ML20087D309
| ML20087D309 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 02/29/1984 |
| From: | Rybak B COMMONWEALTH EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 8121N, IEB-79-01, IEB-79-1, NUDOCS 8403130353 | |
| Download: ML20087D309 (40) | |
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[ 'C Com'monwrith Edison
) One First National Plaza. Chicago. Ilhnois f
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f Chicago. Illinois 60690 i
s February 29, 1984 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
Quad Cities Station Units 1 and 2 Resolution of Safety Evaluation Report for Environmental Qualification of Safety-Related Electric Equipment NRC Docket Nos. 50-254 and 50-265 References (a):
B. Rybak letter to H. R. Denton dated April 4, 1983.
(b):
B. Rybal letter to H. R. Denton dated May 19, 1983.
Dear Mr. Denton:
The Safety Evaluation Report (SER) for Quad Cities Units 1 and-2 was issued on January 18, 1983.
This SER endorsed and enclosed the Technical Evaluation Report (TER) written by Franklin Research Center.
This TER identified generic and specific = deficiencies in qualificatico documentation for Quad Cities.
Reference (a) provided the 90-day asponse as requested in the SER transmittal letter.
Reference (b) provided a complete revision to the IE Bulletin 79-01B response as well as the submittals required by 10 CFR 50.49(g) and a description:of methodology used for compliance with 10 CFR 50.49(b)(2).
A meeting was held with members of your staff on January 25 and l
26, 1984 to discuss Commonwealth Edison's resolution for all deficiencies noted in the SERs and TERs for the Zion, Dresden and Quad Cities Stotions.
Quad Cities specific deficiencies and resolutions were discussed on January 26.
Commonwealth Edison also discussed the general methodology for compliance with 10 CFR 50.49, " Equipment Qualification of Electric Equipment Important to Safety for. Nuclear Power Plants", which became effective February 22, 1983.
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H. R. Dentan February 29, 1984 This letter and its enclosure document the present resolution of all SER open items and the deficiencies noted in the associated with TER as discussed with your staff.
As requested by the NRC staff in the meeting, compliance with 10 CFR 50.49 and confirmation that.all design basis events at Quad Cities Units 1 and 2, including flooding outside drywell, are addressed in Section I of the enclosure.
As discussed with your staff, equipment installed as a result of TMI Lessons Learned implementation (NUREG-0737), have been removed from the environmental qualification program pending completion of the control room design review, Regulatory Guide 1.97, Rev. 2 implementation, and final NUREG-0737 implementation.
Inclusion of the following equipment will be reevaluated in accordance with their respective schedules:
Acoustic monitors Containment water level indication Containment pressure indication i
Suppression pool radiation monitors Containment hydrogen analyzers No items in NRC Categories I.8, II.A, or II.B for which justification for continued operation had not been previously submitted have been identified.
References (a) and (b) provided revised and upgraded justifications for continued operation (JCO) for all items which qualification documentation had not been established at the~ time References (a) and (b) were submitted.
We believe the environmental qualification documentation maintained in the CECO Equipment Qualification files, which is summarized in Section IV of the enclosure, complies with the requirements of 10 CFR 50.49.
These files are available for NRC audit.
We also believe that Quad Cities Units 1 and 2 can continue to operate without undue risk to the-ptblic health and safety based on the present status of the-qualificaton program and. justification for continued operation as provided in References (a) and (b).
It is therefore requested that a final Safety Evaluation Report be issued to indicate that Commonwealth Edison's-Quad Cities Environmental Qualification Program, as described in this letter and enclosure meets the requirements of 10 CFR 50.49 and that the: deficiencies noted in the SER dated January-18, 1983 are considered: resolved..
To the best'of-my knowledge and belief the statements contained herein and in the enclosure are true and. correct. 'In some respects these statements are not based on my personal knowladge but upon information furnished by other Commonwealth Edison and contractor employees or consul-tants.
Such information has been reviewed in accordance with Company practice and I believe:it to be reliable.
c' H. R. Denton Fet'ruary 29, 1984 If there are any questions you may have regarding this matter, please address them to this office.
One signed original and forty (40) copies of this letter is provided for your use.
We have enclosed ten (10) copies of the enclosure to this letter.
Very truly yours, h.*4t/b B. d'ybak Nuclear Licensing Administrator 1m cc:
NRC Resident Inspector - Quad Cities R. Bevan - NRR t
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ENCLOSURE
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COMMONWEALTH EDISON RESOLUTION OF ENVIRONMENTAL QUALIFICATION SER AND TER OPEN ITEM DEFICIENCIES FOR QUAD CITIES 1 AND 2 I.
GENERIC ISSUES A.
Compliance with 10CFR50.49(b) 3.
One Hour Mit.fmum Operating Time Margin C.
Containment Transient Margins D.
Aging and Qualified Life E.
Maintenance and Surveillance F.
Installed TMI Action Plan Items G.
Correspondence II.
POSITIONS CONSIDERED CLOSED A.
Equipment Placed in NRC Category IIIa by the TER B.
Equipment Placed in NRC Category IIIb by the TER C.
Summary of Qualification Methods III. GENERIC DEFICIENCIES NOTED IN SER/TER A.
Definitive Schedule for Corrective Actions B.
Aging and Qualified Life C.
Safety-Related Display Instrumentation D.
Equipment Deleted from Scope E.
Temperature Switches and Solenoid Valves F.
Containment Transient Margins IV.
SPECIFIC EQ DEFICIENCIEC NOTED IN TER/SER A.
Cable B.
Dif ferential Pressure Indicating Switch C.
Differential Pressure Transmitter D.
Distribution Panel, 125 V de E.
Electric Air Heater F.
Electrical Penetrations G.
Flow Switches H.
Flow Transmitters I.
Hydrogen Sensors J.
Level Indicating Transmitter Switches K.
Level Switches L.
Level Tran.mitters M.
Local Control Panels N.
Local Panels 0.
Monitors, Acoustic P.
Motor Control Centers, 480 V Q.
Motor -Driven Pumps R.
Motor Exhaust Fans S.
Motor Operators T.
Position Switches U.
Pressure Switches V.
Pressure Transmitters W.
Radiation Detectors X.
Room Coolers (Fan Motors)
Y.
Switchgear,.4.16 kV AA. Temperature Elements BB. Temperature Switches CC. Terminal Blocks DD. Oils and Greases j
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I.
GENERIC ENVIRONMENTAL QUALIFICATION ISSUES A.
Compliance With 10CFR50.49(b)
Paragraph (a) of 10CFR50.49(b) requires that each licensee establish a program to environmentally qualify electrical equipment.
10CFR50.49(b) groups this equipment into the following three categories:
- 1) Safety related electrical equipment as defined in IEEE Std. 323-1974 and 10CFR50.49(b)
- 2) Nonsafety-related electrical equipment whose failure under postulated environmental conditions could prevent satisfactory accomplishment of safety functions of the safety-related equipment
- 3) Certain post-accidant monitoring equipment The following discussions present the methodology used to identify all electrical equipment falling within the above three categories:
10CFR50.49(b)(1) Safety-Related Electrical Equipment All design basis events such as loss of coolant accident and main steam line breaks inside containment and high energy line breaks outside containment were reviewed.
A list of systems required to mitigate the consequences of loss of coolant accidents, main steam line break and a high energy line breaks analyses, technical specifications, and emergency operating procedures, considering the functions that must be performed for a potentially harsh environment.
The six functions considered were:
(1) emergency reactor shutdown, (2) containment isolation, (3) reactor core cooling, (4) containment heat removal, (5) core residual heat removal, and (6) prevention of a significant release of radioactive material to the surrounding environment.
Not all equipment in a particular safety-related system requires environmental qualification and post-accident active or passive functional capability in order to accomplish accident mitigation.
Depending on system design, certain motor-operated valves, solenoid-operated pneumatic valves, temperature switches, limit switches and instrumentation may not be required to perform a safety function or mitigate the consequences of an accident in order for the system to accomplish its design basis safety function.
Several other systems only require that the containment isolation portion of the system remain functional.
A system analysis was performed to identify the set of electrical equipment which the system requires in order to perform its design basis safety function. Addition or deletion of equipment from the master list of electrical equipment was performed as necessary.
Plant emergency operating procedures were used as a guide to identify i
devices and display instruments required to be used by the operator.
l This equipment was also added to the master list of electrical l
equipment.
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The squipment which cust remain functional in chara cyctens was identified by review of system description. and appropriate drawings (piping and instrumentation drawings, schematics, electrical one line diagrams and control logic diagrams). Application of system / component failure analyses was performed to identify the electrical equipment which requires environmental qualification.
Plant arcas with environmental parameters (pressure, temperature, humidity, radiation level, submergence level, etc.) which increase significantly above normal ambient conditions as a result of a design basis event, were defined to be harsh post-accident areas.
Containment spray and radiation dose from recirculating radioactive fluids were included in these considerations.
A review of the location of the equipment was performed. Equipment items which were required to function but are not located within a harsh environment, were deleted from the list.
In addition, certain equipment items are not exposed to a harsh environment at the same time that they are required to perform a safety-related function.
These items were deleted from the list.
Station operators who were also part of the team of personnel conducting these activities were consulted to review the completeness of the master equipment list and the list of safety related systems.
In addition to electrical scimmatics, wiring diagrams were reviewed as necessary to identify connection types, terminal blocks, etc., which support e?.ectrical component function.
Based on the results of the above tasks, a final safety-related systems list and a final master equipment list (including display instruments) of electrical equipment which requires environmental qualification were developed. This list has been revised and updated on a continuing basis to reflect plant design changes and new information. System Component Work Sheets (SCEWS), in accordancs with NRC I.E. Bulletin 79-01B format, were also completed.
The methodology used by the licensee *: identify electrical equipment which requires environmental qualification is in full compliance with the requirements of NRC I E Bulletin 70-OlB supplements 1 and 2 and 10CFR50.49. Therefore, the master list of electrical equipment is judged by the licensee to address all electrical equipment within the scope of 10CFR50.49(b)(1).
10CFR50.49(b)(2) Nonsafety-Related Equipment 10CFR50.49 includes in its scope nonsafety-related electrical equipment whose failure under postulated environmental conditions could prevent satisfactory accomplishsent of safety functions of th safety-related equipment. The possibility of failure of nonsafety-related equipment in a manner detrimental to safety equipment has been evaluated by a combination of methods which are sumaarized below:
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A mactor lict cf olectricci cquipment requiring snviranaental qualification was developed in accordances with 10CFR50.49(b)(1) and the requirements of NRC I.E.Bulletin 79-018. This equipment is required to j
provide safe shutdown ano to mitigate the consequences of design basis accidents such as a loss of coolant accident or azin steam line break inside containment and high energy line break outside esontainment. The licensee's generic position (described previously) with respect to compliance with 10CFR50.49(b)(1) describes the methodology used to identify the equipment.
