ML20084L434

Suppl to 840120 Petition for Show Cause Re Emergency Feedwater Sys.Nrc Should Independently Verify Adequacy of Environ Qualification of Each Component in Emergency Feedwater Sys.Certificate of Svc Encl

ML20084L434
Person / Time
Site:	Three Mile Island
Issue date:	05/09/1984
From:	Weiss E HARMON & WEISS, UNION OF CONCERNED SCIENTISTS
To:	NRC COMMISSION (OCM)
References
NUDOCS 8405140460
Download: ML20084L434 (32)

Text

_

J55<. o .

! UNION OF CONCERNED SCIENTISTS i3,e c.,,,,,-tu . m,...c. s.w. . s. noi . wa i,35!E 2->e . <2o2> 2*4eaa

'84 MY -9 P4 :52 eer ? r;r ' S i r .; ; ,., i UtlITED STATES OF N4 ERICA DEPOR3 TilS NIA'IL\R IEX2JIAP0aY COtitS3 ION 00 TRCT NUMBER P;1GD & UTIL.nen FAC.,gg r * *a" , g h 1.1Cb 1RJPPIE4Fiff 'IU Uti!0:1 OF C0tCER!ED SCIEffrIJPJ' P17PITION ipr Sil0W CAUSE C0tCERNItu 'n41-1 IM3GE!CY PEEDMYPER SYSTP21 Ellyn R. W.31aa 0)antst for 15stition sr llarmon, Wola1 t. Jordan 2001 3 Street, fl.W., Suite 110 WashinJton, D.C. 20009 Date 1: Hiy 9, lWll 0405140460 040509 PDN ADOCK 0D000;109 0 VDR bD3 .

Steln OfIket 26 Chisteh Street ca..ihrlhe. Sta..aihis.ctis 022316 . (617) 587 5552

l SUPPLEMEffP 'IU UNION OF CONCERNED SCIE?fPISTS' PI:'.TITION FOR S!!OW CAUSE COtCERNING 'It4I-l EMERGEtCY FEEDWATER SYSTE*1 1 1 1 1

IntroJuction 1

On January 20, 1984, the Union of Concerned Scientists petitioned the  !

l Nuclear !bgulatory Omnission for an order suspending the operating license for meee Mile Island Nuclear Station Unit tb. 1 (74I-1) unless and until the i

plant's Dnorgency Feodater (EFW) Systen complies with the NRC rules applicable l to systems important to safety (including safety-grade, safety-related, and engincared safety feature systems) . Union of Concerned Scientists' Petition for Show Cause Concerning T4I-1 Dnergency feedwater System, January 20, 1984. We  ;

Omnisalon declined to tako jurisdiction and referred the petition to the NRC staf f tv2cause "[t]he Commission doas not believe ao plant specific challenges raised in the UCS petition warrant direct Commission action in the first instance," Samuel J. Chilk, Secretary of the Commission, to Ellyn R. Weiss,'

General Counsel, UCS, Apell 24, 1984, p. 1.

On :4ay 4,1931, UCS received a copy of a letter dated April 25, 1981, sent I

to GPU Nuclear by tha NRC staf f which disclose 3, as UCS alleged, that vital canponenta of the T4I-l EFW system are not environmentally qualifled as required by 10 CFR 50.19 and General Design Criterion 4 of Appendix A to 10 CFR Part 50. .

1 Aa discusse3 belos, the information contained in the staff's letter is the basis for UCS supplementing the action requested in our original petition.

Furthormore, since the additional relief requested is directed in part against I the NRC staf f, UCS requests that the Connission itself take jurisdiction in tha first instance with regard to this supplement.

. , 1 l

1 Discussion On March 20-21, 1984, the NitC staff performed an aulit of the environ-mental qualification files for T4I-1. According to the staf f, "[t]he primary purpose of the audit was to review the environmental qualification docunentation

. . . for the emergency feedwater system." % is is being done in order for the staff to prepare a response to the January 20, 1984, UCS Petition for Show Cause l

Concerning T4I-1 P,nergency Feedwater System. We aalit results were sont to the I l

Coanissioners and the parties to the T4I-l restart proceeding as sa enclosure to )

l a one-page letter f rom John F. Stolz to llenty D. Ilukill, Apr1125,1984. A copy of the letter and its enclosure are attached. Because the cover letter trans-I mitting the audit results is misleading and deceptive, and because there is no indication that the staf f intends to properly follow-up the results of this 1

audit, UCS believes it is necessary to put the results on the decisional. record, to place them in perspective, and to supplement the relief requested in our January 20, 1984, Show Cause Petition.

We audit reviewed the environmental qualification docanentation for eight component types, seven in the EFW system. Ibsults of Electrical Equlpnent Environmental Qualltication Audit, GPU Nuclear Corporation, Wree Mile Island, j i

Unit 1, Ibcket tb. 50 289, (hereinafter "Awli t lusults"), p. 1. We cover i

Ictter from Mr. Stolz states: ,

i In general, we believe that the files coatain docunentation that can be utilized to provide the basis for demonstrating 4 that the EFW equipment is qualifled, with one exception.

Tha innocent reader (or a busy Comnissioner) might reasonably conclude from this that the audit turned up satisfactory docanentation of environmental qualification in all but one case. We cover letter neglects to mention what is l 1

l found only by reading the enclosel au: lit results: that in none of the eight files audited was the documentation in fact even close to adequate. It is a 1

l

feat of true Orwellian newsprak, if not an outright f alsohml, to twist those i

remarkable negative results into the rosy concluaion of fered in the cover letter. We equipnent audited woro not minor components. Wey inclu< led the emergency feedwater pumpc, rJW system valves, electrical cables, terminal blocks, and flow transmitters (instruments) . j To begin with, three widespread deficienclos were identified which apply "to all the files reviewed." First there was no evidence that GPU hal reviewed the docunentation or concluded that that the equipnent is qualifled. Second, the handwritten material in the files "is not signed or dated and shows no l l

indication that the statements /information contained on those sheets has over been verified by a checker or approved." Third, the files specify neither the  !

duration of timo for which the equipnent has boon qualified nor the i post-accident period of time for which it is required to function. Audit Ibsults , p. 1.

