ML20080Q633
| ML20080Q633 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 02/21/1984 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Stolz J Office of Nuclear Reactor Regulation |
| References | |
| IEB-79-01B, IEB-79-1B, NUDOCS 8402240138 | |
| Download: ML20080Q633 (49) | |
Text
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1 PHILADELPHIA ELECTRIC COMPANY 23O1 MARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 SHIELDS L DALTROFF ELECTRIC PRODUCTION February 21, 1984 Docket Nos. 50-277 50-278 Mr. John F. Stolz, Chief Operating Reactors Branch #4 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555
SUBJECT:
Peach Bottom Units 2 and 3 Resolution of Safety Evaluation Reports Relating to IE Bulletin 79-OlB, " Environmental Qualification of Class IE Equipment" REFERENCE : (1) Letter to J. F. Stolz from S. L. Daltroff, dated May 20, 1983 (2) Letter to E. G. Bauer, Jr., PECo, from J. F. Stolz, dated December 20, 1982 (transmitting Franklin Research Center's August 3, 1982, Safety Evalustion for the Environmental Qualification of Safety-Related Electrical Equipment)
Dear Mr. Stolz:
This letter provides the NRC with supplementary information to our above reference (1) letter necessary to resolve the issues addressed in the NRC's above reference (2) letter, Safety Evaluation for Environmental Qualification (EQ) of Safety-Related Electrical Equipment.
The attachments to this letter summarize the actions leading to the Resolution of the Safety Evaluation Reports, present the conclusions reached by Philadelphia Electric Company and the NRC during a joint meeting held December 5, 1983, at the NRC's Bethesda, Maryland, office, present a schedule for completion of the environmental qualification testing and modification of the remaining safety-related electrical equipment, and justify why the Peach Bottom Atomic Power Station Units 2 and 3 can continue to operate with the Dwyer Differential Pressure Switches. 'b 8402240138 840221 %
_2 * -
Mr. John F. Stolz February 21, 1984 Page 2 A description of each of the. attachments included as part ci this letter is:as follows:
1
-(l) Attachment-1, " Resolution of Safety Evaluation Reports for Environmental Qunlification of Safety-Related
-Electrical Equipment", is a summary of the. events leading to the Resolution of the Safety Evaluation Reports on Environmental' Qualification of Class IE
- Equipment, including the highlights of the December 5, 1983, meeting.
" Meeting Summary - 12/5/83", is a detailed (2) Attachment 2, synopsis of~the-December 5, 1983, meeting. Included in this attachment is a summary of the resolution of all the electrical equipment environmental qualification ideficiencies identified by Franklin Research Center in their August 3, 1982, Safety Evaluation Report. Also included as part of this attachment'is the ettendance list of the Decedber'5, 1983, meeting.
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-(3). Attachment 3, "EQ Modification Schedule", is Philadelphia Electric Company's schedule for completion of environmental qualification testing and modification of the remaining safety-related electrical equipment.
(4) . Attachment 4, " Justification for Continued-Operation for the Dwyer Differential Pressure Switches", is a description of the failure mode of.the Dwyer Differential Pressure Switch and why Philadelphia Electric Company' concludes Peach Bottom Atomic Power Station _ Units 2 and 3 can continue to operate without undue risk to public health and safety. As.shown in
' Attachment 3, page 1- of the EQ Modification Schedule, Philadelphia Electric Company will be replacing the Dwyer' Differential Pressure Switches by March 31, 1985.
As discussed in Attachment 1,," Resolution of Safety Evaluation Reports for Environmental Qualification of Safety-Related Electrical Equipment",. Philadelphia Electric Company anticipates,.following the NRC review of the Attachments
- contained within this letter, the issuance by the NRC of a
~
supplemental Safety Evaluation Report stating the deficiencies noted:in the above reference.(2) letter (J. F. Stolz, NRC, to E.
lG.1Bauer,.Jr., PECo,! dated December 20, 1982) are considered resolved.
L
"b Mr. Jchn_F. Stolz February 21, 1984 Page 3 Should'you have any questior.s or require additional information, please do not hesitate to contact us.
Very truly yours, l'
,' /S DNB:lm Attachments-
~ cc: A. R. Blough, Site Inspector I
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< PHILADELPHIA ELECTRIC COMPANY PHILADELPHI A
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PEAQ1 BOTIOi A10fLC F0WER STATION -
UNITS 2 AND 3 D00TI NLMBERS 50-277 AND 50-278 s
ATTAONENTS 1, 2, 3 AND 4 SUPPIRiENIARY -INFORMATION REIATED 10 mVIR0tNENIAL QUAUFICAHON OF.SAFEIY-REIATED EECDUCAL EQUIRHf PURSUANT TO IE BUUETIN 79-01B t
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11E UNITED' STATES NUCIEAR REGUIATORY 0@tilSSION AS PART OF A REQUEST 1011E tRC 10 ISSUE A SUPPIDNEARY -
SAFErY EVAWATION REPORT FOR PEAQ1 BOTIUi AIGIIC E0WER STATION UNITS 2 AND 3 FEBRUARY 1984
f PEAQI B0fI101 A10MIC POWER STATION UNITS 2 AND 3 D00Tr NUMBERS 50-277 AND 50-278 ATTAQ NENTS 1, 2, 3 AND 4 SUPPIRIINEARY INEURMATION RELATED TO ENVIR0tNENTAL QUALIFICATION OF SAFETY-REIATED EECIRICAL EQUIPMENT PURSUANT TO IE BULLETIN 79-O's SUEMIITED 10
'11IE UNITED STATES NUCLEAR REGULA10RY 00bMISSION AS PART OF A REQUEST 10 IllE NRC 10 ISSUE A SUPPIRIENTARY SAFEIY EVAIUATION REPORT FOR PEAGI B0rrIQ1 AIQf1C 10WER STATION UNITS 2 MlD 3 FEBRUARY 1984
ATTACHMENT 1 PHILADELPHIA ELECTRIC COMPANY PEACH BOTTOM ATOMIC POWER STATION UNITS 2 AND 3 DOCKET NOS. 50-277 AND 50-278 RESOLUTION OF SAFETY EVALUATION REPORTS FOR ENVIRONMENTAL QUALIFICATICN OF SAFETY-RELATED ELECTRICAL EQUIPMDIT
l Attachment 1 Resolution of Safety Evaluation Reports for Environmental Qualification of Safety-Related Electrical Equipment On December 22, 1982, Philadelphia Electric Company (PECO) received from the Nuclear Regulatory Commission (NRC) the Safety Evaluation Report (SER) dated 8/3/82 regarding the Environmental Qualification of Safety-Related Electrical Equipment at Peach Bottom Atomic Power Station (PBAPS) for Units 2 and 3. The SER cont ined a Technical Evaluation Report (TER), written by Franklin Research Center under contract to the NRC, which identified a number of environmental qualification documentation deficiencies for safety-telated electrical equipment at PBAPS.