Not all the equipment in a particular safety-related system requires qualification and post-accident active or passive functional cpability in order to accomplish accident uitigation and safe shutdown. A ;ystem t
j failure analysis was performed on each safety-related system to identify I
the set of equipment requiring environsental qualification. The system failure analysis included a review of the safety system operation, systems interaction and included a review of the safety system operation, system inters.ction and operation of equipment with each safety systee. This failure analysis identified all auxiliary systems and equipment which were necessary for the required operatiaa of the safety-related system or equipment. This effort included review of the plant safety analyses, technical specifiestion, emergency operating procedures, piping and instrumentation diagrams, schematics, wiring diagrams, electrical one line diagrams and control logic diagrass. The entire instrument loop l
associated with each identified instrument was reviewed to identify any other components whose function could adversely af fect operation of the equipment required to remain functional. A small number of equipment items were identified as potentially af fecting the performance of the equipment required to remain functional. These items were added to the equipment qualification master list and were subsequently qualified under i
the equipment qualification program, therefore eliminating the potential for af fecting or degrading system perforat: ace.
Based on the above considerations, the licensee has not specifically classified any electrical equipment as nonsafety-related whose failure under postulated environmental conditions could prevent accomplishment of required safety functions by the safety-related equipment. Therefore, the current master list of electrical equipment and the review methodology is judged by the licensee to adequately address electrical equipment within the scope of 10CFR50.49(b)(2).
10CFR50.49(b)(3) Certain Post-Accident Monitoring Equi ent l
Paragraph (b) (3) of 10CFR50.49 includes in its scope "certatu post-accident monitoring equiprent." Specift:: guidance parameters to be monitored is l
provided in Regulatory Guide 1.97 Revision 2.
The licensee's generic position l
with respect to this issue and the methodology that was used to-identify l
equipment that falls within this category is presented below.
PREUENMV I-3
i Dicpicy instrumentctica 10 currantly includ:d co on integral part cf th2 qualification program in accordance with requirements established by NRC IE Bulletin 79-015. The identified display instrumentation was evaluated in the NRC SER/TER review, and System Component Evaluation Work Sheets (SCEWS) for this equipment have been developed. The detailed systems review and development of the master list of electrical equipment requiring environmental l
qualification provided justification of equipment additions or deletions from the master list as necessary on a case by case basis.
The licensee's methodology used to identify display instrumentation has been s
I previously described in Section 10CFR50.49(b) (1) (above). Equipment that currently falls within the category classified as certain post-accident i
i monitoring equipment was selected based on the following:
Sensors for display instrumentation channels which are exposed to a harsh environment following a design basis accident. These are identified in the plant Emergency Operating Procedures and are used by the operator to diagnose system failure to perform safety functions. This equipment is i
incorporated into the qualification program in accordance with the requirements of NRC IE Bulletin 79-015 and the DOR guidelines (enclosure 4).
Instrumentation previously identified by the NRC based on plant walkdowns conducted under the Systematic Evaluation Program (SEP Topic 111-12).
l At this time, the following activities have not been completed by the licensee: The detailed Control Room Design Review; the revision to the Plant Emergency Operating Procedures based on the results of the control room design L
review and the Regulatory Guide 1.97 revision 2 review; the response to NRC concerning compliance with Revision 2 of Regulatory Guide 1.97, l
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" Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident"; and a determination of certain installed and operating electrical equipment located in harsh environments required for TMI Lessons Learned Implementation (NURGE-0737) in acuordance with NRC IE Bulletin 79-015 supplement 3 item 2.
As these activities are completed, equipment considered by the licensee to be classified as Regulatory Guide 1.97 revision 2 Category 1 or Category 2 items will be fully qualified in accordance with 10CFR50.49 criteria before operation in the plant.
l Based on the above considerations, the licensee judges that all electrical equipment within the scope of 10CFR50.49(b)(3) has been adequately addressed and incorporated into the licensee's equipment environmental qualification i
program.
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B.
Ono Hour Minigua Optrating Tina Margin In order to account for various uncertainties inherent in equipment qualification test programs, the NRC criteria for qualification incorporated a one-hour minimum time margin requirement in addition to the required operability time of equipment. The "one-hour minimum margin plus required operating time" requirement was established by the DOR Guidelines section 5.3.1, IE Bulletin 79-01B Supplement 2 Question / Answer No.12, and NUREG-0588 section 3.(4).
Even though some equipment was requ' ired by design to perform its safety function within a short time period after the onset of an accident, the NRC criteria required that this equipment remain functional in the accident environment for a period of at least one hour in excess of the design operating time for the equipment. The NRC SER/TER used this criteria in the review of the licensee's equipment qualification documentation.
j Subsequently, the NRC issued Generic Letter 82-09 which stated that equipment may be qualified using the required operating time plus an cppropriate m3rgin, however, subsequent failures cust be shown not to be detrimental to plant safety. This criteria is_ applicable to equipment subject to the requirements of the DOR Guidelines or Category II of NUREG-0588.
In addition, the one-hour time margin is not applicable to equipment whose safety function is performed l
prior to significant changes in the environment. Regulatory Guide 1.89 revision 1 position C-6 further discusses this issue. The outline presented in position C-6 of R.G.1.89 states that equipment which is required by design to perform its safety function within the first 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of the event should remain functional in the accident environment for a period of at least one i
hour in excess of the required equipment operating time unless a time margin 1
of less than one hour can be justified. This justification must include:
consideration of a spectrum of line breaks; potential need for use of the equipment later in the eveut; determination that failure of the equipment after the required operating time interval 7111 not degrade safety function or mi= lead the operator; and determination that margin applied will account for uncertainties in the qualification program.
10CFR50.49(e) (8) also requires use of appropriate margins.
CECO's position with respect to the issue of one-hour minimum operating time margin is in accordance with the criteria presented in Generic Letter 82-09, 10CFR50.49(e) (8), and Regulatory Guide 1.89 revision 1 position C-6.
Test data and analysis used to demonstrate qualification of equipment ' envelop the required design operating time plus one-hour margin or an appropriate margin properly justified in accordance with NRC criteria. This issue is therefore considered resolved.
PRELIMINARY E
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Contcinment Trensient Margina 3
a2 For Dresden and Quad Cities Stations, General Electric performed a drywell temperature analysis based on a main steam line break.
The analysis considers aain steen line break inside the drywell with treak areas of 0.01 and 0.75 ft2 the peak temperature was ca*calated to be 334F for 600 seconds. This G.E. drywell temperature analysis profile is used in the qualification of all equipment being tested for use inside the drywell. The analysis performed for CECO (GE Report NSEO-52-0682) is based op a main steam line break with adequate margins. The margins include conservative decay heat values, heat transfer coefficents, valve closure times and flowrates. The analysis will, therefore, supercede Appendix A, Figure A-2V and A-3 of the TER. This report was transmitted to the NRC by letter, Mr. T. Rausch to Mr. H.R. Denton, dated January 25, 1983.
I D.
Aging and Qualified Life The NRC DOR guidelines, Section 5.4(4) and 7.0, require that the licensee conduct an assessment of electrical equipment to identify materials susceptible to significant age Telated degradation which could affect I
performance of design safety functions. A qualified (designated) life should be established for equipment susceptible to signiilcant aging based on engineering evaluations and judgment. Maintenance, surveillance and equipment or component replacement intervals should be taped on the established qualified life co that equipment qualification is maintained on a continuing basis. Specifically, the DOR guidelines require: identification of materials susceptible to significant degradation due to thermal and radiation aging, 2stablishment of ongoing programs to reviet' survie11ance and maintenance activities to identify equipment exhibiting age related degradation.
Arrhenius techniques are generally considered acceptable for assessment of thermal aging. These requirements are also implicitly established by 10CFR50.49 Section e(5), NUREG-0588, Rev.1, Section 4 and Regulatory Guide 1.89, Rev.1, Section 7; however, for new equipment (replacement equipment),
these standards are more rigorous in that the criteria uf IEEE-323 (1974) must be applied and the equipment must be preconditioned prior to testing. Methods for compliance with established crite ria are presented below.
l For installed equipment, the licensee has identified electrical equipment whose materials are susceptible to significant age related degradation. A qualified (designated) life has been established for each equipment type with requisite replacement or component refurbishment schedules. Various methods were employed in establishing the qualified life for equipment such as: use of available qualification test data on similar or actual components or equipment to support a conservative equivalent life extrapolation of the enveloping temperature test profile using Arrhenius techniques; contact with vendors to obtain hills of material, material information, and technical data to identify age sensitive materials; review and engineering evaluation of industry references and technical literature to determine materiai' radiation threshold end thermal withstand capabiliti?a; and engineering analyses to establish a reasonable qualified life and justified replacement schedule.
Calculations, assumptions, technical data and references were incorporated into the respective equipment qualification documentation. The results of these evaluation and analyses are incorporated into the existing plant maintenance and surveillance program to ensure that equipment qualifiction is maintained. Based on these considerations, the licensee fully complies with the aging and qualified life criteria presented in the DOR guidelines.
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PPAIM NARY When currently instellsd equipment (qualifisd to th2 DOR guidalinto) 10 replaced, the new equipment will be qualified in accordance with the aging and qualified life criteria presented in ICCFR50.49, Section e(5), NUREG-0588, Revision 1, Section 4 and Regulatory Guide 1.89, Revision 1, Section 7, unless there are sound reasons to the contrary to preclude upgrading. For this 1
equipment, the qualification test plans and test reports are evaluated to ensure that equipment is properly preconditioned (naturally or artificially) prior to testing and a reasonable qualified (designated) life and component replacement interval is established. The results of the equipment qualification progres are incorporated into the existing plant maintenance and surveillance program to ensure tLs; equipment qualification is maintained.
With respect to synergistic effects, the licensee recognizes the limitations in the state-of-the-art; therefore, synergisms were not addressed unless know synergisms were identified and were considered to have significant effect on equipment's safety function. Based on these considerations, the licensee fully complies with the synergistic effects criteria presented in 10CFR50.49 Section e(7), NUREG-0588, Revision 1, Section 4(3) and Regulatory Guide 1.89, Revision 1, Section 7.
Finally, the station maintenance history file will be used in conjunction with the established maintenance and surveillance program to identify significant age related degradation trends, characteristics and observations f or equipment. Appropriate corrective actions will be taken on a case-by-case basis.
Based on these considerations, the license fully complies with the aging and qualified life criteria presented in 10CFR50.49, NUREG-0588, Category 1 and Regulatory Guide 1.89.
E.
Maintenance and Surveillance The DOR guidelines and 10CFR50.49 require that on-going programs be implemented to establish and perform maintenance, surveillance, and equipment (or comporent) replacement activities for safety-related electrical equipment to ensure that equipment qualification is maintained on a continuing basis.
The program must it':orporate the established values of designated life for equipment considered to be susceptible to significant aging. The licensee's methodology, with respect to compliance with NRC criteria, is summarized below.
To assure the continued qualification of installed equipment, CECO has initiated a Qualification Maintenance Program. This program takes specific environmental qualification related surveJ11ance and maintenance requirements and integrates them into existing surveillance, maintenance and testing '
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It was decided to take this approach, rather than to establish an
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independent program to take full advantage of these existing programs and the l
people that make them work.
I For each type of environasntally qualified equipment, a loose-leaf binder is being prepared whit.h contains all of the qualification documentation and specific EQ related surveillance and maintenance. Enginecting and station personnel vill review these binders and incorporate any qualification requirements into station surveillance and maintenance procedures or develop new procedures where this equipment had not previously been installed at that station.. Any EQ related surveillance and maintenance requirements will then be programmed into our newly developed General Surveillance Program which is computer based and which inititates needed activities and automatically I-7
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PREiEINARY estchliches tha date of the esxt curveillence end maintenance cctivity ones the work is completed. The Work Request form presently used for all surveillance and maintenance work has been modified to alert station personnel that they ar working on an EQ piece of equipment. When EQ related surveillance and maintenance work is completed, this information will be entered into our computerized Maintenance History File. This file will have a record of work done and the potential for trending age related degradation.