Reso three d:ficiencies, which applied to every type of component audited, muld be enough in themselves to lead one to concludo that GPU's claims i

that the equipnent is environmentally qualified aro without foundation. Ibwever,-

I the specific component-by-component deficienclos are even wese. I 1

For the motorized valve actuators in the EIM synto.n which were aadtted, the filo did not even docanent. the motor manufacturer, the insulation class, and I

the current type despite the fact that the tbvember 5, IW12, wchnical Evalua-tion Ibport ("TER") for T41-1, sont to GPU on Dicember 10, 1982, specifically noted theno onissions as deficienclos. Copios of the portinent TER pages are enclosed. toy clearly docanent that in 1982, Gpu was told that it had failed to establish that the FEW valvo actuators in T41-L were suf ficiently similar to the components which had actually been tested so as to make reliance on the testa valid. GPU never submitted a justification for continued operation (JCO)

i

. . l dith those caninnont.1; it simply continual to asaort th1t th7y waro q1tliflod.

Ilwor, over 15 months lator, the dermntation still <l32s rnt oxist to 1upp)tt thosa claims.

The 1ER preparm! by Franklin Rosearch Contor concluled with respset to DNipnent Item 15 (EEW system valves EF-VIA&D) as follows at pajo 51:

C. Tio licensoo has cited Limitorque reports D0027 ad B000) as evidence of qualification for this equipaent [to.n.

Similarity has not b?on ostabitsha l intsoen the installed o pipnent aryl the toit ainal:noni in olthor rep)ct. Goveral points should also be notol atnut the licens?o's qualification packap for this o pipnont item:

1. D0027 testod a class Ril insulated MVA [motorizSl valvo actuatori and the licensoo has a class G insulated MVA installed. Docauso of this, D0027 cannot tn used to demonstrato the functional capability of the installed equipnent to withstan-1 a tempfraturo transient to tho levola stipulated in the report.

2.1ho host transfor analysis prosented in D0027 could in ,

applicablo, however, D0027 tested a model Q43-00 which l is of a difforent size and m23s than the installed equipnent (which is molol $43-000) . U n l'icensoo hhis not provided an analysis of thoso dif forences.

Tioao prociao doficienclos stiLL oxist.

Moreover, the staff audit of March 20-21 shows that the to.npiraturo profilo used by GPU to claim qualification was loss novoro than would result from a break of the pipe which supplies steam to the turbino-driven pump. GPU has provided no justification for using a loss sovero envirorrnent. Alain, this is not a nostymliccovered deticiency. Ttn 1902 TER foon1:

3. Tio licensoo claims that the MVA temp 2rature will not exceed 250F, the qualification loval establishel in D000?

[tho tost report rolled on). The licensoo has not provided an adspato technical rationato to support the statomont maJo on paqo 3a. 1ho data presented in D0027 (the second tost report rulind on) was far a specific size and mass MVA exposed to a specific tempsraturo transient, all of which aco different from the licensoo's paramotors. Por the licensoo to draw conclusions with no a411tional analysis is not valid. Other host transfer analysis [ sic] have tnen porformed on this alzo MVA which show thit an expnuto to 350P for GO sec. and 100P for 100 sec. results in a limit aditch surface temperature of 291P. Tils heat transfor analysis more closely simulatos the licensoo's p stulatml

3 i a,3cident tranalent at>l in licatna th it tho ?tVA to.nporaturo muld riso above the level cop >rted in 3000), which it abould in noted ajain has not boon de.nonatratoI to tn applicable to this ocpipnent item incause of similarity. -

Id. at 51 and Sj. i nat fundamental deficiency still exists. ,

30 sad truth is that, almost five years after IE Bulletin 79-013 I

required all licensoon to document the environmental qualification of i

olectrical 32foty e.luipnent and 15 months af ter the tea was issued, GPU did not havu docanentation to alegastoly support that any of the oight typos of companents audited in environmentally qualif Lod.

r Vio next oxa.nplo tu the tw motor-driven enorgency feedwater panps, i cortainly basic co.npononts nooded for ducay host removal following a

postulated design baats accident -- and particularly important in the caso of ,

TtI-1 where the staff appears intent on supporting GPU's position that tho turbino-driven EIM pump nood not moet the Comnission's rules prior to restart.

Soo Safety Evaluation by the Of fico of Naclear Roactor Ngulation Sup[ntting Dicoctor's Interim Decision Undte 10 CFR 2.206 (Soismic capability of Doorgoney Poodsator), April 27, 1984. The first deficiency noted by tho staf f is that the "filo does not contain information to establish similarity between.

theso motors and the motor, lead witos and insulation tested." Audit Results,

p. 2. Indood, GPU did not oven seek such information until Mitch 15, 19341 Once a'jain, this prociso problem was broajht to GPU's attention in the 1932 TER:

The licensoo has not provided evidenco of similarity for the installed motors to tho tested motors or insulation systems.

TER, Feluipnent Ito.n 51, p. Sf. .

In fact, the environmental qualification doficienclos of the T41-1 EEM ,

panp motors woro identiflod much earlier in the staff's " Partial Review, lautpnent Qualification ' Report by tho Of fice of Nuclear Roactor Regulatlon" (horoinafter, "1981 Review") for T41-1, transmittod to GPU by lottor from

Thonas 4. tbvak to 11. D. !!akill, February 25, 1991. See 1981 Review at B-2, motors CF-P2A and EF-P2B. tw stat f's February 25, 1911, lottor directed GPU to "provido within 10 days of receipt of this lotter, a written statement, signed under oath or affirmation suptneting the safe oporation of your facility, that takes into account the NRC staf f's preliminary list of deficiencies."

Tie sum total of GPU's resp)nse to this was a lotter dated March 12, 1931, f rom II. D. llakill to T. M. tbvak which stato41 in its entirety:

"this lottor is in resp >nso to your request of February 25, 1931 rejarding onviron;nontal qualification of oloctrical quipnont. Our staff has roviewxl the proliminary list of deficiencies sat forth in your letter of February,25,1931, taking into account tho information contained in our uutinittals of 0;tobor 31,1980 and January 30, 1981. Ibsed on our review of those submittals and the planned activition unJorway for the restart of T4I-1, thoto will be aloquato assuranco that T4I-1 will oporato safoly following authoriz-ation for restart.

Based up>n this entitoly conclusory lutter, tho staf f wroto a safoty evaluation report which stated that GPU had "conploted a proliminary review review of tha identifiol deficienclos an1 has dotor;nined th1t, af ter duo consideration of the doficienclos and thole ramtfications, continued safo oporation would not be alvorsoly af fected." T41 Restart floating, Tr. 21,966-7.

VM fact is that the staff hal then no basis for ju<lj in) whether GPU's adoopin-), unaupp3rtel claims waro true and, even W)rso, now his facts that GPU's claims wore anil continue to tw fatuo.

Vio list of fundanontal deficioncios disclosed by the recent ataff anlit gaos on and on. For exa:nplo, the filos for electrical cablo contain "na docanentation to establish similarity botdaen the cablos tested and thoso inatalled." Aalit Ibsults, pp. 2, 3. to qualiflod life for the cablos h23 boon catablished. p. at 1. Wo will not go into tho doficienclos in oach l l

I

.y.

canponent type in details a copy of tno hilt Roaalta is onclocel. Vmy establish t>> yond r m onablo question that the filos do g etatahllsh the gaalifleation of any of the cangonents.

