1559 Not required Post LOCA/HELB

/- ~4-E. Group 5 (Replace Prior to Fuel Load)

This group consists of only one (1) Model 1151 transmitter MPL (B21-N078; PPDP 163C1564). This Model 1151 transmitter must be replaced because of the following:

1. Function time of 100 days 6 6

2. Radiation exposure of 7.2x10 Rads; qualified for 2.0x10 Rads The model 1151 transmitter is being replaced with a Rosemount Model 1152 "T0280" transmitter. Thg Model 1152 "T0280" trangmitter has radiation qualification of 12.6x10 Rads (Required - 7.2x10 Rads). The qualification of the T0280 Model is discussed further in Iten F below.

F. Qualification of the 1152 "T0280" Model and the Gould PD-3018 Model is as

_follows:

1. Gould Model PD-3018 This transmitter is qualified for its application and was reviewed by EQB during Grand Gulf's site audit of October 19-22, 1981.

Rosenount Model 1152 "IO280" This transmitter has been tested as follows:

Time Pressure Temperature Humidity 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 84.7 paia 316*F 100%

7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months 70.1 psia 303"F 100%

42 hours4.861111e-4 days 0.0117 hours 6.944444e-5 weeks 1.5981e-5 months 20.7 psia 230*F 100%

6 Radiation: Test value of 12.6x10 Rads Also see attached Supplement 2 for Model 1152 transmitters Qualification Status with Regard to Interim Operation Justification The qualification status update section above establishes the interin operation justification for the Model 1151 transmitters MPL's identified in Group A through F above.

Follow Up Program The Rosemount Model 1151 transmitters identified in Group B, C, and E above will be replaced as follows:

1. Replaced with Rosemount Model 1152 "T0280" transmitters and qualified to Category 1 of NUREG-0588 by June 1982 or as soon thereafter as possible. ,

2. Replaced with Rosemount Model 1153B transmitters which are qualified to Category 1 of NUREG-0588 by June 1982 or as soon thereafter as possible.

Y SUPPLEMENT 2 NSSS Equipment Description A. Purchase Part Drawing Nos.: 169C8391, 169C8392, 169C8393, 169C8394, 169C8969 B. Component: Differential Pressure Transmitters, Gage Pressure Transmitters, Absolute Pressure Transmitters C. Manufacturer: Rosemount, Inc.

D. Model No.: 1152DP, 1152GP, 1152DP "T0280", 1152GP "T0280", 1152AP "T0280" Qualification Status at Original Submittal (July 1981)

The initial NUREG-0588 review of the Rosemount Model 1152 transmitter was based on the worst case environment for each of the GE Purchase Part Drawing Number (PPD #) associated with the Model 1152's purchased for Grand Gulf by GE.

The end result of using this approach to review qualification status was that none of the Model 1152 transmitters met Category II of ITUREG-0588.

The model 1152's did not meet Category II of NUREG-0588 because of the following reasons:

1. Aging was not adequately addressed

2. The impact of design changes made to Model 1152 relative to the T0280 Model which was qualified to different Icvels.

Qualification Status at Supplement 1 Submittal (September 1981)

In the Supplement 1 submittal, MP&L noted that Model 1152's were not qualified to Category II of NUREG-0588 and that interim operation justification would be provided prior to fuel load.

Qualification Status Update (December 1981)

Since the original submittal and the Supplement I submittal, an extensive re-evaluation of the Model 1152 transuitters at Crand Gulf has been conducted.

i The results of this extensive evaluation has produced the following:

1. The number of Model 1152 transmitter MPL has increased from 19 to 38 as a result of Model 1151 transmitters being replaced by Model

'1152 transmitters.

2. 1 Model 1152 transmitter MPL (B21-N095) must be. replaced prior to fuel load with a Model 1152 "T0280" transmitter.