PECO submittals dated 9/3/81 and 3/1/82 identify electrical equipment important to safety which is qualified and include a schedule to complete mcdifications for the remaining electrical equipment for which a modification is required to establish qualification. In addition, a Justification for Continued Operation (JCO) was provided for those items of electrical equipment with incomplete environmental qualification documentation. A later PECO submittal dated 5/20/83 revised the modificaticn schedule. On December 5, 1983, a meeting was held with the Nuclear Regulatory Commission's Office of Nuclear Reactor Regulation Staff, region I&E members and the PBAPS Project Manager (attendance list attached) to discuss Philadelphia Electric Company's proposed method of resolution for each of the deficiencies. The proposed resolution, as discussed with the Nuclear Regulatory Commission Staff for each of the environmental qualification documentation deficiencies listed in TER Table 4-2, is summarized in Attachment 2 to this report. Discussions also took place at the meeting regarding PECO's general methodology for compliance with 10CFR50.49, " Environmental Qualification of Electrical Equipment Important to Safety for Nuclear Power Plants," which became effective February 22, 1983. The purpose of this report is to provide doct. mentation of the discussions held at the December 5,1983 meeting.
At the December 5, 1983 meeting the NRC Staff requested confirmation that all design-basis events at PBAPS which could result in a potentially harsh environment, including flooding outside primary centainment, were addressed in identifying safety-related electrical equipnent. Flooding and environmental effects resulting from all postulated design-basis accidents documented in Chapter 14 of the PBAPS Final Safety Analysis Report (FSAR), including Loss-of-Coclant and Steam Line Break Accident (SLBA) inside primary containment, were considered. The flooding and environmental effects resulting from High Energy Line Breaks (HELBs) in secondary containment, as documented in Appendix A of the FSAR were also considered in the identification and qualification of this equipment. Therefore, all design basis events at PBAPS were considered within the scope of Paragraph (b) (1) of 10CFR50.49 (i.e., " Safety-Related electrical equipment . . relied upon to remain functional during and following design basis events...")
y Attachment 1 Paragraph (b) (2) of 10CFR50.49 requires that licensees irientify "Nonsafety-related electric equipment whose failure under postulated environmental conditions could prevent satisfactory accomplislanent of safety functions ..." The methodology used to identify electric equipment in PECO's responses to I.E. Bulletin 79-OlB dated 9/3/81 and 3/1/82 was detailed in PECO submittal of 5/20/83 on Clarification of Qualification Safety Evaluation Report and is reiterated here. PECO submittals of 9/1/81 and 3/1/82 comply with Paragraph (b) (2) of 10CFR50.49. The list of equipment included in these submittals is based on a review of the PBAPS Q-list, Electrical Schematic Drawings, Piping and Jestrument Diagrams (P&ID's) and the FSAR. The FSAR is the basis for < mining the systems required to mitigate the effects of the postulau d LOCA and HELB accidents. The Q-list, Electrical Schematic Drawings and Piping and Instrument Diagrams (P&ID) were reviewed concurrently to determine the role of individual electrical components in supporting the operation of systems identified from the FSAR. If it was determined that 1) the failure of the component could prevent the system from performing its safety function and 2) the component was, located in a potentially harsh environment, the component was included in the I.E. Bulletin 79-01B equipment list.
The method used to identify electrical equipment within the scope of Paragraph (b) (3) of 10CFR50.49, i.e., "Certain post-accident monitoring equipment", invc,1ved a review of the Type A variables in NRC Regulatory Guide 1.97 (Rev. 2) ," Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident." The instrur.entation required for emergency procedures which is considered safety related is based on this review.
The PECO submittal of 3/1/82, J. W. Gallagher to J. F. Stolz, transmitted:
- 1) Instrumentation List for PBAPS Units 2 and 3.
- 2) System Component Evaluation Work Sheets (SCEWS).
- 3) Deficiency Resolution Plan for Instrumentation with EQ Deficiencies.
- 4) JCO's for instruments with EQ deficiencies.
Since the 3/1/82 submittal, pressure Transmitters PT-4952, PT-4953, PT-5952 and PT-5953 and Temperature Elements TE-2501-36A,B and TE-3501-36A,B have been deleted from the emergency procedure equipment list. See Attachment 3, modification update schedule for a justification for deleting thcse PT's and TE's.
Philadelphia Electric Comany concludes that all electrical equipment important to safety transmitted in tha submittals of 9/1/81 and 3/1/82 complies with the scope of Paragraph (b) to 10CFR50.49, that the supplemental environmental qualification documentation in the PBAPS central rile, which is referenced in Attachment 2 to this letter, complies with the requirements of 10CFR50.49 and is available for audit, and that PDAPS can continue to operate without undue risk to the
Attachment 1 public health and safety based on the JCOs provided in submittals dated 9/3/31 and 3/1/82 and the modification update schedule (Attachment 3) to this report. Note that a revised JCO for the Dwyer Differential Pressure Switches (DPS) is submitted as Attachment 4.
As discussed at the December 5, 1983 meeting, it is requested that a supplemental SER be issued to indicate that Philadelphia Electric Company's Electrical Equipment Environmental Qualification Program, as described in this report, meets the requirements of 10CFR50.49 and that the deficiencies noted in the SER dated August 3, 1982.
a WJC:LCY 1/3/84 LY121283M315
Philadelphia Electric Company Peach Bottom Atomic Power Station Units 2 and 3 Docket Nos. 50-277 and 50-278 Attachment 2 Meeting Summary - 12/5/83 Synopsis of the Philadelphia Electric Company and Nuclear Regulatory Commission meeting held in Bethesda, Maryland on December 5, 1983.
G 1/3/84
Philadelphia Electric Company Peach Bottom Atomic Power Station Units 2 and 3 Docket Nos. 50-277 and 50-278 Attachment 2 Table of Contents Section Description Page Table of Contents i Attendance List 11 Definition of Deficiencies 1 from Table 4-2 of SER Review of Table 4-1 2 Categorization of Equipment at PBAPS Units 2 and 3 Aging Discussion 3 PECO Evaluation for items where 4 similarity was the only deficiency
- 1) Pyle National - Plug Connectors 5
- 2) Limitorque - MOV Actuators 6
- 1) Agastat - Relays 9
- 2) ASCO - SV's 10
- 3) AVCO - SV's 11
- 4) Brown /Boveri - Load Centers 12
- 1) Agastat - Relays 15
- 2) Barton - DPIS 16
- 3) Burns - RTD's 17
- 4) GE - Relays 18
- 5) GE - Terminal Blocks 19
- 7) Marathon - Terminal Llocks 21
- 8) NAMCO - Limit Switch 22
- 9) Reliance - Motor - CAD 23
- 10) Reliance - Motor - Area Coolers 24
- 11) Rockbestos - Cable 25
- 12) Rosemount - Trip Units 26
- 13) Rosemount , Transmitters 27
- 14) Scotch - Tape 28 i 1/3/84
Attendance List NRC/PECO Meeting 12/5/83 D. J. Thomspon PECO W. J. Boyer PECO R. G. LaGrange NRC/NRR/DE/EQB P. Shemanski NRC/NRR/DE/EQB G. Gears NRC/NRR/OL/ ORB-4 R. J. Lees PECO W. J. Clune PECO R. K. Ho EPM F. M. Valentino PECO L. S. Cheung NRC Region 1 A. E. Finkel NRC Region 1 J. A. Calvo NRC/NRR/ORAB H. Walker NRC/NRR/DE 11
Philadelphia Electric Company Peach Bottom Atomic Power Station Units 2 and 3 Docket Nos. 50-277 and 50-278 Deficiencies as Defined in Table 4-2 FRC Technical Evaluation Report
- 1. Documented Evidence of Qualification Adequate
- 2. Adequate Similarity Between Equipment and Test Specimen Established
- 3. Aging Degradation Evaluated Adequately
- 4. Qualified Life or Replacement Schedule Established (if required)
- 5. Program Established to Identify Aging Degradation
- 6. Criteria Regarding Aging Simulation Satisfied (if required)