Urxlor thoso circumstancos, Mr. Stolz's assortion that the "filos contain docanontation that can be utilized to provido the basis for dos nstratinJ that the IW equipnont is qualified," is at best i deceptivo semantic circianlocu-tion arKl at worst a patent falsotml.

In adlition, the Commission should bo acro that Tit-1 was ono of the plants which the staf f assured you had no environuntal qualificition doficionclos as of Juno 30, 1932 -- that each conponent had uither boon desmatratud to bo unvironnontally qualified or a valid justification for continued oparation (J00) had lyson provid*l. On the contrary, for the compononto aalited by tho staf f, no J00s woro provided and qualification is still not ostablinhod. D>spito the statt's 1932 assuran::o to the Commission that thoro woro no environnontal qualification proble.u at Tit-1, tho staf f had to request an extonsion of timo to respond the onvironmntal quilification aspects of UC3's Show Causo Potition, which the Canission granted.

3)coover, althoajh the staf f reconmond21 restart of T41-1 on Docomtwr 5, 19i33, when the statf b+jan bolatodly to pursuo this lasu1 in ordor to resp >nd to UQl's Show Causo Potition, it inform +1 GPU th1t itn "princip11 concern with thu pitition wald be at timo of rustart will the plant moot the owintin'J regulations?" Transcript of March tl , 19tli, Moo t in-J with UPU, TMt-1 thvirannontal Qualifications, p. 142. IMr in'; that moo t in*j , CPU malumnly aasurmi tho staff that tho onvironnontal qualification filon had urvlorgono an "indopnvlont" ruview by GPU quality a1ouram:0 pironnot anl thtt they fully oupp3rted GPU's claims of palificition.

i l

[

-a.

MA. U: '!1N) : Any doticluncy identified in this (TSRl, pajo by pajJ, du expict that you havo anawr ta thaac duticluncios.

Whan the inspuctor gmu out thoto, the TER will sorvo as i guido to inspect.

l M. MUS [GIUl tiat has boon our promino. ' mat is what w tried to do, to bo ouro we had tho information in the filo.

l I4R. IE: Did you make that commit;nont? If you m>lo that -

l cunnitment, then w will proceed.

MR. MU3: Wo aven ha<l a trial annonnont on our filo by our own QA to mako sure that this kin! of information is in there.

Wo ha1 indopinlont vorification if you will.

MR. IIAlettu (GPuli 1 am rut suro tvaw indoptrilont.

, Ma. MAU3: It is indopntiont, inliovo mo. W>> ovon hvl a trial run to mako noro. 92 mijht nay yo1, w havo it, but wo are projalicod no w lot tonotoly olaa tako a look at it, naying hoy, do they really havo it. Okay?

J;1.,pp.25-26.

It to now manitost that Git 01 thor lacks the conpitonco to ovaluato onvirorwontal (patification or in untrutnful. (trilomi, since the "trvloponlont roviow" wu dono by GPU ipality assuranco p>raonnot, w met question thoir compitoneo or intoJrity.) As recontly as robruary 24, 19114, GPU statml that it had "rospondod to the outstanding concerna" raiand in the onvironmontal qualification review. Licensoo's 14:np>n99 to Union of Omeornod notontists' Potition for llhow Cauno 0)ncornin; T41-1 Mnorgoney romisator Systen, p.17. Um Aallt 16Nulto d<mmetrato that they hivo nit d-)no W); thtt nano dificienclos identiflod by tha tUtPo contrar: tor in 1912 aro at.111 outstalin1 1;m, also, 010 tiuotoar 'lk:nnical 14:apmno to Union of Gw:ornet D:lontlita' Ikttition for Show Cio1o C)neornin) Tit-1 linorpncy roodsator System, robrutry 21, 19:11, sign +1 urblor oath by Richard P. Witwm, Vico Prostilont for W;hntual run'Jtioni, who claims that GPU "documonted the runolution of out4tanelin) tiillficition items...." tj., p. 4, vnphnim alJol. 'tho to a11ortiam soro n >t. withirawn in tho ta) sub w pant "roviso!" roopina n to it:1'n pttition filt*l by Ott, tho j

l i  !

I l

l latuit twiw) datol April 26. 1911 ordt aanth af tor the Statt'n 1411t. In <*lthor l

l caso, whother rmtml in inoptnean or dinhonetsty, GPU's claims are utterly untrustwirthy and thoto is the tv) bula for mnetulin-) that vital :nfoty I eqJipnont in tho omorgency fooddator en any other safety system in < tither onvironnontally quattflod or that a valid justification for continuel optration has boon provi bl.

Th9 final qumion is shoro tho Nic profoola f ran hoto. Ibapite the fae:ts that all o1Jht of thu of Jht co,nponont f11os aulitud woro ,doflotont in turvitnuntal ways, anl th at tho Staf f has conclalo.I that tho aollt cownti aro l

"<janorally applicablo to all fil-1 onvironwntal qualification filon" (lotte r fran Stold to liukl11, April 25, 19110 , the staf f apturontly has no plan 1 to go l

furthur. It dl roots GPU to conp)rvi oq1y to tho aptclfic itern3 aalited.

Althoujh it is maj'joutext that GPU "considor" tho StoAlor impitaations, na roap>nno to relutrol. ' min mako1 a mockory of the "aallt" mothol of reyjalation. i i

W tn an aalit of only a n.u11 fraction of asfoty olalpnont shows 1004 run-oinplianco, tho statt euroly canrnt continu's to opstato as if evorythlry; rot aalitel is in onnplianco. Ild);ostto; that GPU "conaldor" tho incrollblo 1

impliestiona of this aallt la hardly nuf ficiont. 'the NHC sitt have a rational l Inits for conciulinj t. hat oporation of fil-1 wout1 in nifoi that it manifustly 11.sa rut luv9.

e nsf.

• m i

'mo infor ution oint ain+1 in (no A111t nmita arti <lisca m t hornin providos con [=#11tn'J nupp>rt for IMI'm Divis Caa49 l*# t i t ion. ' thoro in ryst l

l comnahto anuranco that tho fit =1 omorJ moy fev+1sitor 9/4 tom walet f anation in ciruanitanina whon it la no+141 for < loci / haat ternv11.

l l

l .

l

Pernaps the rm)st llsturblnj alpict of thil situation is that Cit, with the NE atstf's uuggurt, claimod that all of thors conp)nonts wro fully (palitim!