The Qualification Maintenance Program is flexible and can readily accomodate future requirements mandated by I&E Circulars, Notices and Bulletins or by manufacturer's recommendation.
1 To support the basic Qualification Maintenance Program, CECO is presently developing a training program for periodic presentation to our engineering and station personnel to educate them in all aspects of qualficiation. The Station Storekeeper and our Purchasing personnel are also being involved in this program to assure an adequate supply of replacement parts.
Through the use of our recently modified Work Request form, we are establishing a mechanism to upgrade qualification whenever equipment replacements are required. The company is developing its Qualification Maintenance Program based on two policies. When replacement parts are i
required, like-for-like parts are used; when exact parts are not available, the recommended replacement is soubjected to a review by station engineering, operating and maintenance personnel. When a component qualified to the DOR Cuidelines or to CAT. II must be replaced it will be replaced with a component qualified to NUREG-0588 Revision 1 Category I except where sound reasons to the contrary preclude this upgrading.
An example of the present program for large motors which includes a periodic lubrication program based on manuf acturer's recommendations and our operating experience; chemical analysis of the lubricants may be performed. Bearings are inspected at each motor overhaul. Also, during these overhauls the windings are inspected and cleaned and any suspect windings are zeggered and hipotted. A vibration signature is taken of all large motors and vibration analysis performed periodically so as to detect early signs of age related degradation. On a daily basis all large motors are visually inspected by i
1 operating personnel. To these ongoing surveillance and maintenance j
activities, any EQ related requirements such as the use of radiation resistant lubricants will be integrated into the present program. Results of completed surveillance and maintenance work will be entered into the Maintenar,ce History File which has trending capabilities.
Another example of the present surveillance and maintenance program for transmitters includes a periodic calibration check based on manufacturer's i
recommendaticas and our operating experietice. At the time of each check as-foun:! and as-lef t data is recorded sud transmitters beyond prescribed limits are recalibrated. Transmitters requiring frequent recalibration beyond i
prescribed limits are replaced. Durii.g calibration checks each unit is l
subjected to a thorough visual inspection. To these ongoing surveillance and maintenance activities any EQ related requirements, such as 0-ring replacement each time the cover is removed, will be factored into the present program. -
As-found data will be entered into the Maintenance History File which has trending capabilities.
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In summary, the company has initiated a comprehensive Qualification Maintenance Program which is being integrated into our present maintencnce, surveillance and testing program. To support this program we are taking steps to assure adequate supply of replacement parts and components. The l
computerized General Surveillance Program provides an audible link of work performed and the Maintenance History File provides the potential to detect age related degradation.
Based on the above considerations, the licensee concludes that the activities i
conducted thus far on environmental qualification, and the current development of a maintenance and surveillance program for electrical equipment requiring l
environmental qualificaton fully complies with the requirements of the DOR guidelines and 10CFR50.49 regarding maintenance and surveillance.
F.
Installed TMI Action Plan Items NUREG-0737 " Clarification of TMI Action Plan Requirements" established actions to be taken by licensees regarding TMI Lessons Learned Implementation.
NRC IE Bulletin 79-015, Supplement 3 Iten 2, requires environmental qualification of installed electrical equipsett located in harsh environments required for TMI Lessons Learned Implementation. Those items that have control or accident mitigating functions are included in the present environmental qualification program.
The licensee's position with respecst to TMI lessons learned equipment falling within the category of "certain post accident actitoring equipment" has been previously presented in generic position A above.
Based on these considerations, the licensee judges that installed TMI action plan items have been properly incorporated into the qualification program in accordance with NRC IE Bulletin 79-01B, Supplement 3 and 10CFR50.49 l
qualification requirements.
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Correspondence 1.
Correspondence to NRC D. Peoples to J. Keppler - D, QC, QC2 Master Lists 03/04/80 3
1 F. Janacek to J. Keppler - QC, QC2 initial response 04/22/80 1
IE Bulletin 79-01B Response D, D, QC, QC2 06/10/80 2
3 1
Revised IE Bulletin 79-01B response D2 08/22/80 l
J. Abel to J. Keppler - D, QC, QC2 revised 3
1 response (11/1/80) 10/29/80 J. Abel to D. Eisenhut - D2 revised response (11/1/80) 10/30/80 T. Rausch to H.Denton TER Response D, D, QC, QC2 09/04/81 2
3 1
1 02/03/82 TER Response Supplement QC, QC2 TER Response Supplement D3 02/23/82 D, QC, QC2 - TMI Equipment 04/29/82 TER Response Supplement D e 2
3 1
4
)
E. Schwartz to D. Eisenhut - TMI Action Plan Equipse.at Qualification 08/02/82 i
T. Rausch to H. Denton - GE Drywell Analysis 01/25/83 T. Rausch to H. Denton - Reaffirmance of JCOs 02/01/83 B. Ryback to H.Denton - Proprietory Material 02/14/83 B. Ryback to H. Denton TER Response D, D, QC, QC2 04/04/83 2
3 1
B. Ryback to H. Denton - 10CFR50.49 05/19/83 Response D, D, QC, QC2 2
3 1
C. Reed to H. Denton - R.C.1.97 and G.L. 82-33 11/15/83 Commitments 2.
Correspondence from NRC IE Bulletin 79-01 02/08/79 I
IE Bulletin 79-01A 06/06/79 J. Keppler to C. Reed IE Bulletin 79-015 01/16/80 NRC Request to D2 02/15/80 IE Bulletin 79-01B Supplement 02/29/80 D. Ziemann to D. Peoples - Schedule and Clarifications 03/28/80 CLI 80-21 05/23/80 Staff Orders D, D, QC1 QCg 08/29/80 2
3 IE Bulletin 79-01B Supplement No. 2 09/29/80 IE Bulletin 79-01B Supplement No. 3 10/24/80 Staff Order 10/24/80 C. Lainas to J. Abel - Partial NRC Review Dresden 2 02/13/81 T. Novak to J. ASel - Partial NRC Review Dresden 3 04/01/81 T. Ippolito to J. Abel - NRC SER-QC, QC2 06/03/81 1
T. Ippolito to J. Abel - NRC SER-D3 06/03/81 D. Crutchfield to J. Abel - NRC SER _- D2 06/10/81~
GL-82-09 04/20/82 Memorandum to D.Eisenhut from P.0'Connor - JC0 Evaluation 10/19/82 D. Crutchfield to L. De1 George NRC SER-D, D3 12/29/82 2
)
D. Vassallo to L. De1 George - NRC SER-QC, QC2 01/18/83 1
l l
L I-10
l II.
POSITIONS CONSIDERED CLOSED A.
EQUIPMENT PLACED IN NRC CATEGORY IIIA BY THE TER - None B.
EQUIPMENT PLACED IN NRE CATEGORY IIIB BY THE TER - (equipment not in the scope of review)
Quad Cities 1:
FRC Item 12 - PS-1-1462A, B, C, D FRC Item 62 - FT-1/2-7541-6A, B Quad Cities 2:
FRC Item 12 - PS-2-1462A, B, C, D C.
SUMMARY
OF QUALIFICATION METHODS The qualification methods discussed in paragraphs 4.3.5 and 4.3.6 of the Franklin Research Center's Technical Evaluation Report for Dresden Units 2 and 3, respectively, are revised as follows:
A number of components were included in the original IE Bulletin 79-OlB response which could be subjected to maximum temperatures between 104 and 120F for reasons other than direct exposure to a loss-of-coolant accident (LOCA) or high-energy line break (RELB) environment.
It was initially thought that this environment should be classified as more severe than nonharsh (benign) conditions and an additional category called a mild environment was created in the IE Bulletin 79-OlB response for this equi pment. A subsequent examination of plant operating experience, vendos information, industry standards, regulatory criteria, and potential failure mechanisms for equfyaent in this mild category has led Commonwealth Edison Company (CECO) to the conclusion that this additional category is not required. The justification for this revision is presented below.
CECO's position with respect to areas where the temperature does not exceed 120F is that these are mild temperature areas and as such do not expose equipment to immediate, prolonged, or significant high-stress conditions. The maximum temperature of equipment represents no significant change from the normal temperature for equipment located in these areas. For all equipment located in these areas, the mild temperature environment is the result of normal plant operation, the loss of the heating, ventilatfng, and air conditioning (HVAC) system, or operation of equipment required for post-accident plant recovery.
It is not the result of direct l
exposure to LOCA or HELB environment.
In all cases the increase in temperature from the normal temperature to the maximum of 120F will be gradual. The resulting applied stresses on the equipment are relatively low an3 well within the maximum stress level capability l
of the equipment which is conservatively designed, fabricated, and j
installed as supported by equipment design specifications and manufacturers' data.
Operability of similar equipment in such mild l
temperature environments has been demonstrated by many years of experience in the utility industry.
In addition, operating experience (e.g., Licensee Event Reports) does not indicate that a common-mode failure of safety-related equipment resulting from mild temperature environments is a problem. Therefore, no additional evaluations or documentation are necessary to ensure that this equipment will perform its safety function.
II-1
1 This juetification was found ratisftetory by Franklin in tha Janusry 1983 TER for Quad Cities Units 1 and 2, Section 4.3.3.2.
A further discussion concerning the qualification of safety-related electrical equipment located in a mild environment which CECO also endorses car.
be found in Reference 1.
This equipment was reevaluated on a case-by-case basis and reassigned to either the harsh or mild (benign) category as shown in Table 1.
As a further clarification, the terms "nonharsh" and
" mild" are now used synonymously in the report reflecting the current usage of these terms in the nuclear industry.
In support of this position, we note that the latest revision of 10CFR50.49 excludes equipment in a mild environment from the present equipment qualification effort.
The licensee's position on the above qualification methodology is summarized below:
1.
A harsh environment is defined as any one or a combination of any number of the following conditions.
a.
Temperatura above 120 F 4 rads b.
Total radiation exposure above 5 x 10 c.
Pressure transient resulting from a LOCA or HEL3 inside the drywell, the pressure suppression pool, and the main steam tunnel 2.
Qualification of howidity will be required only when the humidity is in conjunction with harsh temperatures.
3.
A mild (nonharsh) environment must meet all of the following criteria.
a.
Temperature equal to or lower than 120F 4 rads b.
Total radiation equal to or below 5 x 10 c.
Pressure no higher than that of all plant locations other than the drywell, the pressure suppression pool, and the main steam tunnel; i.e., less than or equal to atmosphe-ic pressure 4.
CECO's approach to achieve environmental qualification of safety-related electrical equipment is summarized below in Table 1 and the notes which follow.
PREi.iMINARY I
I l
l II-2
l TABLE 1
SUMMARY
OF QUALIFICATION METHODS Tempera ture liation Hild Harsh Mild Note a Note b Harsh Note c Note d Notes:
a.
Equipment located in a mild environment is not included within the scope of the NRC SER in accordance with 10CFR50.49. No action by the licensee is required, b.