- 7. Criteria Regarding Temperature / Pressure Exposure:
A Peak Temperature Adequate B Peak Pressure Adequate C Duration Adequate D Required Profile Enveloped Adequately E Steam Exposure (if required) Adequate
- 8. Criteria Regarding Spray Satisfied
- 9. Criteria Regarding Submergence Satisfied
- 10. Criteria Regarding Radiation Satisfied
- 11. Criteria Regarding Test Sequence Satisfied
- 12. Criteria Regarding Test Failures or Severe Anomalies (if any)
Satisfied
- 13. Criteria Regarding Functional Testing Satisfied
- 14. Criteria Regarding Instrument Accuracy Satisfied
- 15. Test Duration Margin (1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> + Function Time) Satisfied
- 16. Criteria Regarding Margins Satisfied (NUREG-0588, Cat. I) 1/3/84
Philadelphia Electric Company Peach Bottom Atomic Power Station Units 2 and 3 Docket Nos. 50-277 and 278 Review of Categorization From Table 4-1 for PBAPS SER PECO has reviewed the categorization of all items listed in Table
)
4-1 of the TER/SER for Units 2 and 3 and they are summarized below:
Unit 2 Cat IA - PECO concurs Cat IB - PECO concurs except as follows:
Item 88 - see PECO evaluation p. 23 Item 130 - HPCI level switch, should be in category IIIA, see P. 5-3 of TER Cat IIA - PECO concurs except as follows:
Item 65 - HPCI flow switch should be in category IIIA, see p. 5-3 of TER Item 91 - RHR Control Stations have been tested and will be modified, should be in category IB Cat IIB - PECO concurs Cat IIC - PECO concurs, aging addressed generically Cat IIIA - PECO concurs Cat IIIB - PECO concurs Cat IV - PECO concurs Unit 3 Cat IA - PECO concurs Cat IB - PECO concurs except as follows:
Item 88 - see PECO evaluation p. 23 Cat IIA - PECO concurs except as follows:
Item 65 - HPCI - Flow Switch should be in category IIIA, see p. 5-3 of TER Item 91 - RHR Control Stations have been tested and will be modified, should be in category IB Cat IIB - PECO concurs Cat IIC - PECO concurs, aging addressed generically Cat IIIA - PECO concure Cat IIIB - PECO concurs Cat IV - PECO concurs
Philadelphia Electric Company Peach Bottom Atomic Power Station Units 2 and 3 Docket Nos. 50-277 and 50-278 Aging Discussion FRC Equipment Item No.: Generic Description of Item: Generic Summary of TER: Aging degradation not evaluated adequately Qualified life or replacement schedule not established Evaluation: The environmental qualification requirements for PBAPS are contained in the DOR Guidelines and NUREG 0588 Cat II. It is not required that a specific qualified life be established for equipment qualified to NUREG 0588 Cat. II, but that equipment be analyzed and materials having known in service susceptibility to significant degradation due to thermal and radiation aging, be subject to a schedule for inspection of and/or replacement of the susceptible components in that equipment incorporated into the preventive maintenance and surveillance programs, ref. NRC Letter 82-09.
Maintenance procedures for Class lE equipment installed at PBAPS are currently under review. Philadelphia Electric Company's experience with this review has revealed that Class 1E equipment is currently being addressed on a routine basis. For example, ASCO Solenoid Valves are replaced / rebuilt at a maximum of every fourth refueling outage, MSIV's are reconditioned every refueling outage, instrumentation is subject to surveillance tests, calibration procedures and compcnent replacement and valve actuators are inspected and serviced every refueling outage. The completion of our review and the incorporation of qualification related component maintenance activities with equipment / component changeout intervals defined will ensure that all Class lE equipment located in the reactor building will retain its qualified status and function as required under nortnal operation conditions and after postulated Design Basis Accidents.
==
Conclusion:==
Based on the above information, it is concluded that in-service degradation of safety related equipment is adequately being addressed by plant preventative maintenance / surveillance activities.
Philadelphia Electric Ccmpany Peach Bottom Atomic Power Station Units 2 and 3 Docket Nos. 50-277 and 50-278 Equipment With Only One Deficiency Similarity In three cases within the TER, FRC reported that the only deficiency was " similarity had not been established between the tested equipment and the purchased equipment installed at PBAPS." These are:
(1) Pyle-National Plug-Connectors (Item No. 103), Limitorque MOV Actuators (Item 1,2,3,4,5,9,10,11,13,14 Units 2 and 3) , ASCO-SV (Item 48 Unit 2 and 3) . These items are identified and discussed on the following pages 5-7 To provide similarity, it has been PECO's policy to take a three way approach with equipment vendors:
- 1. A Certificate of Conformance from the vendor attesting to the similarity of the equipment purchased with the equipment tested.
- 2. Clarification and traceability in writing of equipment and/or component part numbers where variations from vendor Catalog. numbers exist.
- 3. Material certification on the subcomponent level where necessary.
As an example of this process, PECO cites FRC Item Number 103, Pyle-National Plug-Connectors. PECO purchased several of these devices to serve as quick disconnects for Motor Operated Valve electrical connections during maintenance or replacement operations.
The items purchased differed from the tested units in external shell material, and an optional seal. PECO documentation records include three (3) Certificates of Conformance which were issued to coincide with the three separate sales orders issued between PECO and Pyle-National.
It should be noted that the questions regarding similarity raised by FRC were previously asked by the NRC in a letter from H. D.
Thornburg (Division of Reactor Construction Inspection, Office of I/E) to J. L. Hankins (VP-EP, PECO) received 7/10/78, as part of the NRC confirmatory environmental qualification testing program. PECO's response in a letter from J. W. Gallagher (Mgr. EP, PECO) to W. R.
Rutherford (NRC Division of Reactor Construction Inspection, Office of I/E), dated 8/30/78, was accepted.
1/3/84
t PECO Evaluation FRC Item Number: 103 Unit 2 Description of Item: Plug-Connector Pyle National Summary of TER Item Unit Deficiencies 103 2 2 Adequate similarity between equipment and test specimen not established.
Evaluation: Pyle-National Company letter to F. M. Valentino, PECO, dated 8/1/78 establishes similarity between tested connectors and PECO connectors. Exhibits 3, 4 and 5 of the above referenced letter are Certificates of Conformance and reference the applicable test report for the connector installed at PBAPS. Three separate Certificates of Conformance were issued to coincide with the three separate sales orders issued between PECO and Pyle-National. Documentation also includes a letter from Pyle-National with clarification of the PECO unique part numbers issued, i.e. the addition of the optional seal on the PECO order dictated use of a unique series of part numbers differing from the standard catalogue numbers; and a letter certifying that: the plug-connectors purchased by PECO are the same generic product line produced by Pyle National; the aluminum shell material is standard for BWRs while the stainless steel material (which was used on the test models) is standard for PWRs and that the two shell materials do not affa t performance in the environments specified; and the internal insert configurations and materials are identical in both lines of plug-connectors.
Conclusion:
Based on the above information, it is concluded that the Pyle-Nat ional plug-connectors are environmentally qualified for the postulated accident conditions at PBAPS.
1/3/84
PECO Evaluation FRC Item Number: 1, 2, 3, 4, 5, 9, 10, 11, 13, 14 Unit 2 1, 2, 3, 4, 5, 9, 10, 11, 13, 14 Unit 3 Description of Item: Limitorque Motorized Valve Actuator Summary of TER Item Unit Deficiencies 1,2,3,4,5,9, 2&3 2 10,11,13,14 2& 3 2 Adequate similarity between equipment and test specimen not established.