(or had a valid justification for continaml oporation) and that tho da:umenta-tion to prova it was in GPU's f Llos. If UCS hai not filed a show Ciuao Potition, tho staff mi<jht never ha,Vo discovocod othorwise, and certainly not priar to restart. Ibw can the Osenission have any confidence in the accuracy of tho asuttions malo by its own reijulstory atsf f when it is apptront that the staf f ha s simply tnen ochoinj tho unnopp)tto;l aawetions of Git? O n is forced to cunctulo that tho rejulatory procoas is inatitutionally uniblo to copt with an intranil<jont or inconpitont i tconwo. M cultman Pallatino han tenirked,

'pality cannat tn rojulated in, it must tn built in. Um sorry nLtuation at I41-1 providoa a dramatic illustration of the rovnn why manajomont competenco arkt intejrity are such crucial reptrements for a naclear licensoo. It is tronic that at thle mamont, with GPU's compotonco an'l intejetty one of the contral innuos in quantion in the costart procuelln<j, the staf f has ijivon no inlication thit it pirc=1ves the connoction tyttwoon its Aallt Intsalta arvl that lanao, much loan that it intonia to tako the appropriato action.

It is Ltl's p)aition thit the facts describod horoin call for the followinj rollof (in .tllition to that repostml in our January 20, 1981 Show con m Potitlon)i

1. A4 a pen onlition ta roatart, the ntaff alnull in directml to indiptolontly vority t'nt dmanontation ostatn .yy t thit it in tochnically outf f Leiont to ilomonstrato environ <nontal quallt(cation of each anil ovory oloctrteal empinont in tho onorijoney foolsator ny4 ten an1 in ovory other systo,n to ptrol for proptr optration of tho onorjoncy fo+1dator nysten.

1

_11-

2. The Office of Investigations should be directed to immediately investigate whether GPU has made material false statements to NRC in connection with the environmental qualfication program. Because this issue bears directly on GPU's competence and integrity, the investigation should be completed before a vote on restart.

3. 'Ibe Off fice of Inspector and Auditor should be directed to investigate P

and determine whether the NRC staff has provided false or misleading information to the Boards or to the Commission, or has been derelict in its duty in connection with the issue of environmental qualification in 'IMI-1.

Sutxtitted by, N

El n R. N iss General Counsel Union of Concerned Scientists Harmon, Weiss & Jordan 2001 S Street, N.W., Suite 430 Washington, DC 20009 Dated: May 9, 1984

jaMcg 8 .

UNITED STATES NUCLEAR REGULATORY COMMISSION

['.c' h

/ f WA$mNGT ON, O C 20%S

• %' 'i f E April 25,1984

%, ...../

' Docket No. 50-289 Mr. Henry D. Hukill, Vice President and Director - TMI-1 GPU Nuclear Corporation P. O. Box 480 Middletown, Pennsylvania 17057

Dear M- Hukill:

As you know, the NRC staff and a consultant audited the Three Mile Island, Unit 1 (TMI-1) electrical equinment environmental qualification files on March 20-21, 1984 The primary purpose of the audit was to review the environmental qualification documentation relied upon to demonstrate qualification of electrical equipment within the scope of 10 CFR 50.49 for the emergency feedwater (EFW) system.

In general, we believe that the files contain documentation that can be utilized to provide the basis for demonstrating that the EFW equipment is qualified, with one exception. The exception, the Square D Diodes, is .

further discussed in enclosure (1) which contains our detailed audit comments, fiost of these detailed comments were provided to GPU staff during the audit or at the exit interview. We believe that the comments pertaining to the EFW system should be expeditiously resolved. Therefore, we request that you provide a detailed submittal addressing your disposition of all connents per Mining to the EFW system within la days of receipt of this letter.

Although the audit focused specifically on the EFW system, we believe the audit connents to be generally applicable to all TMI-1 environmental qualification files. You should consider them accordingly.

Sincerely, D

g'Qy Y d(; 4 i

/JcWn F. Stolz, Chief

, Op6 rating Reactors Branch F4 Division of Licensing

Enclosure:

TMI-l EO Audit Comments cc w/ enclosure:

See next page k_ _

Results of Electrical Equipment Environmental Qualification Audit GPU Nuclear Corporation Three Mile Island, Unit 1 Docket No. 50-289 On March 20 and 21, 1984, the NRC staff and a consultant from EG&G, Idaho, audited the electrical equipment environmental qualification files for Three Mile Island, Unit 1. The primary purpose of the audit was to review the environmental qualification documentation relied upon to demonstrate qualification of electrical equipment within the scape of 10 CFR 50.49 that is associated with the Emergency Feedwater (EFW)

System. A total of seven files containing EFW equipment qualification documentation were reviewed. One additional file for equipment not associated with the EFW system was reviewed.

During the course of the audit, the staff and its consultant asked questions of and provided comments to GPU concerning the files and documentation reviewed. Some of the comments are applicable to all the files the staff and its consultant audited, and are very likely to be applicable to all GPU EQ files. In addition, comments on the specific files audited may also be applicable to many other files. Therefore, GPU should review all EQ files and update them, as necessary, in accordance with the comments identified below. The comments made by the staff and its consultant which are applicable to all the files reviewed are listed first, followed by the comments made on specific equipment files.

1. The EQ files contain no indication, other than SCEW sheets (some of which were in the process of being revised) and some brief handwritten sheets, that the documentation has been reviewed by GPU nor that it has been concluded by GPU that the equipment is qualified.

2. Most of the nandwritten material in the files is not signed or dated and shows no indication that the statements /information contained on these sheets has ever been verified by a checker or approved.

3. The files do not specify the required post-accident operating time for the equipment nor the duration of time the equipment has been demonstrated to be qualified. Specifying duration of accident on a SCEW sheet a uf referencing the FSAR is not adequate. Similarly, indicating on a SCEW sheet that qualification has been demonstrated for continuous operation or for the duration of time for which the equipment was tested is neither correct nor does it document why such a post-accident operating time is acceptable.

8

/

Limitorque Motorized Valve Actuators EF-VIA&B, Model SMB-000, TER Item No. 15 EF-V2A&B, Model SM8-0, TER Item No. 11

1. The file should document the motor manufacturer, insulation class and-current type for each actuator to establish applicability of (f

the EQ documentation.

The temperature profile used to evaluate the qualification of the 2.

actuators is a time history following a main steam line break for evaluation 295 ft. of the Intermediate Building. However, the temperature profile resulting from a steam supply to EFWP turbine line break appears to be a more severe environment for approximately the first 800 seconds. The file needs to contain justification that establishes the adequacy of the EQ documentation for demonstrating qualification to this more limiting line break.

