ML20087P665
| ML20087P665 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 03/30/1984 |
| From: | Rybak B COMMONWEALTH EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 8394N, NUDOCS 8404090255 | |
| Download: ML20087P665 (38) | |
Text
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/D Commonwealth Edison
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) One First NLtionil Plaza. Chicago, lihnois
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} Chicago. Illinois 60690 Address Riply to: Post Office Box 767 N
f March 30, 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 Final 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. Rybak letter to H.
R. Denton dated May_19, 1983.
(c):
B. Rybak letter to H. R. Dentore dated February 29, 1984.
Dear Mr. Denton:
A meeting _was held with members of your staff on January 25 and 26, 1984'to discuss Commonwealth Edison Company's (CECO's) resolution for all deficiencies noted in the SERs and TERs for the Zion, Dresden and Quad Cities Stations.
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.
Reference (c) transmitted, in draft form, CECO's understanding of the final 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, was addressed in Section I'of-the enclosure of that letter.
The staff has reviewed Reference (c)
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and requested a final submittal.
This letter and its enclosure is considered the final resolution of the environmental qualification issue at-Quad Cities Station.
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
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will be reevaluated in accordance.with their respective schedules:
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16-R. Denton March 30, 1984 Acoustic monitors Containment water level indication Containment pressure indication Suppression pool. radiation monitors Suppression pool temperature 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)1and (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
-- 5 0. 4 9. :These files are available.for NRP audit.
We also believe that Quad Cities Units 1 and 2 can continue to operate without undue risk to
.the public1 health.and. safety based on the present status-of the equalificaton program and justification for continued operation as provided
'in References--(a) and (b).
,It-is therefore requssted that a. final Safety Evaluation Report
.be issued to indicate'that Commonwealth Edis~on's Quad Cities Environmental Qualification Program,1 as. described in this letter and enclosure, meets the requirements 1of :10 CFR 50.49 and that the deficiencies.noted in the
'SER. dated January 18, 1983 are considered resolved.
If there are any questions yourmay have regarding this matter,.
.please address-them=to this office.
..One signed original and. forty (40) copies of'this letter is provided-forfyour use..We have enclosed : ten (10) copies of the enclosure
.tojthis. letter._.
-Very.truly yours,
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B. Ryba
. Nuclear l Licensing A inistrator
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NRC Resident Inspector <- Suad Cities
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g C00910NWEALTH EDISCH 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 Bour Minimum Operating Time Margin C.
Containment Transient Margins D. ' Aging and Qualified Life E.
Maintenance and Surveillance F.
Installed TMI Action Plan Items C.
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.. Containsment Transient Margins IV.
SPECIFIC EQ DEFICIENCIES NOTED IN TER/SER A.
Cable B.
Differenti.al Pressure Indicating Switch C.
Differertial Pressure Transmitter D.
Distritition Panel, 125 V de E.
Electric Air Bester i
F.
Electrical Penetrations G.
Flow Switches H.
Flow Transmitters I.
Hydrogen Sensors 1
-J.
Level Indicating Transmitter Switches K.
Level Switches
-L.
Level Transmitters i
M.
Local Control Panels N.
Local Panels 0.
Monitors, Acoustic I
P.
Motor Control Centers, 480 V Q.
Motor Driven Pumps R.
Motor Exhaust Fans S.
Motor Operators l
T.
Position Switches U.
Pressure Switches V.. Pressure Transmitters W.
Radiation Detectors I. Room Coolers (Fan Motors)
T.
Switchgear, 4.16 kV
.AA. Temperature Elements l
'BB. Temperature Switches CC. Terminal Blocks DD. Oils and Greases
t I*
GENERIC ENVIROINENTA1 QUALIFICATION ISSUES A.
Compliance With 10CFR50.49(b)
Paragraph (a) of 10CFR50.49(b) requires that each licensee establish a c program to. environmentally qualify electrical equipment. 10CFR50.49(b) groups this equipment into the following three categories:
- 1) Safety related electricals 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-accident monitoring equipment The followisig discussions present the methodology used to identify all electrical equipment falling within the above three categories:
10CF150.49(b')(1) Safety-Related Electrical Equipment All design basis events such as loss of coolant accident and main steam line breaks inside contatassent and high energy line breaks outside contai ment were reviewed.