Evaluation: A record of correspondence between PECO and Limitorque is in PECO's central file which indicates that the cited test report on the SCEWS is applicable to this equipment.
==
Conclusion:==
Based on the above information, it is concluded that the Limitorque motorized valve actuators listed above are environmentally qualified for the postulated accident conditions at PBAPS.
1/3/84
PECO Evaluation FRC Item Number: 48 Unit 2 48 Unit 3 Description of Items: ASCO - Solenoid Valve Model - GV-206-380-3-U Summary of TER Item Unit Deficiencies 48 2& 3 2 Adequate similarity between equipment and test specimen not established.
Evaluation: These solenoids are used as pilot valves on the Control Rod Drive (CRD) Hydraulic Control Units (HCU). When the reactor is not in a scram condition, both three way solenoids associated with each HCU are energized and instrument air is supplied to the diaphragns of both scram valves. Both solenoids are required to be de-energized to scram their associated control rod. In response to a scram signal from the RPS system, the solenoids are de-energized and are required to shift position once at the on-set of the accident.
In response to a request by PECO, ASCO performed an analysis of the PBAPS specific equipment based on tcsts performed to qur.lify the NP series solenoid valves. The DECO request identified the function, expected environmental conditions, and model/ serial number. The information provided to ASCO was based on a field inspection. The ,
results of the ASCO analysis are located in PECO's central file.
Surveillance tests of the HCU which are periodically conducted, exercise the solenoid valves, and in addition, these solenoid valves
- are re-built every fourth re-fuel outage.
Conclusion:
Based on the above information, it is concluded that the ASCO SV's are environmentally qualified
- for the postulated accident conditions at PBAPS.
1/3/84
l Philadelphia Electric Company Peach Bottom Atomic Power Station Units 2 and 3 Docket Nos. 50-277 and 50-278 Equipment with Only One Deficiency Documentation All documentation reque.sted by the NRC to be submitted to FRC was submitted to FRC with the exception of one document which was not a PECO reference in our response to I.E. Lulletin 79-01B, (LLL) Motor Manufacturer and Insulation Class for Limitorque Operators.
Documentation submitted to FRC was in several instances analysis which referenced a qualification report but the qualification report did not appear as a reference in PECO's submittal to I.E. Bulletin 79-01B and was not requested by or submitted to FRC. Therefore, FRC d!.d not have the opportunity to review the report, and establish qualification. Five types of equipment out of a total of 22 fall into this category.
Page 11 Agastat - Relays 9
- 2) ASCO - SV's 10
- 3) AVCO - SV's 11
- 4) Brown Boveri - Load Centers 12
The Brown Boveri Load Centers which were placed in Category IIA were reported in our response to I.E. Bulletin 79-OlB as an outstanding item awaiting a qualification report from Brown Boveri. The report is now in the PECO central file and available for review.
Based on the above information, it is concluded that the Agastat-Relays, ASCO-SV's, AVCO-SV's, Brown Boveri Load Centers and Target Rock-SV's are environmentally qualified for the postulated accident conditions at PBAPS.
1/3/84
PECO Evaluation FRC Item Number: 95 Unit 3 Description of Item: Agastat Time Delay Relay - 2414D - ECCS pump room unit coolers switching.
Summary of TER Item Unit Deficiencies 95 3 1 Evaluation: Agastat document No. E7012/E7022 is a Qualification Test Report. Letters from Agastat to PECO dated 9/18/80 and 9/22/80 establish the applicability of Agastat document No. E7012/E7022 to Agastat time delay relays 2414AD.
Conclusion:
Based on the above information, it is concluded that the Agastat relay 2414D is environmentally qualified for the postulated accident conditions at PBAPS.
t o
1/3/84
PECO Evaluation FRC Item Number: 47, 49, 50, 51, 52, 53, 54, 55, 56, 57, 58, 59, 60, 61, 62, 63, 119, 120, 122 Unit 2 47, 49, 50, 51, 52, 53, 54, 55, 56, 57', 58, 59, 60, 61, 62, 63 Unit 3 Description of Item: ASCO - Solenoid Valves Summary of TER Item Unit Deficiencies 47 2& 3 1 49 2& 3 1 50 2& 3 1 51 2& 3 1 52 2& 3 1 53 2& 3 1 54 2&3 1 SE 2& 3 1 56 2&3 1 57 2& 3 1 58 2&3 1 59 2&3 1 60 2&3 1 61 2& 3 1 62 2&3 1 63 2& 3 1 119 2 1 120 2 1 122 2 1 Evaluation: These solenoids are used as pilot solenoids on air operated valve actuators. The solenoids are normally energized open to hold the actuator / valve closed. On a system start signal, the solenoids are de-energized and chift position closed to open the actuator / valve. The actuator / valve service is to isolate water flow to local area fan cooler units which maintain the ambient temperature in the Emergency Core Cooling System (ECCS) pump rooms. In response to a system start signal, the solenoids are de-energized and are required to shift position once at the on-set of the accident. The area coolers will then act to maintain the ambient temperature within nomal temperature limits.
In response to a request by PECO, ASCO perfomed an analysis of the PBAPS specific equipment based on tests perfomed to qualify the NP series of ASCO solenoid valves. The PECO request identified the function, expected environmental conditions, and model/ serial number specific to the equipment installed in the plant. The infomation provided to ASCO was based on a plan't inspection. The results of the ASCO analysis are located in PECO's central file.
1/3/84
_PECO Evaluation In addition, surveillance tests of the ECCS systems which are periodically conducted, exercise the solenoid valves. The PECO replacement policy for this equipment is to use the NP-1 series of ASCO solenoid valves which conforma to the requirements of 10CFR50.49 and to re-build the solenoid valves every 4th re-fuel outage.
Conclusion:
Based on the above informatior, it is concluded that the ASCO SV's are environmentally qualified for the postulated accident conditions at PBAPS.
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_va- 1/3/84 i _ _ _ _ _ _ _ _ - - _
l t
- PECO Evaluation FRC Item Number 43, 44, 45 Unit 2 43, 44, 45 Unit 3
- 4scription of item: Pilot solenoid valves for steam relief valves and MSIV's Automatic Valve Corporation (AVCO)
Summary of TER Itec Unit Deficiencies 43 2&3 1 44 2& 3 1 45 2& 3 1 Documented evidence of qualificaiton inadequate.
Evaluation: GE Letter G-HE-8-198 transmitted Environmental Qualification Test Results and Procedures for Automatic Valve Corporation SV's model numbers C-5450, and 4988-33 and 34. A Technical Evaluation Report on PBAPS Unit 2 dated 11/80 conducted by A. E. Finkel of the NRC indicates that the enly deficiency is aging. The Steam Relief Valves are removed from service every refueling outage sent to Wyle Labcratories, tested, reconditioned, tested and returned to PECO for teinstallation. The MSIV's are reconditioned every refueling outage by PECO.
Conclusion:
Based on the above information, it is concluded that the AVC SV's are environmentally qualified for the postulated accident conditions at PBAPS.
1/3/84
PECO Evaluation FRC Item Number: 98 Unit 2 98 Unit 3 Description of Item: Gould/ Brown Boveri Load Centers Summary of TER Item Unit Deficiencies 98 2&3 1 Documented evid(nce of qualification inadequate.