Qualification analysis or qualification testing or a combination of both will be performed to ensure that equipment in this category is fully qualified for the harsh temperature environment.
If the component or part of the component is found not to be qualifled, its replacement will be complete by the end of the second refueling outage after March 31, 1982 or by March 31, 1985, whichever is earlier.
c.
The component will be qualified for the harsh radiation environment only by a combination of analysis and testing, quaJification testing, analysis, or by replacement with a fully qualified com pone nt.
The replacement schedule will be as stated in Note b above.
d.
The component will be qualified by testing or be replaced with a qualified component. The replacement schedule will be as stated in Note b above.
5.
Equipment qualification for submergence and/or containment spray, if required, will be handled by analysis or testing as appropriate.
REFERENCES 1.
A Nuclear Industry Position Regarding Environmental Qualification of Safety-Related Electrical Equipment Subjected Only to Mild Environment, submitted to H.R. Denton of the NRC by S.H. Howell of the AIF in a letter dated July 2, 1980.
-II-3~
~
- ~. -
l C00940NNEALTH EDISON RESOLUTION OF ENVIRONMENTAt QUAllFICATION SER AND TER OPEN ITEM DEFICIENCIES FOR QUAD CITIES UNITS I AND 2 j.
'lli. GENIRIC DEFICIENCIES Deficiency Reference Proposed Resolution
' A.
'In many instances, the licensee has connitted TER, Section 5 A definitive schedule for W completion of corrective actions in compliance with ISIC
~
to replace equipment during a refueling outage Paw 5-1 SER requirements has been established. The schedule for cogletion of corrective action
. fallowing receipt of the qualified comp a nts was reflected in Section 1.3 of the individual component summary sheets in Attachment 1 onsite.. It is concluded ht the licensee has to the Dresden and Quad Cities TER responses for components in NRC Categories 1.8,
.not provided a definitive schedule for h II.A. and l1.B.
The schedule was also reflected in h May 19, 1983, transmittal from letion of corrective actions in compliance
- 8. Rybak to H. Denton as required by 10 CFR 50.49.
tsi NRC SER requirements.
1 The licensee has not resolved h NRC concern TER, Section 5 The resolution for this item is provided in Secton i of this enclosure.
l 8
ding aging and quellflod life (Dresden 2 Page 5-1 C.
h licensee has not resolved h NRC concern TER, Section 5 Equipment qualification summary sheets were provided in N Dresden 2 TER response dated l
regarding identification of safety-related Page 5-1 April 4,1983, for N ins 1rruments identified by W FRC item nun 6ers shown below.
display Instrumentation. The licensee will i
. provide component evaluation summary sheets Instrument identificaiton FRC ltem Number
[
for display instruments h t provide infor-motion only to N operators by June 1982.
LT-2-1641-1 70 Justification for exclusion of safety-related LT-2-1626 72 i
' instruments from this list should contain a PT-2-1625 75 L
4 description'of h ability to meet h LT-2-646-A/B 73 L
requirements of Regulatory Guide 1.97, LT-2-263-61 73 i
Revisica 2 (Dresden 2 only).
PT-2-647-A/B 76 PT-2-662 76 6
FCR ltem 69 referred to DPT-2-1602-12. This transmitter is not installed in h plant and has, therefore, been deleted from W scope of h environmental qualification L
program.
I Additional and revised system component evaludion worksheets (SCEWs) were provided in
[
the ravised IE Bulletin 79-018 response submitted May 19, 1983. CECO's position regarding Regulatory Guide 1.97, Revision 2,. compliance schedule was provided in a
[.
letter from C. Reed to H. lienton, dated November !S, 1983.
, 0.'
The liconsee has deleted various. items from-TER, Section 5'a.
Equipment qualification was stated in Attachment I to N Dresden 2 TER response for 4
. h list of equipment items to be qualified.
Page 5-1 the, instruments identified by FRC item number shown below.
- FRC does not agree with h licensee in-thisregard/Dresden2only).
Instrument idenfication FRC liam Number LT-2-1641-1 '
70 LT-2-1626 72 PT-2-1625 75 LT-2-646-A/8 73 LT-2-263-61 73 PT-2-647-A/8 76
],
PT-2-662 76 e
4
Generic Deficiencim (continued)
Deficiency Reference Proposed Resolution D. (continued)
FCR ltem 69 refer red to DPT-2-1602-12. This *.ansmitter is not installed in h plant and has, therefore, been deleted frun the scope of the environmental qualification program.
b.
CECO's response to Regulatory Guide 1.97, Revision 2, is provided in h letter from C. Reed to H. Denton, dated Noved er 15, 1903.
E.
Appendix D of the TER discussed conce ns which TER, Section 5 Appendix D conceins were addressed in W 30-day response letter, Mr. T. Rausch to require resolution with regard to temperature Page 5-2 Mr. H.R. Denton, dated February 1, 1983. In addition, the temperature switch component (witches er1 soienoid valves, sununary sheets were included in Attachment I to the Dresden and Quad Cities TER responses. No deficiencies related to solenoid valves were identified in Appendix 0 to -
the Dresden TER; W refore, no action by Ceco is required for this item. Verbal approval of the February 1, 1983, submittal on justification for continued operation (JCO) was given to R. Rybak from R. Gilbert on February 1, 1984. It is Ccannonwealth Edison's understanding that formal acceptance of this JCO will be given in the safety evaluation report.
F.
It appears that h licensee has not resolved TER, Section 5 The resolution for this item is provided in Section I of this enclosure.
~ h imC concern regarding margins applied to Page 5-1 h in-containwt temperature profile
-(Dresden 2 only) 0493c..
I11-2
CON 40NWEALTH EDISON RESOLUTION OF ENVIRONMENTel QUM.lFICATION SER AND TER OPEN ITEM DEFICIENCIES FOR QUAD CITIES UNITS I AND 2 LEGEND:
QCl = Quad Citics Unit i QC2 = Quad Cities Unit 2 None = No deficiencies noted or SCEL provided subsequent to NRC review by IRC IV. SPECIFIC EQUIPMENT EQ DEFIC g *:lES Description (Manufacturer, NRC FRC liam Number Model. Etc)
Category Deficiencies Proposed Resolution A.
ELECTRICAL CABLE 0C1: 49 General Electric l.B Documented evidence of qualification Testing and analysis had not been performed on this cable at the QC2: None cable Model SI-57275; inadequate time of the TER/SER review; therefore, qualification documenta-Vulkene insulated tion was noted as being inadequate by FRC. Qualification defici-switchboard wire encies for qualification time, material aging, humidity, temperature, pressure, and radiation were originally to be resolved by type testing. However, prior to testing, EDS Nuclear evaluated Wyle Test Report 44114-2 and concluded that the qualification deficiencies for pressuia, radiation, and rela +ive humidity could be resolved by that test report, and the remaining
/ /
y deficiencies could be resolved by an analysis utilizing Arrhenius f
I methodology to extrapolate the test results. All deficient P
parameters were satisfactorily qualified by Wyle Test Report 44114-2 and EDS Analysis, Environmental Qualificatior, of General Electric SI-57275 Electrical Cable Report 04-0590-69, Rev 1,ld be October 7, 1963. Therefore, these quellfled conponents shou in NRC Category 1.A, Equipment Qualified.
QCI: 51,53,55, General Electric and I.B Documented evidence of qualification Testing and analysis had not been performed on ihls cable at the 56 31mplex cable; butyl inadequate time of the TER/aER review; therefore, qualification documenta-QC2: None asbber-Insulated with tion was noted as being inadequate by FRC. Qualification defici-
'VC jacket; power and encies for qualification time, material aging, humidity, tempera-control functions ture, pressure, and radiation are being resolved by type testing. Prior to testing, it was determined that the term "Anhydrex XX" (identified as the insulation material in QCl item 56) was the Simplex name for their butyl rubber insulation.
Because SCEWs existed for Simplex butyl rubber-insulated cable, all references to cables with Anhydrex XX Insulati m have been deleted from the qualification program to eliminate unnecessary duplication. All deficient parameters have been qualified by Wyle Test Plan 45916-03, Final Qualification Plan for Various Power Control and Instrumentation Cables. The test report is to be issued in February 1984.
0494c IV-l
IV. Specific Equipment EQ Deficiencies (continued)
Description (Manufacturer, NRC FRC item Number Model. Etc)
Category Deficiencies Prooosy Resolution A.
Electrical Cable (continued)
QCI: 54 General Electric cable;
!.B Documented evidence of qualification To:, ting and analysis had not been performed on this cable c.t the QC2: None cross-linked poly-Inadequate time of the TER/SER review; therefore, qualification documentation ethylene (Vulkene)-
was noted as being inadequate by FRC. Qualification deficiencies insulated with PVC for qualification time, ceterial aging, humidity, temperature, Jacket; control pressure, and radiatior. were originally to be resolved by type functions testing, engineering analysis, or replacement. Consnonwealth Edison has reviewed a comparison analysis conducted by EDS, A.
Environmental Qualification of General Electric SI-58743 and
'[/
SI-58281 Electrical Cables, Report 04-0590-50, Rev 0, 40 November 18, 1982. Although the analysis states that the cables are qualified, Conononwealth edison las determined that a more detailed analysis to establish similarity to previously tested General Electric specimens will be conducted to fully document qualification. If this analysis cannot dawastrate qualification in CECO's Judgment, the cables will be type tested or replaced.
QCI: 50 Singlex cable; poly-I.B Documented evidence of qualification Testing and analysis had not been performed on this cable at the QC2: None nylon-insulated single /
inadequate time of the TER/SER review; therefore, qualification documentation multipair instrumen-was noted as being inadequate by FRC. Qualification deficiencies tation cable for qualification time, material aging, humidity, temperature, pressure, and radiation are to be resolved by type testing.
Prior to testing, it was determined that the polynylon-insulated cable and the single /multipair instrumentation cable are the same. Therefore, all references to the polynylon-insulated cable have been deleted from the qualification program to eliminate unnecessary dupnication. All deficient parameters have been qualified by Wyle Test Plan 45916-03, Final Qualification Plan for Various Power, Control, and instrumentation Cables. The test report is to be issued in Fe.bruary 1984.
QCI: None Simplex cable; threo-NA None Qualification deficiencies for qualification time, material aging, QC2: None conductor twisted w11h humidity, temperature, pressure, and radiation are to be resolved overall shield; instru-by type testing. All deficient parameters have baen qualified by mentation wire Wyle Test Plan 45916-03, Final Qualification Plan for Various Power, Control, and Instrumentation Cables. The test report is to be issued in February 1984.
B.
DIFFERENTIAL PRESSURE AND INDICATING SWITCHES QCI: 32 Barton 289 1.b Documented evidence of qualification These components were scheduled for replacement; however no QC2: 32 Inadequate qualified replacement was identified at the time of the YER/SER review. Therefore, documented evidence of qualification was indicated as inadequate. They will be replaced by qualified i
Rosemount Model 1153, Series B transmitters. Qualification is required for temperature, pressure, htsnidity, and radiation during post-accident conditions. Roseniount has tested its Model 1853, Series B transmitters and provided the qualification documentation in Test Report 108025, Rev B, dated February 1983.
The report has been reviewed and evaluated and found to qualify the transmitters for the required conditions. The quallfied life of the Nodel 1853, Series B transmitters has been determined by Rosemount to be 20 years; therefore, these components will require replacement af ter this period. These qualified replacement components should be in NRC Category I.A, Equipment Qualified.