3. Five (5) grouping of Model 1152 transmitter MPL was established:

1) Function time less 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ; 2) non-harsh pressure, temperature, and humidity; 3) not qualified to Category II requirements of NUREG-0588; 4) replace prior to fuel load; 5) exempt

+ 4. Failure Mode and Effects Analyses have been performed on all Model

'1152 transmitters.

A. Group 1 (Function Time Less Than 24 Hours)

For this group of Model 1152 transmitters, the function time for the transmitters to perform their safety function is 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or less. This group of Model 1152 transmitters consists of the following MPL's:

MPL# PPD # MPL# PPD #

B21-N068 169C8393 E31-N076 169C8391 B33-N014 169C8391 E31-N077 169C8391 B33-N024 169C8391 E31-N083 169C8392 C71-N050 169C8969 E31-N084 159C8392 E22-N054 169C8392 E31-N085 169C8394 E31-N075 169C8391 E51-N051 169C8392 B21-N080 169C8392 For this group of Model 1152 transmitter MPL's a service life = 10 years was established by performing a detailed aging analyses on the materials.

The required LOCA environments for Grand Gulf for a 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months time period are as follows:

Time Pressure Temperature __ Humidity Radiation 6

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 30 psia 200*F 100% 7.2x10 Rads Test data for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is as follows:

Pressure ' Temperature Humidity Radiation 6

84.7 psia 230*F 100% 12.6x10 Rads B. Group 2 (Non-Harsh Pressure, Temperature and Humidity)

For this group cf Model 1152 transmitter MPL's, the only harsh environment they are exposed to was radiation. This group of Model 1152 transmitters consists of the following MPL's:

MPL# PPD # MPL# PPD #

E12-N052 169C8392 E32-N051 169C8969 E12-N055 169C8394 E32-N055 169C8394 l E12-N056 169C8394 E32-N056 169C8969 l E22-N050 169C8394 E51-N053 169C8394 E22-N056 169C8392 E51-N055 169C8394 For this group of Model 1152 transmitter MPL's, a service life = 10 years was established by performing a detailed aging analysis on the materials.

The mag predicted radiation exposure for any6 ne f these transmitters is 7.2x10 Rads and the tested value is 12.6x10 Rads.

C. Group 3 (Not Qualified to Category II of NUREG-0588)

For this group of Model 1152 transmitter MPL's, it has been determined they do not meet Category II of NUREG-0588 because they are required to function for 100 days (tested for a 50 hour5.787037e-4 days 0.0139 hours 8.267196e-5 weeks 1.9025e-5 months time period). This group of Model 1152 transmitters consists of the following MPL's:

MPLf PPD # MPL# PPD #

B21-N062 169C8394 B21-N094 169C8969 B21-N067 169C8969 E12-N062 169C8969 B21-N073 169C8392 E32-N050 169C8394 B21-N091 169C8392 E32-N058 169C8394 Interim operation justification is based on the following:

1. Failure Mode and Effects Analysis for the above Model 1152's have been developed which indicate failure will not be detrinental to plant safety.

2. 50 hours5.787037e-4 days 0.0139 hours 8.267196e-5 weeks 1.9025e-5 months of LOCA testing exceeding the first 50 hours5.787037e-4 days 0.0139 hours 8.267196e-5 weeks 1.9025e-5 months of Grand Gulf's LOCA enviror. cents. 6 6

3. Radiation testing of 12.6x10 Rads vs. required of 7.2x10 Rads.

4. Aging analysis has established a service life of four (4) years based on detail review of materials.

5. All of the above model 1152's are the 1152"T0280" Models.

D. Group 4 (Replace Prior to Fuel Load)

This group consists of only one (1) Model 1152 " Regular" transmitter MPL (B21-N095; PPD # 169C8391). This Model 1152 transmitter must be replaced because of the following:

1. Function time of 100 days 6 6

2. Radiation erposure of 7.2x10 Rads; qualified for 5.0x10 Rads This model 1152 " Regular" transmitter is being replaced with a Rosecount Model 1152 "T0280" transmitter. Interim operation justification is based on the five (5) reasons stated above in Item C above (Group 3).