Evaluation: The PECO 9/1/80 submittal to I&E Bulletin 79-OlB cocunitted PECO to purchase the qualification report from Brown Boveri and did not submit any qualification documentation to FRC. Brown Boveri Electric, Inc. has provided an environmental qualification report (33-55045-QS) Rev. 2, 7/8/82 which establishes the environmental qualification of Load Centers for PBAPS. The subject environmental qualification report not reviewed by FRC is in PECO central file and available for audit.
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Conclusion:==
Based on the above information, it is concluded that Brown Bovari Load Centers are environmentally qualified for the postulated accident conditions at PBAPS, 1/3/84
PECO Evaluation FRC Item Number 39, 40 Unit 2 39, 40, 41, 42 Unit 3 Description of Item: Target Rock - Solenoid Valve 73AA-001, 73AA-002 Sunmary of TER Item Unit Deficiencies 39 2& 3 1 40 2&3 1 41 3 1 42 3 1 FRC requires a review of Target Rock Report 2787A to establish qualification.
Evaluation: Target Rock report No. 2787A, " Aging, Seismic and Accident Simulation for SV's 73AA-001 and 73AA-002." is available for audit in PECO's central file. PECO did not submit this report to FRC.
Our qualification analysis, which is based on Target Rock report No.
2737A, was submitted to FRC.
Conclusion:
Based on the above information it is concluded that the Target Rock SV's are environmentally qualified for the postulated accident conditions at PBAPS.
l 1/3/84
Philadelphia Electric Company Peach Bottom Atomic Power Station Units 2 and 3 Docket Nos. 50-277 and 50-278 Equipment With Multiple Deficiencies 1/3/84
PECO Evaluation FRC Item Number: 93, 94, 95 Unit 2 93, 94 Unit 3 Description of Items: Agastat GP series relays Summary of TER Item Unit Deficiencies 93 2&3 2 3 7B 94 2& 3 2 3 -
95 2 2 3 -
Evaluation: The letter from Amerace Corporation to PECO dated 3/13/81 establishes similarity between GPBC757 and FGFBC757 relays and the testad EGP series relays. PECO supplemental analysis Ref. 118 establishes the environmental qualification of the relays for their use at PBAPS.
Aging degradation is included within the generic discussion of aging.
The application of these relays requires their operation for LOCA only. The pressure during a LOCA is atmospheric therefore deficiency 7B is not applicable.
Conclusion:
Based on the above infomatien, it is concluded that the Agastat GP relays are environmentally qualified for the postulated accident conditions at PBAPS.
1/3/84 L _ _ _ _ _ - . _ _ _ _ . _
PECO Evaluation FRC Item Number: 81, 82, 125, 126 Unit 2 81, 82 Unit 3 Description of Item: Barton differential pressure switch model 288A, 289B Summary of TER Item Unit Deficiencies 81 2&3 3 4 7B 7E 13 82 2 3 4 7B 7E 13 82 3 1 125 2 3 4 13 126 2 1 2 Evaluation: Item number 81 Units 2 and 3 and item number 125 Unit 2 will be replaced with new qualified Barton Differential Pressure Indicating Switches (DPIS). A request by the NRC for additional information concerning justifications for continued operation for equipment at PBAPS resulted in a letter to the NRC on 2/11/82, S. L.
Daltroff to J. F. Stolz. This letter contained an evaluation of the operating requirements for item 81 and 125 and concluded that the switches are qualified for their intended safety function. These switches are being replaced to enhance our environmental qualification documentation.
Item 82 Units 2 and 3 and item 126 are required for HPCI, RCIC and RWCU line break detection. GE has tested Barton 288 and 289 DPIS to 212'F, 100% RH, 7" Water Column, with a 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> post accident operability time.
Radiation levels resulting from the above listed line breaks are negligible and the required operating time of 15 minutes is encompassed by the test time. The pressure deficiency listed in the TER has been addressed in a PECO analysis. Steam exposure and functional testing are addressed in GE - Design Verification test DV 145C3008.
Conclusion:
Based on the above infomation, it is concluded that the Barton DPIS's are environmentally qualified for their intended safety function.
1/3/84 t
PECO Evaluation FPC Item Number: 83 Unit 2 83 Unit 3 Description of Item: Burns Engineering, Inc. Resistance Temperature Detectors (RTD's).
Summary of TER Item Unit Deficiencies 83 2&3 7B 7E Evaluation: FRC accepted the qualification of the Burns RTD as submitted; however, they asked questions with respect to the connection head /
conduit interface. In susuary, these questions are: Does in-leakage occur through seals? and, if yes - What is the effect of this in-leakage on the connecting wire within the connection head?
The analysis submitted by PECO, and accepted by FRC, did not take credit for a connection head / conduit seal. The connection head was assumed to be open to the surrounding atmosphere.
Conclusion:
Based on the above information it is concluded that the Burns RTD's, including the connection head / conduit interface is qualified for the postulated accident conditions at Peach Bottom.
l 1/3/84 t - - - - - - - - - - _ - - - - - - - _
PECO Evaluation FRC Item No.: 123 Unit 2 99 Unit 3 Description of item: GECO CR 120A auxiliary relays Summary of TER Item Unit Deficiencies 123 2 1 3 4 7A 7B 7C 7D 7E 99 3 1 3 4 7A 7B 7C 7D 7E l FRC states NEDO 10698 is not a valid qualification report. The report provides no supporting data or references which would permit independent verification that a test had been performed and that the results including the operability of the item are correct. The SCEW sheet; parameters: 151*F, 15.7 psia, 100% RH, 3.07x10" rads are not approached by the data presented. In addition, aging and qualified life have not been addressed. Adequate evidence of qualification not established.
Evaluation: These relays are used in control circuits associated with the Emergency Core Cooling System area coolers. NEDO 10698 is a surumary of the GECO qualification program and it includes the levels to which .GECO has qualified the relaya, 140*F, 14.7 psia, and 95%
relative humidity. The specified values for the PBAPS application of these relays is 151*F, 15.7 psia, and 100% relative humidity. A radiation analysis has been performed by PECO which establishes that the materials are acceptable. The ambient conditions identified above are dne to a HELB. The relay panels are Jocated remotely from the equipment they control, and the specified conditions result from conservative assumptions. These assumptions include modeling the isolation valves, which are redundant, as a step function i.e. 100%
i open until closed, and the HVAC duct and other steam communications l paths are 100% open due to duct collapse. The area in which this equipment is located would be accessible within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> post-HELB.
PECO has addressed the difference of 11*F, 1 psia and 5% relative htmidity in a supplemental analysis which is included in the central file.
Conclusion:
Based on the above information it is concluded that the CR 120A relays are environmentally qualified for the postulated accident conditions at PBAPS.
l 1/3/84
l l
PECO Evaluation FRC Item No.: 99 Unit 2 Description of Item: GECO CR 151 Terminal block Summary of TER Item Unit Deficiencies 99 2 1 2 Documented Evidence of qualification inadequate.
Adequate similarity between equipment and test specimen not established.
Evaluation: The Qualification Summary Reports (QSR's) were a generic evaluation performed under contract to the Utility Equipment Qualfication-BWR Owners Group and were submitted to FRC as proof of qualification. The QSR cover sheets were developed to determine if 3 or more utilities had the equipment installed in their plant. If 3 or more utilities did have the equipment then the Consultant would pursue EQ documentation fron the equipment manufacturer. The cover sheet is a quick reference and does not preclude or limit any member utility from referencing the infomation. In addition, PECO has a letter from GECO which establishes applicability of tested CR-151 terminal bicek to the PBAPS CR-151 terminal blocks, J. Z. Sherk to W. H. VanBuskirk 2/2/78.