0494c IV-2
IV.
Specific Equissnent EQ Deficiencies (continued)
Description (Manufacturer, NRC FRC item Nun 6er Model. Etc)
Ca teqo_ry, Deficiencies Proposed Resolution B.
Differentiat Pressure and Indicatina Switches (continued)
QCI: 35 Barton I.B Documented evidence of qualification These components were scheduled for replacement; ha ever, no QC2: 35 Inadequate qualified replacement was identified at the time os the TER/SER review. Therefore, documented evidence of quellfication was indicated as inadequate. They will be replaced by qualified Rosemount Model 1853, Series B transmitters. Qualification is required for temperature, pressure, humidity, and radiation during post-accident conditions. Rosemount has tested its Model 1853, Series B transmitters and provided the qualification documentation in Test Report 108025, Rev B, dated February 1983.
The report has been reviewed and evaluated and found to qualify the transmitters for the required conditions. The qualified life of the Model 1153, Series B transmitters has been deter nined by Rosemount to be 20 years; therefore, these components will reautre replacement after this period. These quallfled replacement compwts should be in NRC Category 1.A, Equipment yf Qualifled.
C.
DIFFERENTIAL PRESSURE TRANSMITTERS None D.
DISTRIBUTION PANELS QCl: 44 Cutler-Hansner I.B Documented evidence of qualification Qualification defidency was identified as the radiation parameter QC2: 44 Inadequate and was originally to be resolved by analysis end/or testing.
This deficiency was appliceble because these panels had not been quellfled to a harsh radiation environment. Subsequently, the approach adopted for qualification was a combination of analysis and testing. Bechtel performed an engineering analysis (Chron 7352) for nonnntallic components except those associated with the circuit breaker. This analysis indicated that all ttiese nonmetallic components had radiation damage thresholds in excess of the required radiation environment. A radiation test was conducted by Wyle for the breakers, and Wyle Test Report 45917-3 was evaluated. The deficiency is resolved by this analysis and the test report. These items are fully qualified to all environmental parameters. Therefore, these qualified components should be in NRC Category 1.A Equipment Qualified.
E.
ELECTRIC AIR HEATERS QCI: 59 Chromalox 1.B Documented evidence of qualification These heaters are used as consnon equipment for both the Quad 1-113462/2-113462 inadaquate Cities Units I and 2.
This equipment was originally sctwJuled for replacement with a qualified heater because the qualification was not established at the time of TER/SER review. Radiation was the only harsh environment requiring qualification; therefore, all the materials were reevaluated to determine whether qualification could be established by analysis. Subsequently, the unit wat. quellfled by Engineering Analysis for Nonmetallic Components, Hechtel Power Corporation, July 8, 1983 (Reference 3 of Qualification Package 06.C332.01). Therefore, these qualified components should be in NRC Category 1.A, Equipment Qualified.
0494c IV-3
IV.
Specific Eaulunent EQ Deficiencies (continued)
Description (Manufacturer, NRC FRC ltem Number Model. Etc)
Category Defigiencies Proposed Resolution F.
ELECTRICAL PENETRATIONS QCI: 52 General Electric II.A Documented evidence of qualificati--n ln, original documentation submitted during the TER/SER review was GE-NEBS Inadequate incomplete because of the ongoing data search for these penetra-QC2: None NA None tions. Qualification was required for all the occident and norinal er.vironment parameters inside the drywell. Subsequent to the submittal of the TER response, enviroia.iental information study, Report EWA-EAF98--94, was received from General Electric (GE) along with another report dated May 30, 1972, for the electrical penetratic, assemblies sumary data. These repp h, as w911 as GE Report F Cl (April 30, 1971), GE Report 994-79-011 I
'm quell *v these penetrations for the normal and accident (April 29, 1975), and a special report for an incident at Dresden Unit 2 in J7ne 1970, have been reviewed and found to adequately
['f envi r mnent. These electrical penetration assemblies contain metallic es well as nonmetallic materials. Daterioration due to thermal aging is insignificant for nonorganic and metallic materials under the specified envirevnental conditicns.
Therefore, component aging is based on organic materials. GE Report 994-75-011 demonstrates a cycling eM aging test to simulate a nuclear power station startup ared shutdown cycle.
This 100F temperature change and 120 cycle test is c.ansistent with the requirement of IEEE Ste dard 317-1976 even though this standard was not in effect at thy time of the qualification test. Because the penetration assemblies successfully withstood the cycling and aging test, which represents significet thermal stressing, the aging qualification is considered supper table by this test. In addition, the penetration assemblies can be considered to have a remaining qualified life of 30 years. This conclusion is based on the material analysis of the age-sensitive materials used in the F01 canister design electric penetratrons (GE Report EWA-EAF98-94), their location within the assembly (which is not subject to extreme temperature and radiation devadation), and the fact that these assemi,IIes continued to furdion during and subsequent to the June 5,1970, depressurization incident. This 30-year qualified life requires that periodic maintenance and surveillance procedures be established and implemented. Surveillance procedures are being developed to detect comon-mode failure mechanisms. If unidentified aging or degradation mechanisms become apparent, upgraded replacement or maintenence programs will be developsd to address these concerns.
Based on the above reports and the followup meetings with GE and the fact that they did perform satisfactorily during the June 5, 1970, leecident, it is concluded that these penetrations are qualified. Therefore, these qualified components should be in NRC Category 1.A, Equipment Quellfied.
049/;.:
17-4
-~
'lV. - Specific Eeulomont EQ Deficiencim (continued)
Description (Menufacturer, NRC FRC ltem Nuuber Model. Etc)
Category Deficiencies Proposed Resolution G.-
FLOW SWITCHES QCI: il Barton, 289 1.B Documented evidence of qualification These components were scheduled for replacement; however, no
- QC2
- 11 Inadequate qualified replacement was identified at h time of the TER/SER review. Therefore, documented evidence of qualification was indicated as inadequate. They will be replaced by quellflod j-Rosemount Model 1853, Series B transmitters. Qualification is required for post-accident radiation only. Rosemount Test Report 108025, Rev B, dated February 1983, has been evaluated and j
found to qualify W Rosemount Model l153, Series B transmitters g
for the normal service conditions and h postulated post-accident radiation at the Quad Cities units. The Installed operational life of the Model 1153, Series B has been determined by Rosemount to be 20 years; therefre, these naponents will require replacement at the end of this period. These quellfled replacement components should be in NRC Category 1.A, Equipment-Qualifled.
j QCI: 63 Mercold, DA5333 1.B Documented evidence of qualification These components were scheduled for shielding or replacement, and inadequate qualification was not available at the time of h TER/SER review.
Therefore, h documented evidence of qualification was considered inadequate by FRC. Qualification was required for 4
post-accident radiation only. The shielding design for h se
}
components has been completed, and h radiation environment is now mild. Therefore, h se components should be in NRC Category ell.B, Equipment Not in h Scope of h Review.
~
H.
FLOW TRANSMITTERS QCis-10,31 General Electric 1.B Documented evidence of qJalification At h time of TER/SER review, h se components were scheduled for QC2: 10,31-GE/MAC 553 inadequate ei h r testing or analysis. The decision was made to test h component for radiation because radiation caused by a design basis accident is W only harsh environment to which these t.caponents are ever subjected Subsequently, h GE/MAC 553 transmitters were tested by Wyle Laborateries. Qualification was provided in Wyle Test Rsport 45917-1, July 30, 1982. Review and evaluation of h test report revealed that h se components are qualified for the required conditions. Therefore, these quallfled components should be in NRC Category 1.A, Equipment Qualifled.
.QCis.68 Leeds And Northrup I.B Documented evidence of qualification This component was origine51y scheduled for replacement; however, 000-0300-0300 Inadequate no qualified replacement wws identified at h time of TER/SER review. Therefore, documented evidence of qualification was indicated as inadequate. Subsequently, it was determined that this component would perform no safety-related function. It provides only flow indication for h SGTS and does not provide
^
any control function. The required control function for W system is provided by FSL 1/2-7541-8A,B and -33A,B.
Therefore, this component should be in NRC Category ill.A, Equipment Eumpt from Qualification.
I 0494c IV-5
I V.' Specific Equianent EO Deficienci s (continuedj Description (bnufacturer, NRC FRC lten Humber Model. Etc)
Category Deficiencies Proposed Resolution I.
HYDROGEN SEllSORS QCI: None General Electric NA None These sensors were not part of the original IE Bulletin 79-01B QC2: None submittal and were added to h program af ter the SER/TER review. Qualification deficiencies were observed for operating time, temperature, pressure, relative humidity, and radiation.
Ceco decided to replace this General Electric system, includies h sensors, with a qualified gas analyzer system instead of '
/
g qualify ng by other means. Ceco has rocured h se gas analyzers and is n h process of installing e new systems. These gas.
analyzers are manufactured by Consip, Delphi System Division (Model K-IV).
EART Test Report 1035-1 for Consip is being N
J.
LEVEL-INDICATING TRANSMITTLR SWITCHES QCI: 42 Yarway 4418C and 4418CE I.B Documented evidence of qualitication These comments were scheduled for replacement; however, no 4C2: 42' Inadequate qualified replacement was identified at W time of the TER/SER review. Therefore, documented evidence of qualification was indicated as inadequate. They will be replaced by quallflod Rosemount Model 1853, Series B transmitters. Qualification is required for post-acc Hent radiation elly. Rosemount Test Report 108025, Rev B, dated Febraary 1983, has been evaluated and found to rwalify h Rosemount Model 1153, Series B transmitters for h normal service conditions and h postulated post-accident radiation at Dresden and Quad Cities units. The qualified ilfe of the Model 1853, Series B has been determined by Rosemount to be 20 years; therefcee h se components will require replacement at h end of this period. The qualified replacement components should be in NRC Category 1.A, Equipment Qualified.
K.! LEVEL SWITCHES QCis None Magnetrol 291 NA None These er-panents were originally considered to be in a mild
.QC2: None-arei; W refore, h y were deleted from W qualification program. Later, it was found that hse components would be subjected to a harsh temperature environment for a short period of time during a LOCA. These components were previously tested, and the test results are provided in Wyle Test Report 43235-1, May 2, 1977. This report has been reviewed and evaluated and found to encompass the required time and temperature environment for Quad Cities units, hrefore, hse qualified components should be !n NRC Caregory 1.A, Equipment Qualified.
i L.
LEVEL TRANSMITTERS
~
None 1
0494c IV-6
-IV.
Specific Equipment 20 Deficiencies (continued)
Description (Manufacturer, NRC FRC lten Number Model. Etc)
Category Deficiencies Propos%t Resolution C.
LOCAL CONTROL PANELS QCI: 65 Hario, DRAW-D/297 1.B Documented evidence of qualification These components were scheduled for replacement; however, no inadequate.
qualified replacement was identified at h time of the TEk/SER review. Therefore, documented evidence of qualification was Indicated as inadequate. These panels are required to be quellfled for radiation only. A review of possible replacement panels on the market revealed that none were qualified to meet the required radiation dose. Therefore, the panels will be physically shielded to reduce their radiation dose to that of a
/
mild environment. The panel shielding will be cog leted by March 1985. Therefore, the shielded panels should be in NRC Category ill.B Equipment Not in the Scope of the Review.