3. GPU should review Equipment Environment Qualification Notice No. 24 of IE Information Notice 83-72, and document the results of their evaluation of that information in the file. (This comment was not provided to GPU during the audit.)

Westinghouse Pumps EF-P2A&B, Model HP 450, TER Item No. 51

1. The file does not contain information to establish similarity between these motors and the motor, lead wires and insulation tested. A March 15, 1984 letter from GPU to Westinghouse requests

'the information needed to establish that similarity. A response to this-letter should be pursued and placed in the file.

2. One of the EQ documents in the file, WCAP 7829, states that a motor without a heat exchanger is qualified for short term post-accident operation. The file should document whether the installation in TMI-1 includes a heat exchanger and, if not, the i adequacy of the EQ documentation for demonstrating qualification of the pumps for the period of time they are required to operate post-accident.

Continental Wire and Cable Co.-Cable TER Item No. 107

1. The file ccntains no documentation to establish similarity l . between the cables tested and those installed. The file must l contain either a letter from the manufacturer that establishes 1the applicability of-the test report. or documentation describing how GPU has determined that the installed cable is similar to the specimens tested.

cn ^h l

2. GPU should document in the file an aging calculrif on, using infor-mation from the test report, that establishes a qualified life for the cable.

Kerite Cable -

TER Item No. 106 Same two comments made for Continental Wire and Cable Co. Cable.

Square D Diode

~Model JTXIN6071A, TER Item No. 116 ,

1. EQ documentation currently in the file is not adequate to demonstrate qualification. However, these uiades are associated with ASCO DC solenoid valves and, according to GPU, there are no such valves associated with the EFW system that are required to be environmentally qualified. Therefore, these diodes would not L be required to be demonstrated qualified. GPU should document the basis upon which these diodes are exempted from being quali-fied, and evaluate whether there are any DC solenoid valves and associated diodes in a harsh environment area that are required to be qualified. ,

States Terminal Block Model NT, TER Item No. 110

1. The file should document the specific equipment associated with these terminal blocks, and GPU must determine whether the IR readings documented in the test report are acceptable for the application (s) of these terminal blocks.

Foxboro Transmitters FT-791, 779, 782 & 788, ModeluNE 13DM, TER Item No. (None)  !

1. The EQ documentation, WYLE Test Report 45592-4, states that the end user. must address specific accuracy requirements for each application and evaluate total loop error. GPU must document such an evaluation using the demonstrated accuracies from the test report.

2. Other than SCEW sheets indicating 23.62 years, the file contair.s no assessment of qualified life by GPU. The file should document GPU's qualified life determination.

3. The transmitters were tested with interfaces as described in the test reports, e.g., with a Conax electrical conductor seal assembly with integral electrical junction box, flexible conduit with holes drilled in it, etc. The file should document that the transmitters in TMI-1 are either installed as tested, or a description of their installation provided and the applicability of the test report to their installed condition justified, i

4. Part of the test sequence is seismic qualification. GPU should  !

document that the seismic testing performed is applicable to TMI-1.

5. On page IX-22 of the test report it is stated that a. formal report .

will be issued to answer anomaly N0A F37. Similarly, on page X-25 it is stated that justification for a test interruption, anomaly N0A F42, will be provided in the final test report. Until the formal report addressing NOA F37 and the final test report addressing N0A F42 are reviewed by GPU and placed in the file, GPU should document its evaluation of the anomalies and their effect on the qualification of the transmitters.

Foxboro Transmitters (Not associated with EFW System)

RC3A-PT3 & 4, RC3B-PT3, Model E11GH, TER Item No. 78 PT-282, 285 & 288, Model EllAM, TER Item No. 79 SP6A-PTI&2, SP6B-PT1&2, Model E11GM, TER Item No. 81

1. The EQ documentation reviewed does not resolve the deficiencies identified in the TER for these transmitters. However, the SCEW sheets now reference the WYLE Test Report 45592-4, being used by GPU to establish qualification of transmitters FT-791, 779, 782 and 788 (Model NE13DM). GPU stated that the WYLE report is referenced only to address aging and qualified life for these Ell models. In order to resolve all the deficiencies for these transmitters, including aging and qualified life, GPU should determine the applicability of the WYLE report for qualifying these transmitters. Regardless of whether the WYLE report is used, GPU should document.in the file the resolution of the TER deficiencies. If it is determined that the WYLE report can be used, the following comments are applicable in addition to those above for the Model NE13DM transmitters.

2. The file should document that the normal radiation simulated in

. the testing is applicable to the TMI-1 transmitters.

• O On page iii it is stated that additional testing is being performed 3.

by the manufacturer to extend the accident radiation qualification ar.d to confirm the aging analysis for the silicone capsule 0-rings of transmitters represented by test specimen F-1 (Model NEll).

GPU should document whether the testing completed thus far adequately addresses aging for these transmitters since additional testing appears to be necessary. If it is determined that the results of the additional testing are needed to confirm the aging analysis, then GPU should review the test results and place them in the file when they become available.

4. On page I-7 it is stated that Foxboro Report No. PER-81-106 I provides justification for qualification of untested transmitters by similarity to those tested. Also, page I-171 refers to Foxboro document Q0AAC012 for similarity information. GPU should procure these documents, "eview them, and place them in the file to address similarity and substantiate the applicability of the WYLE report for these transmitters, particularly to Model EllAM.

i l

1 9

9

i l

t i

A NRC Contrcct No. NRC-03-79-118 FRC Project No. C5257 Pcgs ,

l .. u00Knurina. archCenter i

- A De of The frar*An la**we fRC Assignment No.13 lc l , 20th and Race Sweets. Phda.. Pa 19103 (215) 448 1000 FRC Task No. Il G f,"g j EQUlPMENT ENVIRONMENTAL QUALIFICATION REVIEW OF EQUIPMENT ITEM NO. I

,];4, y p)

, . *r IL$. EQUIPMENT ITEM NO.15

! MOTORIZED VALVE ACTUATOR IACATED IN THE INTERMEDIATE BUILDING

$j_D g LIMITORQUE HDDEL SN3000 WITH CLASS B INSULATION {'

((Q . REQUIRED OPERATING TIME: CONTINUOUS p," TER CHECKSHEET NO. 15 ~

@ LICENSEE REFERENCE (S): 662, 2876 i

FUNCTION (PLANT ID): EMERGENCT FEEDWATER PUMP SUCTION LOFW/MSLB MITICATION

!f.' (EF-V-1A, IB) *

,.] ,

LICENSEE SUBMITTAL: SCEW(S): 3, 4 0F 30 ,

% i f}: l f

i

1.  !

b >

ps 1[ I l

i,' '

a h,,$,

e

- l

.t NA DESIGNATION FOR DEFICIENCY IDENTIFIED BY THE NRC SER - CIRCLED ITEM (S) ONLY:

idw ..