Conclusion:
Based en the above information it is concluded that the terminal blocks are environmentally qualified for the postulated accident conditions at PBAPS.
1/3/84 l
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PECO Evaluation FRC Item Number: 87 Unit 2 Description of Item: GE - ECCS pump motor Summary of TER Item Unit Deficiencies S7 2 2 10 Adequate similarity between equipment and test specimen inadequate.
Evaluation: The PECO 9/1/81 submittal to I&E Bulletin 79-OlB committed PECO to issuing a purchase order to resolve the documentation deficiencies. PECO has issued the purchase order and GE has provided an environmental qualification report NSE76-1281 dated 4/82 and letter G-HE-3-009 dated 1/27/83 which establishes the qualification of ECOS Pump Motors. This report establishes the applicability of tested l equipment to the equipment installed at PBAPS and addresses the radiation capability of the materials of construction in the PBAPS ECCS Pump Motors. The EQ Report is in PECO central file and available for audit.
Conclusion:
Based on the above information, it is concluded that the GE ECCS pump motors are environmentally qualified for the postulated accident conditons at PBAPS.
1 1/3/84
l PECO Evaluation 1
l FRC Item Number: 100 Unit 2 and 3 Description of Item: Marathon Terminal Block 1600 Series Summary of TER Item Unit Deficiencies 100 2&3 3 4 7E 8 Criteria regarding steam exposure inadequate and effect of failure on other Class lE equipment not addressed.
Evaluation: Marathon terminal blocks were tested as part of an overall qualification test program which was initiated to both qualify existing wiring interface methods and to evaluate potential wiring methods. This testing was conducted at Franklin Research Center in late 1978. Marathon terminal blocks were tested in two horizontal mounting configurations. They were installed in aluminum junction boxes which had % inch drain holes and conduit stubs for cable entry.
The horizontal mounting was chosen as the worst case condition for the test. One of two test specimens failed at 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> into the 340'F steam and demineralized water spray part of the test. The cause of failure was determined to be the result of an electrical tracking path which formed along molding ridges on the barriers of the terminal block. The Marathon blocks have a very small residual ridge which appears to result from the molding process, on every other barrier.
} The ridges provide a mechanism for condensation to collect on and run i along. It is hypothesized that during the steam exposure, the cable insulation releases chloride cases which combine with free elements to form a gaseous salt. Due to the small volume of the test chamber, the concentration of the:se gases become significant such that when condensation is formed, the salt is deposited. When a continuous run-off path is established such as the ridges on the Marathon blocks, a high concentration of moist salt is deposited continuously along the path.
To evaluate the impact of this test failure, safety-related equipment in primary containment was inspected and no Marathon terminal blocks were found. With respect to secondary containment, these terminal blocke are satisfactory based on the following factors. Only one of two blocks mounted in a worst case orientation failed. Teminal blocks are normally mounted in a vertical orientation. The failed block and l other equipment (with cable) were subjected to live steam and l demineralized water spray continuously for 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. On an outside containment HELB, the blowdown is terminated in less than 30 seconds.
All high energy lines which penetrate primary containment contain redundant isolation valves. The potential to release gaseous chlorides is greatly diminished and the free volume of secondary containment will result in an insignificant concentration of chlorides in the air.
Without the possibility of establishing the demonstrated failure mechanism, the blocks can be expected to survive based on the successful completicn of the test for the terminal block which did not exhibit the failure mechanism.
1/3/84
l PECO Evaluation l
conclusion: Based on the above information, it is concluded that the Marathon terminal blocks are environmentally qualified for use other than primary containment.
l
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PECO Evaluation FRC Item Number: 84, 85 Unit 2 84, 85 Unit 3 Description of Item: Namco - Limit Switch Summary of TER Item Unit Deficiencies 84 2&3 2 3 4 85 2& 3 2 3 4 Adequate similarity between equipment and test specimen not established dus to lack of information on sealing method betwean conduit and se,?l.
Evaluation: The seal between the limit switch and the associated conduit is made by means of an explosion proof Crouse-Hinds conduit seal (cat. #EY331). GE silicon compound RTV-lll which is rated for temi- =ture operation of -175'F to 400*F and radiation exposure up to 100 Mrads, is used as a potting compound to seal the limit switch.
PECO drawing E-1315, " Seal Detail of Limit Switches in Containment,"
describes the installation of the NAMCO limit switch seal. Aging degradation is included within the generic discussion on aging.
Conclusion:
Based on the above information, it is concluded thet the Namco Limit Switches are environmentally qualified for the postulated accident conditons at'PBAPS.
1/3/84
PECO Evaluation FRC Equipment Item No.: 88 Unit 2 l
88 Unit 3 Description of Item: Reliance motor, Model CS. Provides motive force for Hydrogen Analyzer sample pump.
Summary of TER Item Unit Deficiencies 88 2& 3 1 Evaluation: The FRC states that PECO has committed to modifications to resolve the deficiency. PECO has not reported motor deficiencies nor committed to any motor modifications.
The H2 /02 analyzer sample pump and a_ cor were reported as associated components on the analyzer SCEW. However, they are not required for the analyzer to perform its intended post-LOCA safety function.
Therefore, they do not require environmental qualification. A revised SCEW which does not identify the sample pump as an associated component will be prepared.
Conclusion:
Based on the above information, it is concluded that the CADS sample pumps are not required for the hydrogen / oxygen analyzers to perform their intended safety function. The sample pumps are used to perform required tests during normal plant operation.
l l
1/3/84
Technical Discussion FRC Item No.: 86, 90 Unit 2 86, 90 Unit 3 Description of Item: Reliance ECCS cooler fan motors.
l l Summary of TER l Item Unit Deficiencies 86 2& 3 4 5 10 90 2& 3 4 5 10 A supplemental report to NUC-9 is appended by letter from Reliance Electric. This letter restricts the applicability of the supplemental report to the motor insulation system. The PECO analysis (Ref. 112) correlates the insulation system organic materials list to radiation damage thresholds. Additional evidence of qualification should be provided for the motor lead splice and bearing lubricant and should address the thermal aging and radiation exposure of the motor as a whole.
Evaluation: As noted in the TER, PECO reference 112 is a radiation analysis for the organic materials which comprise the motors' electrical insulation system. The radiation analysis of the motor is complete in that all the organic materials within the motor are addressed. The motor splice insulation qualification is covered by System Component Evaluation Worksheets which are located in the Electrical Power Sys' tem part of the database. The extension of this analysis is not necessary since the remaining materials are metallic.
The original motor bearings have been replaced with sealed bearings as a result of the PECO surveillance and maintenance program.
Conclusion:
Based on the above information, it is concluded that the Reliance fan motors are environmentally qualified for the postulated accident conditions at PBAPS.
1 1/3/84 i _ _ _ _ _ - _ _ _ _ _ _ . _ _ _ _
l PECO Evaluation l
l FRC Item number: 105 Unit 2 Description of Item: Electrical Cable Rockbestos Pyrotrol Summary of TER Item Unit Deficiencies 105 2 1 3 13 Documented evidence of qualification inadequate.