[g N.
LOCAL PANELS None O.
MONITORS, ACOUSTIC 0C1: None NOT snstruments 1.8 None, pending modifications This ecNipment item has been removed from the environmental QC2: 104 Model 400A qualification program pending completion of the following items:
pretaplifiers
- a. Detailed control room design review
- b. Response to NRC concerning compliance with Regulatory Guide 1.97, Rev 2
- c. Determin olon of electrical equipment located in harsh envi-ronments required for TMl lessons-learned implementation (NUREG 0737) In accordance with IE Bulletin 79-018, Supplement 3, item 2 Fur h r details are included in Section I of this enclosure.
P.
MOTOR CONTROL CENTERS QCI: 43 General Electric l.B Documented evidence of qualification Qualification deficiency was identified as the radiation para-QC2 43 7700 Series inadequate metar and was e lginally to be resolved by analysis and/or testing. This.hficiency was applicable because h se MCCs had not been qualified to a harsh radiation environment. Later, the qualification was selected to be by the method of testing. A dotalled walkdown of h MCCs was completed to identify the specific components of each MCC. An investigative study was undertaken to properly select the co gonents to be included in h test program. These components, which were obtained from the stations with consideration for the vintage, were assembled into a test model designed to be representetive of all MCCs. A radiation test was conducted for this model. Wyle Test Report 45917-30 was evaluated. The defichncy is resolved by this test report, and this item is fully qualified to all environmental parameters. Therefore, these qualified components should be in GC Category I.A. Equipment Qualified.
0494c IV-7
i IV-Mific Eaulomont EQ Deficiencies (continued)
Description (Manufacturer, NRC FRC ltem Number Model. Etc)
Category Deficiencies Proposed fS w lution l
Q.
MOTOR-DRIVEN PUDFS QCl 2 General Electric 1.B Documented evidence of qualification The qualification of these components was not established at h time of TER/SER review, and the components were stated to be QC2: 2 5K6338XC23A Inadequate qualified for radiation during a post-0BA operation only.
General Electric has provided qualification documentation in its Report NEDC-30067/83NED025 (February 1983) for h motors at Quad 4
Cities. Based on the evaluation of W data in h se reports, 1
these motors are qualified for the normal and W postulated post-DBA environmental conditions. Therefore, these qualified components should be in NRC Category 1.A, Equipment Qualified.
QCI: 3 General Electric 1.B Ibcumented evidence of qualification The qualification of these components was not established at the time of TER/SER review, and the components were stated to be QC2s 3 SK6336XCl93 Inadequate qualified for radiation during a post-0BA operation only.
General Electric has provided qualification documentation in its Report NEDC-30067/8?NED025 (February 1983) for h motors at Quad Cities. Based on the evaluation of the data in h se reports, Wse motors are qualified for the normal and the postulated post-0BA environmental conditions. Therefore, W se qualified components should be in NRC Category I.A, Equipment Quallfled.
R.
MOTOR EXHAUST FANS QCI:.60 General Electric l.B Documented evider.ce of qualification The qualification of h se components was determined to be inade-SK2568K2038 is inadequate quate at h time of the TER/SER review because quellfled replacements were not identified. Therefore, h y will be replaced by quellfled Westinghouse motors. Qualification is required for radiation only. Radiation qualificatien is documented in Westinghouse Test Report P919112, dated Janusry 1982. Review of N test report revealed that these fan motors are qualified for h required radiation dose rate. Therefore, N se quallflod components should be in NRC Category 1.A, Equipment Qualifled.
l l
4 l
l 1
l 1
IV-8 0494c
IV. Spec:fic Equionent EO Deficienci's (continued) f bu"h d[?B
^
V u
S.
MOTOR OPERATORS Note: Resolution of identified deficiencies for motors operators is corrplex because or *he large number of dif ferent models involved and the variety of environments encountered for which qualification is required. The cross-reference table below provides the plant identification numbees of the operators included in each FRC item and references the specific deficiency and resolution for each operctor. The numeric and letter entries of the cross-reference iable correspond to deficiency and resolution descriptions that follow In continuation of the resolution table.
Unit 1 Unit 1 Unit 2 Deficiency Deficiency Deficiency
@ Valve Nun 6er Number Resolutions FPC Valve Number Nun 6er Resolutions FRC Valve Number Nun 6er Resolutions 4
MD-I-1402-3A,B 3
0 25 E l-1001-16A,B; 3
B.1, G 4
% 2-1402-3A,B 3
D 4
D MD-I-1001-185A B; 4
1, J 4
D MD-I-1001-19A,1b; 5
MD-I-1402-4A,9 3
B.1, G h i-1001-4A,B 5
MO-2-1402-4A,B 3
B.I. G 4
I, J 4
1, J 26 MD-t-1001-23A,B 3
B.4, G 6
MD-I-1001-26A,B 3
B.4, G 4
H, 1, J 6
MO-2-101-26A,B 3
B.4, G 27 MD-I-1001-2BA,B; 1
B.I 7
MD-1-1402-25A,B; 3
B.4, G MD-I-1001-34A,B 2
E 7
M0-1-1402-25A,B; 3
B.4, G MD-1-1402-24A,B 4
H, 1, J 3
G M0-1-1402-24A.B 4
H, I, J 4
1, J 8
MD-I-1402-38A,8 i
B.3 B
MO-2-1402-3BA,B i
B.4 2
E 28 E l-f001-63 1
A.2 2
E 3
G 3
G 4
H, 1, J 29 MO-l-8001-50 i
A.1 4
H, 1, J 13 MD-I-2301-4 i
A.2 34 MD-I-1001-60 i
B.2 13 MO-2-2301-4 i
A.2 2
A.2 2
E 39 MD-I-1201-2 i
A.I 14 MD-I-2301-5 i
B.2 MD-I-1301-16 i
A.2 14 MO-2-2301-5 i
B.2 MD-I-1201-2 2
E 19 MD-1-220-1 1
A.2 MD-I-1301-16 2
A.2 19 MD-2-220-1 1
A.2 2
A.2 2
E 40 MD-I-1201-5 i
B.I 22 MD-I-1001-7A,B,C,D 3
D 22 MD-2-1001-7A,B,C,0 3
B.I, G 4
D 41 MD-I-3706 i
A.2 4
1, J MO-1-3703 i
B.I 23 MD-I-1001-5A,B 3
B.4, G M0-1-3706 2
A.2 23 MO-21-1001-5A,B 3
B.4, G 4
H, I, J MO-I-3703 2
E 4
H, I, J 24 MD-I-1001-18A,B 3
B.1, G 45 MD-I-3702 3
B.1, G 24 P10-2-l001-18A,8 3
B.I. G MD-I-1001-29A,B 3
B.4, G 4
1J 4
- 1. J MD-I-1001-36A,B 3
B.1 MO-2-1001-29A,B 3
B.4, G MD-I-1001-37A,8 3
B.I 46 MD-I-202-5A,8 i
A.3 4
H, 1, J MD-I-1001-18A,B 4
1, J E l-202-9A,B 1
C MO-2-1001-36A,B 3
B.1, G E l-1001-29A,B 4
H, 1, J MD-I-202-6A,B I
C 4
1, J MD-1-1001-36A,B 4
1, J MO-2-1001-37A,B 3
B.1, G MD-1-1001-37A,8 4
1, J 68 MD-I-202-4A,B l
C 4
1, J 05113 IV-9
IV.
Specific Eautoment EQ Deficiencim (continued)
Unit 2 Deficiency kl.c, e // g
@ Valve Number Number Resolutions Ggg g
() [
25 MO-7-1001-16A,8; 3
3.1, G MD-1-1001-185A B; 4
1, J MD-2-1001-19A,b;-
i MD-?-1001-4A,B 26 MD-2-1001-23A,B 3
B.4, 0 4
H, 1, J 27 MD-2-1001-28A,B; 1
B.I, B.4 MD-2-1001-34A,B (34B only) 2 E
3 G
4 H, I, J 28 MD-2-1001-43 1
A.2 29 MD-2-1001-50 i
A.I 34 MD-2-1001-40 1
B.2 39 MO-2-1201-2 i
A.I 2
E 40 MD-2-1301-16 i
A.2 MD-2-1201-5 1
B.1 41 MD-2-3706 i
A.2 MD-2-3703 i
B.I 45 MD-2-3702 2
B.1, E 46 MD-2-202-5A,8 l
A.3 2
E MD-2-202-9A,B l
C 2
C MD-2-202-4A,B 1
C 2
C 0511c -
IV-10
IV.
Specific Equipment EQ Deficienci's (continued)
Description (Monufacturer, NRC FRC ltem Number Model. Etc)
Category Deficiencies Proposed Resolution S,
Motor Operators (continued)
QCI: 8,13,14, Limitorque Type S86 1.B
- 1. Documented evidence of qualification t Lim 1 torques inside the Drywell
'19,27,28,29, ac motors: Peerless, it.A.
Inadequate
- 1) Operators inside the drywell with Type B motor insalation, 34,39,40,41, Rollance, Limitorque, no motor breakes and operating times less than 2 minutes 46,68 de motor: Peerless, arebeingqualifIedutilizingTestReportWCAP-7410L, Reliance supplemented by Bechtel Thermal Analysis NUC-31, which 8,13,14 1.B, demonstrates that the operators complete their function QC2:17,27,28,b, Limitorque Type Sf6 ac motors: Peerless, ll.A before exceeding the NCAP-7410L test temperature. Test 34,39,40,41 Reliance, Electric Report WCAP-7410L has been evaluated and found accsptable td Apperatus, Limitorque 4
y qualify these components to the required environment at Quad
.Q N Cities. Therefore, t%se components qualified by h above de twtors: Peerless, e
Reliance test report and the analysis should be in NRC Category 8.A, U
Equipment Qualifled.
- 2) All S86-000 size operators inside the drywell and all operators with operating time g-eater than 2 minutes are balng replaced with operators qualified to Limitorque Test Report 600376. This test report has been evaluahd and found acceptable to qualify these components to N required environment at Quad Cities. Therefore, these replacement conponents should be in NRC Category 1.A, Equipment Qualified.
- 3) Operators inside the drywell with short operating times and motor brakes will h.,ve replacement motors that do not require brakes. These replacement motors are qualified to Test Report 600376. Test Report 600376 has been evaluated and found acceptable to qualify h se new motors to N roouired environment at Quad Cities. Therefore, h se rators with qualified ; placement motors should be in Category 1.A, Equipment Qualified.
- 4) This operator, located inside the drywell, with an Electric Apparatus motor is being qualified utilizing h WCAP-7410L test report supplemented t y a statement from Limitarque that, for purposes of environmental qualification, the Electric Apparatus motor is equivalent to a Reliance motor as used in W WCAP test. With the above qualification, this operator should be in NRC Category 1.A, Equipment Qualified.
B. Limitorques Outside the Drywell
- 1) Limitorque has stated by letter that, for tha g rpose of equipment qualification, N Class B Insulation system of Dresden and Quad Cities dc :notors is similar to h ac motors qualified in Test Report B0003. Test Report 600461-80003 has been evaluated and found applicable to qualify hse operators to hir environmental service conditions at Quad Cities. Therefore, these operators should be in NRC Category I.A. Equipment Qualified.