(See Section 3 of this TER for Imgend) I

,i R, h QT, Rr, P, H, CS, h S, (R), M, I, 9t, RPN, EXN, SEN, QI, RPS, None, l

R

' 'i Not stated, Not applicable l h

'ib :

LISTING OF APPLICABLE CHECESHEETS:

l l

M Contents ,

Checksheet Page No. f M Equipment Item la l

4. .c lb

}'f; Summary of Licensee Responses to the NRC SER g...

Equipment Invironmental Qualification Summary Forms 2 4,{

no 3a, Ot, 22, 2d g.' Licensee Response to MRC SER System Consideration Review $2, '" '" . II. 't. '!

If.T'.'

L 1 .1 Equipment Environmental Qualification Review A 55, R, 5f, A Sf, l151 Sg, Sh, Si, Sj f ..Q l;.^ * \

Installed TMI Lessons Learned Implementation W

??l~-]j

3. .

Equipment Snemary -

l

'!l Maintenance and Replacement Schedule Su==ary 22  ?, Te j i

, . . l

l. s 1 s - - -

--~.._~_e.. n. ,, . .

7. .

1

p. NRC Contract N@. N RC-03-79-118 FRC Project No. C5257 eage i

t UO0fFranklin Research Center A Dm af The Frenian lasswa FRC Assignment No.13 lb 20e and Race Sevens. PNia.. Pa. 19103 (215) 448 1000 FRC Task No. 4Y_

-i EQUIPMENT ENVIRONMENTAL QUAUFICATION REVIEW OF EQUIPMENT ITEM NO. .[5, j

l ,

4 1  :

St30tARY OF LICENSEE RESPONSES TO THE NRC SER - ONLY Char run ITEMS ARE APPLICABLE: i

.]

X Tne Licensee (has/t.__ ..;M provided a response to the SER concerns. ,

M The Licensee pszar/has not) specifically stated that the equipment is -

qualified and/or will function when exposed to the applicable DBE '

environmental service conditions. l N The Licensee has presented information which shows there are no

.'. outstanding qualification deficiencies.

' ki The Licensee (has/has not) proposed a corrective action for this equipment

- item whose qualification has not been fully established.

'.[ Justification for interia operation (han/has not) been provided by the

- .. f 1 Licensee for this equipment item.

,W '

Corrective action specified by the Licensee

.~n. . a:. .

Ef Equipment replacement with qualified equipment I,lft Equipment modificatQn

$@ Equipment relocation above submergence level g; -

.q .

Relocate or shield equipment from radiation source verify qualification by ' additional (testing / analysis)

_'d,f.,1 - . Equipment relocation to a mild environment g

q?..j; e ,

Qualification testing of equipment in Trogress Other ( )

Q.??

'?f? ' The Licensee has provided other information for this equipment item

• i- thac can be construed as a basis for justification for interim

.',.. operation.

q:. , *

'f.i The Licensee (bas /has not) provided a schedule for the proposed corrective action. (Schedule for accomplishing the corrective

', action .)

e The Licensee states that the equipment item does not require qualification and/or should be exempted from environmental qualification.

.x-..

@ DESIGNATION OF RESULTANT NBC QUALIFICATION EVALUATION CATEGORY BASED ON RFVIEN

- CIPr'f.Pn ITEM ONLY: (See Section 3 of this TER for Legend)

I.a Qualified II.c Qualified Life Deficiency l

I.b Modification III.a Exempt ler.m Oualification Not Established \ III.b Not in Scope II.b Not Qualified IV Documentation Not Available

l

) . . .-

NRC Contre.ct No. NRC-03-79-118

1. g FRC Project N3. C5257 Pcca 000u Frankhn Research Center A De of The Fuinam* FRC Assignment No.13 2 i j 492 20th and Racn Seema Ptda.. Pa. 19103 (215) 444 1000 FRC Task No.

[,_...l

9 y 60UtPMENT ENVIRONMENTAL QUALIFICATION REVIEW OF EQUIPMENT ITEM NO. /5

:s N

Uh

• C r4'

.,(.g _ EQUIPMENT ENVIRONMENTAL QUALIFICATION

SUMMARY

FORM v DESIGNATION:

@4,, h. , -

X = DEFICIENCY "UN NRC REQUIREMENTS .

M7 w .a X-K. Documented Evidence of Qualification Mequate )(

D Mequate Similarity Between Equipment and Test Specimen Established ~

Y

}$',' Aging Degradation. Evaluated Mequately Y M'h Qualified Life or Replacement Schedule Established (If Required)

[pj[ Program Established to Identify Aging Degradation g Criteria Regarding Aging Simulation Satisfied (If Required) py Criteria Regarding Temperature / Pressure Exposures X o Peak Temperature Mequate sg[j.. o Peak Pressure Adequate o Duration Adequate T'[l o Required Profile Enveloped Adequately b o Steam Exposure (If Required) Adequate h{

y:1: Criteria Regarding Spray Satisfied criteria Regarding' Submergence satisfied h

% Criteria Regarding Radiation Satisfied

%gG Criteria Regarding Test Seque'nce Satisfied

'$4 Criteria Regarding Test Failures or Severe Anomalies (If Any) Satisfied 7% Criteria Regarding Functional Testing Satisfied M4!

Criteria Regarding Instrument Accuracy Satisfied h

(*7, 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 criteria Regarding Margins Satisfied (NUREG-0588, Cat. I) -

I 9

, t DESIGNATION:

1-X = CATEGORY NRC QUALIFICATION CATEGORY ae

,;. I.a Equipment Qualified Ql%#,. f I.b Equipment Qualification Pending Modification X

,}$ II.a Equipment Qualification Not Established g,6 II.b Equipment Not Qualified rg.2 II.c Equipment Satisfies All Raquirements Except. Qualified Life 9 or Replacement Schedule Justified

.I III.a Equipment Exempt From Qualification III.b Equipment Not 'in the Scope of the Qualification Review g'f fy - IV Documentation Not Made Available 9

M.

k,', '

v:-t

\,K1, \AA. On O^ O -

l 68.

c.,

-?* .

.n ,

.t

'7*

}

h: s b - -- - - -- - - - -

L________ __-________~_~~;* ~~ " -- -

NRC Contract No. NRC-03-79-118 FPC Project No. CS257 Page 00hranidin Research Center A h of The Frankan tammune FRC Assignment No.13 30 20m and Race Seesen. Phas.. Pa.19103 G15) 4481000 FRC Task No. 4-92

. EQUIPMENT ENVIRONMENTAL QUAUFICATION REVIEW OF EQUIPMENT ITEM NO. 6 1

- ,i E ir l

l f . . .