Evaluation: Rockbestos letter to J. J. Ferencsik dated 8/30/78 (PECO Ref. 49) establishes similarity of Rockbestos Pyrotrol cable to Firewall III cable. Rockbestos qualification report (PECO Ref. 48) defines the environmental qualification levels for Firewall III cable:
40 year qualified life at 90*C, 2E8 Rads, 100% R.H., 346*F at 93 PSIG-LOCA profile. This provides evidence of qualificatf.on.
Aging degradation is included within the generic discussion of aging.
The cable is used to supply power to Class lE equipment. The above qualification test demonstrated that the cable will hold rated voltage post-LOCA and satisfies requirements for functional operability.
Conclusion:
Based on the above information, it is concluded that Rockbestos Firewall III cable is environmentally qualified for the postulated accident at PBAPS.
1/3/84 s ___ _____-______ ____
PECO Evaluation FRC Equipment Item No.: 66, 67, 68, 69 Unit 2 66, 67, 68, 69 Unit 3 l Description of Item Rosemount 510DU Trip Unit 1
i Summary of TER l
l Item Unit Deficiencies 66 2&3 3 4 7B 7E 10 67 2& 3 3 4 7B 7E 10 68 2& 3 3 4 7B 7E 10 69 2& 3 3 4 7B 7E 10 Evaluation: The subject of aging was discussed generically.
FRC states that they are concerned with the units associated with the detection and mitigation of a main steam line break in the steam tunnel. This accident causes a 1.5 pounds per square inch gauge (psig) increase in the ambient pressure for the location of these trip units. Since the trip units are associated with the event that causes the increased pressure, PECO re-reviewed the operating requirements and the area pressure profile.
The Peach Bottom FSAR (Section 14.6) states that the MSIV closure initiation occurs within 200 milliseconds after the break occurs; the pressure profile shows the area pressure peak occurs at 200 milliseconds and is above atmospheric for approximately 100 milliseconds. Therefore, the trip units operate during the pressure up-ramp, considering the conservatism in the pressure calculation, the Rosemount statement that there are no pressure sensitive components, and the PECO inspection, PECO considers the trip units qualified for their intended use.
l l The TER identified a deficiency associated with the radiation qualification of 2 trip units located in Unit #3, specifically Room 257. FRC states that no evidence of radiation analysis or testing has been presented; and therefore, the radiation qualification is deemed unacceptable.
PECO has reviewed the Rosemount qualification documentation at GE/ San Jose and considers the documents that were reviewed sufficient evidence of radiation qualification.
The documentation at GE shows a qualified level of .195 megarads. The specified level reported on the Peach Bottom SCEW was a 30 minute LOCA l dose, which is not only conservative in its calculation but is for a time period twice that reported as the required operating time on the
( SCEw. Furthermore, any transmitter / trip unit loop required for a high energy line break (HELB) has an operating time in the millisecond j range, which moves the radiation requirements to that of normal plant l conditions.
1/3/84
PECO Evaluation The trip units in question see a dose frcm the secondary containment cloud of 51 rads in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and a dose of 35,100 rads after 40 years of normal operating conditions. Adding these together the total dose is only 35,200 rads, which is still well below the qualified level. In fact, there is a margin of .16 megarads or a factor of 5.
Conclusion:
Based on the above information, it is concluded that the Rosemount 510DU trip units are environmentally qualified for the postulated accident conditions at PBAPS.
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1 PECO Evaluation FFC Equipment Item No.: 70, 71, 73, 74, 75, 76 Unit 2 70, 71, 73. 74, 75, 76 Unit 3 Description of Items Rocemount 1151 Transmitter Summary of TER Item Unit Deficiencies 70 2&3 1 3 4 71 2& 3 1 3 4 73 2&3 1 3 4 74 2&3 1 3 4 75 2&3 1 3 4 76 2& 3 1 3 4 FRC's conclusion rejects NEDO-21617A as adequate documentation to substantiate qualification.
Evaluation: The subject of aging was discussed generically.
PECO has reviewed the Peach Bottom environmental requirements against the conditions in the topical report, NEDO-21617A, and fcund that they are sufficiently enveloped. PECO has also reviewed. the Rostmount qualification documentation in General Electric's f;.les at San Jose and found it to be satisfactory evidence of qualification.
Conclusion:
Based on the above information, it is etncluded that the Rosemount 1151 pressure transmitters are environmen : ally qualified for their intended use in the postulated accident conditions at PBAPS.
1/3/84
PECO Evaluation l
FRC Item Number: 115 Unit 2 Description of Item: Scotch #17 Tape Summary of TER Unit Unit Deficiencies 115 2 3 4 Evaluation: PVC taped splices failed during exposure to an inside containment simulated LOCA/SLB accident temperature profile. These specimens were part of a large array of cable splice types and methods. This large array was designed to simulate any possible type of cable splice encountered during a scheduled comprehensive field inspection of electrical penetration splices at PBAPS. The completed field inspection revealed no cable splices of the type in question here. Therefore, we can conclude that the deficiency above is not applicable. PECO's response to I.E. Bulletin 79-01B lists Scotch #17 tape as a splice insulating material. This should not be misinterpreted to mean its use as a single splice insulator; it was in fact used in combination with two other tapes to fonn an insulated splice of the type which successfully passed environmental qualification testing.
Conclusion:
Based on the above information, it is concluded that Scotch PVC tape is environmentally qualified for its intended safety function at FBAPS.
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{
1/3/84 L. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ __ _ . _ _
c, t
Y ATTACHMENT 3 PHILADELPHIA ELECTRIC COMPANY PEACH BOTTOM ATOMIC POWER STATION UNITS 2 AND 3 DOCKET NOS. 50-277 AND 50-278 EQ MODIFICATION SCHEDULE I
1 V
I Philadelphia Electric Company Peach Bottom Atomic Power Station Units 2 ard 3 Docket Nos. 50-277 and 50-278 Attachment 3 EQ MODIFICATION SCHEDULE PBAPS UNIT EQUIPMENT IDENTIFICATION NUMBER EQ MODIFICATION STATUS Common OAV20,0BV20,0CV20 These motors will be replaced.
Completion due by 4/84.
2& 3 M0-14-11A,11B,12A,12B The brakes on these valve actuators 2& 3 M0-10-25A,B will be replaced; Unit 2 - Completion due by end of 2& 3 MO-14-26A,B,MO-10-13A,B,C,D 4/84 Refueling Outage 2& 3 MO-10-34A,B,MO-10-154A,B Unit 3 - Completion due by end of 10/84 Refueling Cutage 2& 3 MO-23-19,MO-23-20 MOV Actuators will be replaced by 3/85 2 M0-23-25 The drive motor will be replaced.
Completion due by end of 4/84 Refueling Outage.
2& 3 SV2671A,B,C,D,E,F,G These solenoid valves are being 2& 3 SV2678A,B,C,D,E,F,G tested by NTS, completion due by 6/84.
2& 3 SV2980,SV-4777,78,79,80, 82,83,84,85,92A,B,C,D, SV-4962A,B,C,D,SV-4964A,B,C,D 2 LS-23-91A,B These level switches will be replaced.
Completion due by end of 4/84 Refueling Outage.
2& 3 N3692,N3693,N3772,N3773, GE Control Stations (CS)-Test Complete N3783,N3784,N3884,N3885, MOD to be made to (CS) will be N3994,N3995 complete by 3/31/85. JCO submitted 2/18/83 M. J. Cooney to R. C. Haynes.
2& 3 PS-14-044A,B,C,D,PS-10-120A, S-O-R Pressure Switches (PS's)
B,C,D,E,F,G,H test completed successfully PS's qualified.