0494c IV-Il
r_
IV-Specific Equipment EO Deficienci m (continued)
Description (Manufacturer, NRC FRC ltem Number Nodel. Etc)
Category, _
Deficiencies Proposed Resolution S.
Notor Operators (continued)~~
- 2) Operators in the steam tunnel and torus with short operating times are qualified by Test Report B0003,
- [f fG supplemented by Bechtel Thermal Analysis NUC-29. The analysis shows that the thermall sensitive materials will b d$'#
notexceedthequalificationtesftemperatureinTest
//,,,
Report B0003. Therefore, these operators should be in NRC N
' A g//
g Category 1.A. Equipment Qualified.
.r
- 3) Operators with unqualified motors will have replacement
/w/) l' y
motors quellfled to the service conditions and Limitorque Test Report 600461-80003. Therefore, these qualified replacements should be in NRC Category I.A, Equipment Qualified.
- 4) The motors with brakes will be replaced with new motors that do not require brakes. The nes.-otors will be qualified to Report B0003, or the operators will be ccrrelately replaced with new operators qualified to either Test Report 600376 or B0003 depending on the service conditions. These qualified replacements should be in NRC Category I.A, Equipment Coalified.
C. Non-Class IE Items, providing no safety-related functions, have been deleted from the program. Therefore, these operators should be in NRC Category ill.A, Equipment Exempt fran Qualification.
D. Operators located in mild environment have been deleted from the program. Therefore, these operators should be in NRC Category 111.B, Equipment Not in the Scope of the Review.
QCI: 8,13,19, Limitorque Type SPE 1.B.
- 2. Demonstrate adequate similarity between E. Letters (referenced on SCEW sheets) from Limitorque state the 27,39,41,46 ac motors: Reliance, ll.A the equipment and the test specimen applicability of the 80003 and WCAP-7410L test reports for Limitorque, Peerless each shop order and provide evidence of similarity to the test de motors: NA specimens.
QC2: 8,13,19, Limitorque Type S8e I.B, 27,39,41 ac motor: Reilance, ll.A L1mitorque de motors: NA QCI: 4,5,6,7,8, Limitorque Type Sie 1.8
- 3. Evaluate age-related degradation for F. Mobil 28 grease has been installed on all torque and limit 22,23,24,25, ac motors: Peerless, ll.C these operators switches for operators located inside the drywell and steam 26,27,45 Reliance, Lim 1 torque tunnel to replace Beacon 325, which hardened due to elevated de motors: NA tenperatures.
QC2 4,5,6,7,8, Limitorque Type Spe 1.B.
22,23,24,25, ac motors: Peerless, ll.C G. A motor analysis is being re red by Bechtel utilizing Test 26,27,45 Reliance, Limitorque Reports B0058, B0003, and
-7410L. This analysi s will de motors: NA demonstrate that Class B motors can withstand a design basis accident following 40 years of installed life.
0494c IV-12
IV. Specific Equipment EQ Deficiencies (continued)
Description (Manufacturer, NRC FRC ltem Number Model. Etc)
Catego_ry Deficiencies Proposed Resolution S.
Motor Operators (continued)
QCI: 4.5,6,7,8, Limitorque Type See 1.8,
- 4. Qualified life or repacemeat schedule H. Specific outage dates have been provided for all replacement 22,23,24,25, ac motors: Peerless, ll.C not established items.
26,27,45 Reliance, limitorque de motors: NA
- 1. No other weak-link materials (besides the grease in QC2: 4 5,6,7,8, Limitorque Type Spe I.B.
-gj resolution F above) have been identified by Limitorque or 22,E3,24,25,acmotors: Peerless, ll.C ErOgF Bechtel that require ongoing maintenance or replacement.
26,27,45 Reliance, limitorque
$/~jj N h
J. Lim 1 torque tests have preconditioned the motors to their de motors: NA y M
., "ljp end ef-life condition in accordance with 10 CFR 50.49 (Test 4
fyg -
g p
Reports B0r58, 600461-80003, 600376, and WCAP-7410L).
T.
POSITION SWITCHES QCI: 58 NAMCo, EA000lll00 1.B Documented evidence of qualification At the time of TER/SER review, adequate evidence of qualification l
QC2: None inadequate was not established for these position Mtches because quellfled replacement switches were not identifies Qualification is required for all the accident environmental parameters, and aging is required because these components are subjected to harsh levels of radiation and temperature during normal operation. At Quad Cities Unit I, the original switch has already been replaced with a NAMCo snap-lock Model EA160-Il302 during November and December of 1982. At Quad Cities Unit 2, the existing switch will be replaced with the above NAMCo model during the next station outage. Qualification data for these N/MCo replacemer,t switches is provided in NAMCo Test Report QTR 105, Rev 3, August 20, 1981. This report has been reviewed and found to qualify these new switches for the required accident environment. To establish a designated life, an analysis is being performed based on the data provided in the NAMCo fast report. These quallfled replacement components should be placed in NRC Category 1.A, Equipment Qualified.
U.
PSISSURE SWITCHES QCI: 21 Static-O-Ring 1.B Documented evidence of qualification These conponents were scheduled for replacement; however, no QC2: 21 12NN-KK2!5VX is inadequate qualified replacement was identified at the time of the TER/SER review. Therefore, documented evidence of qualification was indicated as inadequate. They wiII be replaced by qualifled Rosemount Model 1853, Series B transmitters. The harsh environmenir parameters this equipment will encounter are temperature, pressure, and humidity during post-0BA operation.
Radiation is consid9 red mild at <l.0E04 reds. Rosemount Test Report 10C025, Rev B, dated February 1983, which provides the qmiification data for these transmitters, indkates that the transmitters are qualified for the required environmental conditions. The qualified life of the Ibdel ll">3, Series B transmitters has been determined by Rosemount to be 20 years; therefore, these components will require replacement at the end of this period. These quallfled replacemer t components should be in NRC Category I.A, Equipment Qualifled.
0494c IV-13
-IV. ~ Specific Eaulomont EQ Deficiencies (continued)
Description I
.- 04enufacturer, 15tC l
FRC ltem Number Model, Etc)
Cateaory Deficiencies Proposed Resolution U-Pressure Switches (continued) c,
.QCI: 33 Static-O-Ring II.A Documented evidence of qualification Not applicoble because W se components are not subjected to
,QC2; 33 GNL-3 is inadequate harsh environmental conditions; h refore, h y are deleted from the qualification program. These component should be in IRC Category ill.8, Equipment Not in the Scope of the Review.
QCt: 36 Static-O-Ring II.A Documented evidence of qualification Not applicable because W se components are not subjected to (QC2:-36
.12N-AA5-PP is inadequate harsh environmental conditions; h refore, they are deleted from W qualification program. These components should be in 85tC Category lli.8, Equipment Not in W Scope of W Review.
0C1: None Barksdale B2T-Al2SS NA None These components were locaed in mild environments at the time of QC2: None
. h TER/SER review; therefore, r.o deficiency was identified.
Subsequently, deficiencies were identified for pressure, temperature, and humidity only. W refore, h se Barksdale B2T-Al2SS pressure switches will be replaced with quellflod
/
Rosemount Model 1153, Series 8 transmitters. Rosemount has t
tested its Model 1153, Series B transmitters and provided h
"" ' " ' "" ' '" "'~ "
'"'" '' ' "".The report has been reviewed a'nd eva'luated and J '
N qualified life of h Model l153, Series B transmitters has February 1983 found to qualify W transmitters for h required conditions.
been determined by Rosemount to be 20 years; h refore, h se components will require replacement after this period. These qualified replacement components should be placed in 15tC Category 1.A, Equipment Qualified.
V.
PRESSURE TRANSMITTERS
.' QCi s ' None :
' Bailey, B8W NA None At the ilme of the TER/SER review, no deficiency was identified QC2: None.
K6556220BAAlWFE for h se Bailey pressure transmitters. However, these transmitters are required to be qualified for post-accident radiation only. Wyle has conducted testing on h se transmitters and provided qualification documentation in Test Report 45917-60, September 1983. The report has been reviewed and evaluated, and it has been determined that h se transmitters are qualified for h required accident radiation dose. Therefore, h se qualified components should be placed in NRC Category 1.A, Equipment Qualifled.
049ec IV-14
=
.-. _ _ = - _
IV.
%ecific Equipment EO Deficiencl<s (continued)
Description (Manufacturer, NRC FRC ltem Number Model. Etc)
C_ategory Deficiencies Proposed Resolution V.
Pr ssure Transmitters (continued)
QCI: 9,30 GE/MAC 551 1.B Documented evidence of qualification At the time of TER/SER review, these componecis were scheduled for QC2 9,30 inadequate either testing or analysis. The decision was made to test the component for radiation because radiation caused by a design basis accident is the only harsh environment to which these components are ever subjected. Subsequently, the GE/MAC Model f.
551 and 553 transmitters were tested by Wyle Laboratories.
O Qualification was provided in Wyle Test Report 45917-6, July 30, t f 1982. Review and evaluation of the test report revealed that u
these components are quellfled for the required conditions.
- g. 3 Therefore, these qua1ifIed components shoutd be in NRC Category I.A Equipment Qualifled.
p it. RADIATION DETECTOR None X.
ELECTRIC MOTORS (ROOM COOLER FAN MOTORS) 0C1: 37 General Electric Model I.B Docunented evidence of qualification These components were scheduled for replacement; however, no QC2 37 5K213AK2476 Inadequate qualified replacement was identified at the time of the TER/SER review. Therefore, documented evidence of qualification was indicated as inadequate. They will be replaced by quallfled Westinghouse motors. The components are required to be quallfled for post-accident radiation only. Westinghouse has provided the radiation quallfled for the replacement motors in Test Report P919112, dated January 1982. Based on review and evaluation of this report,d for the postulated accident radiation dose.it has been determin are qualifie Therefore, these qualified replacement components should be in NRC Category I.A, Equipment Qualified.
0494c IV-15
IV. Specific Eaulement EQ Deficienci-s (continued)
Description (Menufacturer, IRC FRC ltem Number
-Mode?. Etc)
Category Deficiencies Proposed Resolution X.
Electric Motor s (Room Cooler Fan Motors) (continued)
QCI: 38 General Electric Model I.B Documented evidence of qualification These m =panents were s.cheduled for replacement; however no QC23.38 SKl84AL2151 Inadequate qualified replacement was identified at h time of the IER/SER review. Therefore, documented evidence of qualification was Indicated as inadequate. They will be replaced by qualified Wstinghouse motors. The components are required to be qualified f
for post-accident radiation only. Westinghouse has provided h I1 radiation qualified for h replea-ant metors in Test Report 0919112, dated January 1982. Based on. review and evaluation of this report, it has been determined that h Westinghouse motors are qualified for the postulated accident radiation dose.
hrefore, hse qualified reple== ants should be in IRC Category 1.A, Equipment Quelified.
'Y..SOLENDID VALVES QCI: 16
-AVCo C5512 1.B Documented evidence of qualification The November 1980 submittal identified h se components as QC2: 16 -
Gould, 320X39/320X30 Inadequate requiring qualif! cation by testing or replacement. No inforination on replacement qualification was available at that time; h refore, FRC deter 1 mined h t documented evidence of qualification was inadequate. Subsequently, Ceco joined a generic test program for h se valvet sponsored by TVA. The TVA test program was initiated at Wyle Lai, oratories to envelop all harsh environmental. conditions at Quad Cities. TM ongoing test program has currentty established a 5-year qualification for h se solenoid valves. In addition, an analysis will be performed to take credit for h tests being cond d ed to-environmental conditions beyond those required and to establish a reasonable estimate of h quellfled life and appropriate maintenance and replacement requirements.