.. . S.; pacTarcAr, czeewerr svar,oATrow

.1 Asseeearntt .,

l '1

- This Limitersee vs.ive eatser & was met tested to the postutsted I temperuzure for the accidmet sovireement, be= owr as shama La Lisdterque l

_'. Repest No. 8 0027. Limit meter boueings have sufficient thermai l W

inertia to eithstand for 20 seceeds fetie-ed Irr a graduai '

c, emet t aa to 250*F after appnzinetely 100 secames and a fierther .

destine to 200 F La soeus I heer witaeur ailowier tse temperature

't of the meter and intetuts*to exceed 230,F. This partioniar type

.'. operater ses tested to 250 F for 22.3 heers. There fers.

./j \'

.. . this operator wi11 famictica pr verly is the

,y postmiated temperature environment to complete its safety Sectise '

. sith the operating time s fin g

v. .

~ j1 *'

Y'f * ---

.

• _ . f e gy, .}.  %

p ', i

• i

i.

.;i .. .

l

~

' .$ /.

q.. .

/

/-

?...v:

~

,/ ,

1 sateer I m est  !

g* * *

,. f..

l

, -- O

.J l

l

., I

,p.

a k

.m

', *g I

(bg)

I h'.1,

'R s ,5

-*e .

%g.

l. l l 5

.c5}

-) .

h 48

-'l

h

, .. . i NRC Contract N o. NRC-03-79-118 t 4Uuuu Frankan Research Center FRC Project No.C5257 Page l 9

A Dmad The Franun insumme FRC Assignment No.13 $f -

2Duh and bce Seeses. Phda-. Pa. 19103 (211) 44s.1000 FRC Task No. 4Y/_ '

{c;3);

EQUIPMENT ENVIRONMENTAL QUAUFICATION REVIEW OF EQUIPMENT ITEM NO. 5  ;

Mg l

.n'a . ,. . ... . 7- ?.

j.j- '

% NOTES: "I" DENOTES APPROPRIATE NOTES F@4k M Ibh N 1. The Licenses han not provided documentation from the

=amifacturer wh:.ch establishes similarity between the j b.' 'pj '

installed equippent and the fest specimen in the referenced l.

fi

.f document (s). LooTE %Cy i

)g gW 2.' The Licensee haa not identified the class of the insulation system used for the motor in the motorized valve actuator.

f. {  ;

f:3F. 3.. The Licenses has not identified whether or not this motorized gh valve actuator incorporates a motor-braka assembly, i i

The Licensee has not identified the class of the insulation Mf3 4.

$N! system used for the motor-braka assembly (if applicable) .

X 5. The Licensee has not identified the motor =amifacturer for ~

h~ 3 this motorized valve actuator.

i

6. The Licensee has not identified the mamifacturer of the motor-braka assenbly (if applicable). l I

y X 7. . The Licensee has not identified the type of current used in l t

g j' the. motorized valve actuator.

8. The Licensee has not identified the type of current used in i

[ the motor-braka assembly (if applicable).

l X 9. The Licensee .has not established a qum14 fied life estimate '

for this motorized valve actuator based on technically -

justifiable methois and conservative assumptions. ( aJ e rs % ,

.e 10. The Licensee has : stated that the only harsh parameter i pM _f that this motoriznd valve actuator is exposed to is radiation.

11. Since radiation is stated to be the only harsh parameter and  :

considering the extensive radiation testing of the motors j I fi- '

used in this type of motorized valve actuator, the specified ,

, :S -

- is , considered to be of l N rmAfmelon dose of sufficiently low value as to noe affact this equipment  ;

! l~.?'

(bMJ ites. This equipment item is considered qualified for this Qw parameter. l iJiG

12. The Licensee has committed to. replace this equipment item. l Tyf The Licenses has stated the following: l

' ~

)

.}

s .

)

l - 'l e

1 I

=

s i

1

t l

\ > .. .

l

.% NRC Contract No. NRC-03-79-118 FRC Project No. C5257 Pago Uuud Franklin Research Center l

A Om ad The Franklin Insmuse FRC Asslgnment No.13 5g l

492 20th and Race Screets. Phde.. Pa. 19103 (215) 448 1000 FRC Task No.

(

EQUlFMENT ENVIRONMENTAL QUAUFICATION REVIEW OF EQUIPME u'

^J 9

d L if NOTES:

...=.-a

<.9 The licensee has submitted two letters from Limitorque to EDS which vere L ",

...< . A.

l.

,i not referenced on the System Component Evaluation Worksheets (SCEWs).

These letters were dated: 12-10-80 (PSR # 21) and 1-7-81 (in PSR # 7) .

- u,

..., . g; similarity

. ; Yid Neither of these letters however establishes the necessary

l. q q

..d.

• for this ecuipment item. In PSR # 7. Attachment #1. the licensee has

..:9J W listed the following documents which were neither submitted or refer-

. .y.h enced on the SCEUs. The one exception to this being Limitorque Test

. =}. ;

'f N Renort B002T.

g:h?ff . a

.ME Limitorque - - '

t'M;:

WGY'. -

Limitorque Test Report B-0027 hj;'.h ,,

EDS Letter to Limitorque, dated 1/26/81 .

rd.f@ "' EDS Istter to Limitoruqe, dated 2/24/81 I.Q5 ~

RDC, Limitorque and-EDS, dated 3/10/81 y[:j{[.ip' "

Limitorque Intter to EDS, dated 3/11/81 _ __

MfIf"

~

Limitorque Letter to EDS, dated 4/1/81 Telex from Limitorque to EDS, dated 5/12/81 7.M ROC, Limitorque and EDS, dated 5/12/81 M.T[

2' ROC, Limitorque and EDS, dated 6/2/81

.'T '

EDS* I4ttar to Limitorque, dated 6/5/81 f(. RDC, Limitorque and EDS, dated 6/10/81 E. S EDS Eatter to Limitorque, dated 6/18/81 L ~.)

n. ,. .

51 Because these documents were not submitted, their applicability or

. .-A i

l W.1 importance to the review cannot be determined.

,.fp A ## d a 9 ]Lf fh> CL_ _

~_ <

' dLIM e - u z - to =M L:sLL,a L Ehe % \

{ $i k as-< ~~t~ ~ E ul Y l 1 l

< a f '$.I

! ', )

.1 i.

A NRC Contr ct No. NHC43-79-118 ,

FRC Project No. C5257 Pcg3  !

00Er.niaina archCanter  !