Common DPS-00014,00015 Dwyer Differential Pressure Switches 2& 3 DPS-20400-03,04,05,06,07, (DPS) test completed, switches did t8,09,10,11,12,13,14,15, not meet test acceptance criteria.
16,17,18,19,20 DPS's will be replaced by 3/31/85.
See Attachment 4 for revised JCO.
Common CAE65,0BE65 Complete 2& 3 EPTB-003 2& 3 PS-10-121A,B,C,D 1/3/84
Attachment 3 EQ Modification Schedule (continued)
PBAPS UNIT EQUIPMENT IDENTIFICATION NUMBER EQ MODIFICATION STATUS 2& 3 2AP35,2BP35,20P35,2DP35 Complete 2& 3 20B10,11,12,13 Complete 2 20rllA An analysis will be performed; 2& 3 N210025A,B,20B36,37,38 a Purchase Order will be issued 2& 3 39,20D11 6/83. Analysis will be complete by 2/84.
2& 3 MPL23-1,2 These items have been exempted 2&3 FT-23-82 from a qualification up-grades 2& 3 PS-23-68A,B,C,D see response to SER Item 4.2 2&3 PS-23-84-1 9/3/81 submittal.
2& 3 PS 97A, B l 2&3 PT-4952,4953 Feview of the plant-specified PT-5952,5953 emergency procedures has shcwn that the parameter monitored by these pressure transmitters (ie, suppression pool pressure) is not considered a Type A variable as defined by NRC Regulatory Guide 1.97, revision 2. Therefore, these transmitters do not need to,be re-placed to meet the environmental qualification requirements of IE Bulletin 70-OlB.
2&3 TE-2501-36A,B Review of plant specific emergency TE-3501-36A,B procedures has shown that this instrumentation is not needed to provide primary information that is required to permit the control room operator to take specific manually controlled actions for which no automatic control is provided and which are required for safety systems to accomplish their safety functions for DBA. The BWR Owners' Group subcommittee on inadequate core cooling has conducted this review.
2& 3 LT-02-3-72C,D (old LT No.) Unit 2 - Complete
- LT-02-3-110C,D (new LT No.) Unit 3 - Complete l LT-02-3-73A,B (old LT No.)
i LT-02-3-lllA,B (new LT he.)
l l
l 1/3/84 1
Attachment 3 EQ Modification Schedule (continued)
PBAPS UNIT EQUIPMENT IDENTIFICATION NUMBER EQ MODIFICATION STATUS 2&3 2-PT-6-105 Unit 2 - Completion due by end of 3-PT-6-105 4/84 Refueling outage.
[ Unit 3 - Completion due by end of 10/84 Refueling outage.
2& 3 TE-2442A,B (old TE) Unit 2 - Completion due by end of TE-3442A,B (old TE) 4/84 Pefueling outage.
TE-2-71-A1,B1,C1,D1,El,F1,G1,H1, Unit 3 - Complete K1,L1,M1,N1 (new TE)
A2,B2,C2,D2,E2,F2,G2,H2, K2,L2,M2,N2 (new TE) 2& 3 POAM-2-70A,B,PGAM-2-71A,B,C, Complete D,E,F,G,H,J,K,L 2&3 POT-2-71A,B,C,D,E,F,G,H, Unit 2 - Completion due by end cf J,K,L,M 4/84 Refueling outage.
Unit 3 - Complete 2& 3 RE-8103A,B,C,D Complete RE-9103A,B,C,D 2&3 PT-8102A,B,C,D Complete PT-9102A,B,C,D 2& 3 SV-8101 Complete SV-9101 l
2& 3 SV-8100 Complete SV-9100 e
LY121683M340 1/3/84
7 k
ATTACHMENT 4 PHILADELPHIA ELECTRIC CCMPANY UNITS 2 AND 3 DOCKET NOS. 50-277 AND 50-278 JUSTIFICATION FOR CONTINUED OPERATION DWYER DIFFERENTIAL PRESSURE SWITCHES l
I I
u_ - _ - - - - - - - - - - _ - -
Philadelphia Electric Company Peach Bottom Atomic Power Station Units 2 and 3 Docket Nos. 50-277 and 50-278 ,
Attachment 4 Justification for Continued Operation Dwyer Differential Pressure Switches -
Dwyer Differential Pressure Switches (DPS's) have been environmentally tested by Franklin Research Center for PECO. The switches functioned successfully through baseline functional testing, radiation aging, thermal aging, seismic testing and for 4.5 days into the DBA simulation which represents a postulated post DBA period of ;>[' -
13.5 days. The test switches were thermally aged for periods of 20 !q n4 .
years and 40 years before DBA testing which adds to the margin of the gA,*[. -
DPS's installed at PBAPS which are only 10 years old. The DPS failure ,y was such that the pressure actuated diaphragm became increasingly s.
]
stiff during the test and eventually would not move when pressurized 4 i P.; ?. --
7^
to open the micro switch within the DPS. No. electrical failure or l.2 h ',.f, i '.
structural failure occurred to affect the operating of safety-related 4.,
i equipment for the entire 31 days of the DBA simulation. The DPS are used to control the operation of area coolers in RHR rooms.
[ jy.. }
The w-..,
failure of the DPS such that it will not change state does not affect { {,jj, the operation of the running area cooler. These switches are installed . ?ff i 16 in the discharge side of the area cooler fans which would reduce their operating temperature by 10*F and in addition a 10*F margin was added E-hhd.'
k# #I, .
to the general area postulated DBA temperature resulting in a DBA test 5%,
temperature margin of +20'F. Failure of the DPS could affect the h a" capability of the backup area cooler from automatically initiating on .$'b 4 the loss of the running cooler.
J- 7: .
s The RHR system (LPCI Mode) has four pu:ap/ motors located in four g%'@d ',.
different rooms with two area coolers /RHR room. The failure mode of -
the DPS is such that it will not change state after 13.5 days post DBA ;.j- Q and initiate operation of the backup area cooler for the RHR
, . ,f g pump / motor. The existence of the backup area coolers is not required . . .w -;.'
r s ./ ;O to meet system requirements or the single failure criteria; as redundant RHR equipment can neet the cooling requirements resulting $ L#// ?
from a DBA. d2_"
6 9. y ;.
Based on the results of the FRC test, the RHR area coolers will start at the onset of an accident and cycle between the lead fan and
, pj6 .
. .. r e ' v .
backup fan (if required due to loss of lead fan) for 13.5 days. Ten fikf minutes after the start of the DBA only two RHR pumps are required to R p~ . -
effect an emergency shutdown, (ref. Table 8.5. 2a PBAPS FSAR) . If the %;;7 [
DPS's failed 13.5 days after the beginning of a LOCA and the backup -6 area cooler did not start, an increase in room temperature would be T
??b(
- Q Di p ,- e .,
.% V Y 1/3/84
Attachment 4 indicated in the control room and the operator would take appropriate action to start the redundant equipment in one of the other 3 Min rooms. Operation of the NIR pump / motor initiates operation of the area coolers with the DPS in the closed position. The DPS is normally in the closed position during system shutdown and does not have to char.ge state to initiate operation of the area coolers, therefore, it will perform its safety function.
Based on the failure mode of the DPS, the fact that the DPS does not have to change state to initiate operation of the area coolers and the RHR pump / motors are redundant, PECO concludes that PBAPS can continue to operate without undue risk to public health and safety.
l WJC LCY LY121633M205 Rev. 1 1/3/64
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