QCia.17 AVCo/ Target Rock II.C Aging degradation not identified, quell-At h time of h TER/SER review, these components were identi-
' QC2:;17 C5450-5 fled life and repl e== ant schedule not fled as Dresser Industries valve Model C5450-5. FRC noted h t established only age degradation was not identified and qual.fied life and repl e== ant schedule were not esteolished. Subsequently, h se i
components were identified as Automatic Valve Corporation (AVCo)
Model C5450-5 operators on Target Rock relief valves. As a result, h se operators are required to be quellfled to harsh environmental conditions due to temperature, humidity pressure, radiation and domineralized water spray. h rmal ag ng is also r
requiredlobeaddressed. General Electric Plant Des gn i
Engineering Memorandum 126-62, dated January 15, 1975, i
establishes qualification for h se AVCo/Taroet Rock solenoid valves to the Quad Cities harsh environmental conditions. In addition, this report has been supplemented by a Fechtel analysis performed to establish a reasonable estimate of W designated life. Therefore, hse quellfled components should be in IRC Category.1.A, Equipment Qualifled.
i 1
0494c IV-16 i
k-
IV. Specific Eoatoment EQ Deficiencies (continued)
Dorcription (Manufacturer, NRC 4
FHC lten Number Model. Etc)
Cateoory Deficiencies Proposed Resolution Y.
Solenoid Valves (continued)
QCI: 18 Dresser 1525VX ll.C Aging degradation not identified, quall-During the TER/SER review, FRC indicated that aging degradation QC2: 18 fled life and replacement schedule not for these Dresser solenoid valves was evaluated inadequately and established that qualified life and replacement schedule were not established. Later, it was also determined that these components.
would be exposed to higher levels of radiation and temperature than the original values stated in the November 1980 report.
Therefore, these components are required to be qualified for temperature, radiatior, and aging. Nor h ast Utilities Millstone i Project E gineering Frogram 42963,Section I, D
demonstrates partial qualification for h se valves. This report is being supplemented by a Westec analysis to establish complete hr environmental qualification and proper maintenance and replacement requirements. Westec has identified all subcomponent materials and confirmed that a high-temperature insulation system i
was employed in h se valves. This insulation system was also i
satisfactorily submergence-tested. The analysis is scheduled for completion in February 1984.
i QCl: 47 Versa VPS2502/VGS4522/
l.B Documented evidence of qualification At the time of TER/SER review, evidence of qualification was not QC2: 47
,VGS4422 Inadequate adequately established for h se Versa solenoids valves because quallfled replacements were not identified. The Versa valves will be replaced by ASco solenoid valve Model NP8344A73V at Quad Cities. Based on tt4 evaluation of ASCo Test Report AQR47368, Rev 0, these ASCo velves are qualified to h required environmental conditions at Quad Cities. Therefore, these qualified replacement components should be in NRC Category I.A, Equipment Qualified.
I QCl 66 Versa VWS2302 1.B Documented evidence of qualification TER/SER review identified that the qualification documentation was inadequate inadequate because a qualified replacement was not identified for I
this Versa solenoid valve. After reevaluating h qualificailon requirements, it was determined that h SGTS butterfly valve is t
of the fall-open type and is normally open during system operation. It IS r.ct required to change position following an accident. Failure or this valve will not affect ystem safety functions; Wrefore, this component should be in imC Category ill.A, Equipment Exempt from Qualification.
4 QCI: None ASCo NP-1 II.C Aging degradation not identified, quell-An aging analysis had not been performed on this component at h
- QC2: 49 206380-NVF fled life and replacement schedule noi time of the TER/SER review; therefore, aging degradation was not established identified as a qualification parameter. The qualified life and replacement schedule were not established. Aging and quallfled life were addressed generically in Attachment 5 to h TER/SER response. Bechtel has performed an analysis (Bechtel Calculation NUC-32, Rev 0, dated July 20, 1983) to determine h qualified life of the solenold valve subcomponents on h basis of ASCo Test Report AQR-67368, Rev 0.
Subecaponent raolacement schedules have been established and are being incorporated in the plant maintenance and surveillance program. The quellfled life for h subcomponents is as follows: Viton A static seal, 37 years and solenoid coII, 30 years. Therefore, these' qualified components should be in NRC Category I.A, Equipment Qualified.
0494c IV-17
IV-Specific Eaulpment EQ Defici ncies (continued)
Description (Manufacturer, NRC FRC ltem Number Model. Etc)
Category Deficiencies Proposed Resolution Z.
SWITCHGEAR None AA. TEMPERATURE ELEMENTS QCI: 1 Minco (for Panatarm) 1.B Documented evidence of qualific..stion The identified deficiency was te%.erature and was originally to be QC2: I S51-1-103 Inadequate resolved by material analysis. A literature search revealed that all teflon components of the Minco temperature element were inadequate for the required environment. Therefore, the existing -
resistance temperature detectors, TE-1291-60A through H, will be replaced with environmentally qualified temperature detectors w/
[ar:r t
manufactured by Conax Corporation. These Conax temperature gf; detectors will provide an environmentally qualified system, which
,g w, je -
will have redundant sensing trains to detect steam leaks. Conax 4
g 1 /
Test Report IPS-875 was evaluated, and the replacement components are fully qualified for the required environnent. These qualified replacement components should ae in NRC Category l.A, Equipment Qualifled.
BB. TEMPERATURE SWITCHES QCl: 15 UEC Type F7, Model 88B II.A Documented evidence of qualification The TER/SER evaluations concluded that the qualification documen-QC2: 15 inadequate tation was inadequate for these components because Ceco's periodic calibration did not provide evidence of qualification in accordance with the DDR guidelines. These temperature switches are required to be qualified to harsh environmental conditions of temperature, humidity, pressure, and radiation. Thermal and radiation aging effects must also be established. Therefore, it was determined that the qualification would be established by either analysis or replacement. Subsequently, it was decided to replace the microswitch to establish material traceability and to qualify the components by analysis. An analysis is being performed using MCC Powers Test Report 734-79-002, Rev 1; Farr Company Test Report L-71063, Rev A; and the manufacturers' i
technical literature.
QCI: 20,48 Fenwal Model 17002-40 ll.A Documented evidence of qualification The TER/SER evaluation concluded that the qualification documenta-QCt: 20,48 inadequate tion was inadequate for these components because Ceco's periodic calibration did not provide evidence of qualification in accordance with the DOR guidelines. These temperature switches are required to be qualified to harsh environmental conditions of temperature, hurr.idity, pressure, and radiation. Thermal and radiation aging effects must also be established. These switches have a very short operating time, and the accident radiation dose is correspondingly small. They are very simple devices with the most sensitive material (teflon) located only on the lead wires.
Therefore, qualification is being established by material analysis based on the manufacturer's technical literature; GE Report NED024217; GE Report DV145C3004; Wyle Report 43854-1 of TVA; and Bechtel Chron 7089, dated March II, 1983.
0494c IV-18
IV.
Specific Equipment EQ DeficiencI s (continued)
Description (Manufacturer, NRC FRC ltem Number Model. Etc)
Category Deficiencies Proposed Resolution BB. Temperature Switches (c M inued)
QCI: 64 Chromalox bimetal I.B Documented evidence of qualification The TER/SER stcted that qualification documentation was inadequate thermoswitch:. manufac-Inadequate for the thermoswitch because quallfled replacements were not iden-turer unknown tified. In the TER response, it wa s stated that qualification was required for harsh temperature, humidity, pressure, and radiation for the components and that qualified replacements would be installed during or before critical outages at the stations. Subsequently, the stations removed these switches frun the circuitry because they were not required for system operation. Therefore, the components should be deleted from the IE Bulletin 79418 scope and placed in NRC Category ill.A, Equipment Exempt from Qualification.
QCI: 67 Pall Trinity micro-1.B Documented evidence of qualification The SER/TER stated that qualification documentation was inadequate switch 14-T-2H Inadequate for the thermocouple because qualified replacements were not identified. Qualificatian is not required for these components because an environmentally qualified suppression pool temperature monitoring (SPTM) system is installed as a Class IE system to monitor watcr temperature, thereby providing the same function as the subject thermocouples. Therefore, these qualified components should be in NRC Category ill.A, Equipment Exempt from Qualification.
CC. TERMINAL BLOCKS QCl: 57 Allen-Bradley I.B Documented evidence of qualification These components were scheduled for replacement; however, no QC2: None Allen-Bradley inadequate quallfled replacement was identified at the time of the TER/SER review. Therefore, documented evidence of qualification was indicated as inadequate. They will be replaced by Marathon Series 1500 terminal blocks. The equipment is required to be quallfled for harsh environment due to temperature, pressure, humidity, radiation, and domineralized water spray during post-0BA operation. In addition, thermal aging at 150F is required for the remaining 30 years. The Marathon Series 1500 terminal blocks were tested by Wyle Laboratories and qualified by Wyle Test Report TIE-45603-1 February 18, 1982. Based on review and evaluation of this report, it has been determined that the equipment has a quellfled life of 40 years and is quallfled for the postulated accident environment. These qualified replacement components should be in NRC Category I.A, Equipment Qualified.
DD. OILS AND GREASES None
-Mobil 28 None None Qualified by Mobil Technical Bul!etin, May 1974; used in Limitorques.
None Mobil DTE medium heavy None None Qualified by Mobil Technical Bulletin, May 1974; used in General Electric LPCI, core spray, RHR, and shutdown cooling pump motors.
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0494c IV-19
IV.
Specific Equipment EQ Deficiencim (continued)
Description (Manufacturer, NRC 9/
FRC ltem Nun 6er Model. Etc)
Cateoory Deficiencies Proposed Resolution CC. TElW41NAL BLOCKS D2: 100 Al len-Bradley 1.B Documented evidence of qualification These components were scheduled for replacement; however, no D7: 101 General Electric inadequate qualified replacement was identified at the time of the TER/SER D3: 74 General Electric review. Therefore, documented evidence of qualification was indi-D3: 75 Allen-Bradley cated as inadequate. They will be replaced by Marathon Series 1500 terminal blocks..The equipment is required to be quellflod for harsh environment due to temperatt.re, pressure, humidity, radiation, and domineralized water spray during post-0BA operation. In addition, thermal aging at 150F is required for the remaining 30 years. The Marathon Series 1500 terminal blocks were tested by Wyle Laboratories and qualified by Wyle Test Report TIE-45603-1, February 18, 1982. Based un review and evaluation of this report, it has been determined that the equipment has a qualified life of 40 years and Is qualified for the postulated accident environment. These qualified replacement components should be placed in NRC Category 1.A, Equipment Qualifled.
D0, OILS AND GREASES None Mobil 28 None None Quallfled by Mobil Technical Bulletin, May 1974; used in Limitorques.
None Mobil DTE medium heavy None None Quallfled by Nobil Technical Bulletin, May 1974; used in General Electric LPCI, core spray, RHR, and shutdown cooling pump motors.
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