FRC Assignment No.13 $h i A D M een en he haakhalamanas FRCTask No. 492 j 20m .na hee sessen. Phde.. Pa. 19103 (215) 448-1000 N EQUIPMENT ENVIRONMENTAL QUALIFICATION REVIEW OF EQUIPMEN j

.le

..q f

kDi  ;

=ms , ,

[

l A$ -

B. The licensee has noe ormrid.A anw technical basis to suonort the claim t t

of a 40 year qualified life. If this eauipment item is similar to the l

[

q.,

test specimens in the referenced recort(s). it should be noted that the f i.

h. actual accelerated thermal arine that was perforsed does not simulate Crh

' -l 40 years. Also, from the loe-life data provided in PCR ! 659. it is  ;

M1 '

.e; not clear whether the activation enerry for the constants in the lor-

. . i' life equation) is oniv for the motor insulation (i.e. varnish) or for [

e; i

• ,M h45 the entire motor insulation system (i.e. varnish. motor lead insulation...)  :

7..g

,3 The licensee should investimate this issue with the manufacturer and '

$a'y w

r

address the ther==1 aging of any other organic materials identified. l

~

.' ;j t

.:o 9 .

[*[v '*'

b

_~,.y

< *n .t.

' : .= .  !

[ .+, *.E. h~.. .

. , [b f h .M I l :.%

.m l l ..

' f:y. i lx:$ .:

l p #

r

. ?: %. .

i

.; 1 i,. e .

i

'.:1 Lq 4 l

i ir ,,M  !

.n.

y e . i

, ,f n.y)

,w ...- .

s Jm _ - . . .

i A NRC Contract N':. NRC 03-79-118 FRC Project No.C5257 Page ll0bbranidin Research Center A Dw of The Franhan inearwe FRC Assignment No.13 492 5i

oth .nd Rue Se ets. Phaa.. Pa. 19103 (715) 44810m FRC Task No. ,

.; EQUIPMENT ENVIRONMENTAL QUAUFICATION REVIEW OF dQUIPMENT ITEM N

s.

p..

W . .y, ,

..)[.kr NOTES:

Tif C. The licensee has' cited I,imitorcue recoren R0027 and Ronn, n. evidence of g11 c Similarity has not been established

.$[ gn=14Fication for this equipment item.

. .: .u -

between the installed equienent and the test specimens in either report.

.P bR.; <

t. ,,y j .ti Several. points should also be noted about the licensee's cualification

'y

','.i

'ip .; package for this equipment item:

yfy-

~

'. .j-- 1. B0027 tested a class RH insulated MVA and the licensee has a class B

>LA insulated MVA installed. Because of this , B0027 cannot be used .co

.:.; c w .g demonstrate the function =1 capability of the installed equipment to , ,

h ~-

{; -- v1that=ad a temperature transient to the levels stipulated ini _

d.n .

'X .l'.* the report.

• 2 - 2. The heat transfer analysis presented in B0027 could be applicable, ,

M; ~-

- however, B0027 tested a model SMB-00 which is of a different size

..- c.

and mass than the installed equipment. The licensee has not provided

~

[jk .c:

.Y t c'*

4 an =*=17 sis of these differences.

%.w.1-

n. ., . .g.

3. The licensee claim = that the MVA temperactire will not exceed 250F, ~

fe'!{ }

i the qn=14 fication level established in B0003. The licensee has not

. ff.!,'l

• "[ provided an adequate technical rationale to support the statement a made on page 3a. The data presented in B0027 was for a specific W.' ; .

size and mass MVA exposed to a specific temperature transient, all of

~

Q$ NL*

• h,$.fi- which are different from the licensee's parameters. For the licensee

.:;n f aq to draw conclusions with no additional analysis is not valid. Other

" . 'Q  :. .4 M hese transfer analysis have been performed on this size MVA which show that an exposure to 350F for 60 sec. and 300F for 180 sec. results 4,;;.l ,

in a 14=f t switch surface temperature of 291F. This heat transfer hikf:G

( . .,,;

analysis more closely s1=ulates the licensee's postulated accident

FRC Project No. C5257 PdQ"

. ~h$

l Fr:nklin Research Center

=1 A om ad Th u tasenwe FRC Assignment No.13 5)

FRCTask No. 492 i men and Race Seeses. Phda Pa.191M m2 4410m lGp' EQUIPMENT ENVIRONMENTAL QUALIFICATION REVIEW OF EQUIPMENT IT f'd 3

pjef

.aa

((h;. WNr transient and indicates that the MVA eenm.vmene. would rise above the level M5 reported in 50003, which it should be noted again b'as not been determined to e,

Efi be appicable to this equipment item because of similarity.

5$'

l#.n b.r

.a .1 f,h Iin',l -

h4h ik .

k k ..

h.h, d47 7 .'.

.[

g

.X -

C .

W' '- l im

~ ,

>$n #

4:,

,c..-,

h e

e

.,(

• f

..u

.N

.a

-J' ,

4 1

)

q 4 A

..y

~ ii:t

..o

'P.

Fi 19

..q

e

1. O. Q DOCKETED L INE UNITED STATES OF AMERICA '84 liAY -9 P4 :52 NUCLEAR REGUIWIORY COMMISSION LF Fu Of stu t a.

00CMElv4G & SUvu!

SRANCH CERTIFICATE OF SERVICE I hereby certify that copies of " Supplement to Union of Concerned Scientists' Petition for Show Cause Concerning T4I-l Ehergency Feedwater System" have been served on the following persons by hand delivery to 1717 11 Street, N.W., Washington, D.C., or where indicated by an asterisk, by deposit in the United States mail, first class postage prepaid, this 9th day of May 1984.

Nunzio Palladino, Chairman Ibcketing and Service Section U. S. Nuclear Regulatory Commission Office of the Secretary Washington, D.C. 20555 U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Victor Gilinsky, Comissioner U. S. Nuclear Regulatory Commission flerzel Plaine, Esq.

Washington, D.C. 20555 General Counsel U. S. Nuclear Regulatory Commission James Asselstine, Commissioner Washington, D.C. 20555 U. S. Nuclear Regulatory Commission Washington, D.C. 20555

• Mr. Elenty D. Ilukill Director of 'E4I-l Frederick Bernthal, Commissioner GPU Nuclear Corporation U. S. Nuclear Regulatory Commission P. O. Box 480 .

Washington, D.C. 20555 Middletown, PA 17057 W omas Roberts, Commissioner * 'Ihomas A. Daxter, Esq.

U. S. Nuclear Regulatory Commission Shaw, Pittman, Potts & Trowbridge Washington, D.C. 20555 1800 M Street, N.W.

Washington, D.C. 20036 .

, c .

.