E. Group 5 (Exempt)

For this group of Model 1152 transmitter MPL's, the re-evaluation has established that they should be exempted from NUREG-0588 review because they were either exposed to a mild environment, non-Class IE, or not used at Grand Gulf. This group of 1152 transmitters consists of the following MPL's:

MPL# PPD # Reason Exempted B21-N097 169C8394 Not installed at Grand Gulf E21-N051 169C8392 Mild environment E21-N052 169C8394 Mild environment E21-N053 169C8394 Mild environment E31-N080 169C8392 Non-Class IE (not safety related)

E31-N081 169C8392 Non-Class 1E (not safety related)

0 Qualification Status With Regard to' Interim Operation Justification The qualification status update section above establishes the interin operation justification for Model 1152 transmitter MPL's identified in Group A through E above.

Follow Up Program The Rosemount Model 1152 transmitter will be s_.ilified to Category I of NUREG-0588 by test by ' June 1982 or as soon thereaf ter as possible.

( \.

\ ATTACHMENT NO. 2 or 6.0 ACCIDENT ENVIRONMENTS 6.1 GENERAL In order to ensure an adequate basis for the review, Grand Gulf FSAR LOCA/

HELB pressure, temperature, humidity, and radiation environmental conditions were evaluat,ed. Where required, plant-unique environmental conditions .

were developed using the Category I criteria of NUREG-0588. The development of these conditions is described below. The post-accident parameters used in the equipment review are provided in Attachment B, Parts III and IV.

6.2 INSIDE CONTAINMENT 6.2.1 RADIATION Using the guidance of NUREG-0588 and NUREG-0737 (Ref. 1), post-LOCA doses were determined in all areas of the drywell and containment. The fission product release data used in this analysis are based on calculations by General Electric for a 1 MWt BWR-6 equilibrium core with a total burn-up 1 of 1095 MW d . These data were adjusted by the maximum design power level of 4025 MW t to obtain the appropriate fission product inventory for the Grand Gulf core.

In the case of.the NUREG-0588 analysis for the drywell and containment, two scenarios were chosen. The first scenario involved a large line break in the drywell that maximizes the dose to drywell equipment. The second scenario involved an automatic depressurizaton system (ADS) actuation that maximizes the dose to containment equipment.

The drywell scenario began with a line break that caused an instantaneous release of 100 percent of the noble gases and 50 percent of the core inventory iodines to the drywell free volume (270,138 ft3 ). The remaining 1 percent of the particulates were assumed to stay entrained in the reactor coolant. At this same time, plate-out was assumed to begin and continue until the concentration of elemental iodine in the air was reduced by a factor of 100. This occurred 42 minutes into the accident, using a plate-out removal rate of A = 3.31 hr. 1 This value for the plate-out removal was determined using the equation Ap = KgA/V (Ref. 2), with a value of 0.01136 cm 1 for the area-to-volume ratio, and a value of 0.081 cm/sec.

for Kg (Ref. 2, p. 80).

At 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months into the accident, sufficient pressure would build up in the 7 drywell, due to operation of the drywell hydrogen purge compressors, for the first row of vents to clear. At this point, a removal rate of 500 cfm was assumed for all airborne isotopes until the concentration of the longer-lived isotopes in the drywell (e.g., Kr 85) equaled that in the

-containment. This occurred approximately 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months into the accident.

After the 72-hour period, the only removal mechanism was decay.

The containment scenario assumed that an event occurs causing simultaneous core damage and ADS actuation. The entire source of 100 percent noble gases, 50 percent iodines, and I percent of the particulates was released to the suppression pool. This blowdown was conservatively assumed to occur at time zero. For the liquid source, 50 percent iodines and 1 percent 6-1 Revision 1, December 1981

. * *

ML20039B734

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ML20039B734

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Dear Mr. Tedesco:

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Enclosure:

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