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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
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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 pneumatie valves, temperature switches, limit
.s 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 sy' stem 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 oss performed as necessary. Plant emergency operating procedures were used as a guide to identify
, devices and display instruments required to be used by the operator.
. 'this equipment was also added to the master list of electrical equipment.
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h equipment which must remain functional in these systems was identified by review of system descriptions 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 envirossental qualification.
Plant areas 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.
Containement 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.
h oe 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 schematics, wiring diagrams were revieued as necessary to identify connection types, terminal blocks, etc., which support electrical 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.
i h methodology used by the licensee to identify electrical equipment which requires environmental qualification is in full compliance with the requirements of ERC I E Bulletin 70-01B 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 10CF150.49(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 antisfactory accomplishment 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 summarized below:
1-2
g A master list of electrical equipment requiring environmental qualification was developed in accordances with 10CF150.49(b)(1) and the requirements of NEC I.R.Bulletin 79-015. This equipment is required to
. provide safe shutdown and to mitigate the consequences of design basis accidents such as a loss of coolant accident or main steam line break inside containment and high energy line break outside esontainment. The licensee's generic position (described previously) with respect to compliance with 10CF150.49(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 mitigation and safe shutdown. A system
' failure analysis was performed ~ on each safety-related system to identify the set of equipment requiring environmental 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 interaction and operation of equipment with each safety system. This failure analysis identified all auxiliary systems and equipment which were necessary for the required operation of the safety-related system or equipment. This effort included review of the plant safety analyses, technical specification, emergency operating procedures, piping and instrumentation diagrams, schematics, wiring diagrams,' electrical one line diagrams and control logic diagrams. The entire instrument loop associated with each identified instrument was reviewed to identify any other components whose function could adversely affact operation of the I
l equipment required to remain functional. A small number of equipment l
items were identified as potentially affecting the performance of the equipment required to remain functional. These items were added to the equipment qualification master list and were subsequently qualified under the equipment qualification program, therefore eliminating the potential for affecting or degrading system performance.
l 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 accomplistement of required safety functions by the safety-related equipent. 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 10CF150.49(b)(2).
10CFR50.49(b)(3) Certain post-Accident Monitoring Equipment Paragraph (b) (3) of 10CF150.49 includes in its scope "certain post-accident monitoring equipment." Specific guidance parameters to be monitored is provided in Regulatory Guide 1.97 Revision 2.
The licensee's generic position with respect to this issue and the methodology that was used to identify equipment that falls within this category is presented below.
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..g D'isplay instrumentation is currently included as an integral part of the qualification program in accordance with requirements established by NRC IE Bulletin 79-015. h identified display instrumentation was evaluated in the M C SER/TER review, and System Component Evaluation Work Sheets (SCEWS) for this equipment have been developed. h detailed systems review and development of the master list of electrical equipment requiring environmental qualification provided justification of equipment additions or deletions from the master list as necessary on a case by case basis.
h licensee's methodology used to identify display instrumentation has been previously described in Section 10CFR50.49(b) (1) (above). Equipment that currently falls within the category classified as certain post-accident 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. N oe are identified in the plant Energency Operating Procedures and are used by the operator to diagnose system failure to perform safety functions. This equipment is incorporated into the qualification program in accordance with the requirements of R C II Bulletin 79-01B 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).
At this time, the following activities have not been completed by the licensee: h detailed Control Room Design Review; the revision to the Plant Emergency Operating Procedures based on the results of the control room design review and the. Regulatory Guide 1.97 revision 2 review; the response to NRC concerning compliance with Revision 2 of Regulatory Guide 1.97,
" 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 Iassons Imarned Implementation (NURGE-0737) in accordance 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.
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 program.
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g B.
Una Bour Minimum Operating Time Margin In _ order to account for various uncertainties inherent in equipment qualification test programs, the NRC criteria for qualification incorporated a one-hour miniana 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 D0R 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.
Subsequently, the NRC issued Generic letter 82-09 which stated that equipment may be qualified using the required operating time plus an appropriate margin, however, subsequent failures must 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 EUIEG-0588. In addition, the one-hour time margin is not applicable to equipment whose safety function is performed prior to significant changes in the enviroment. 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 hour in excess of the required equipment operating time unless a time margin of less than one hour can be justified. This justification must include:
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consideration of a spectrum of line breaks; potential need for use of the
. equipment later in the event; determination that failure of the equipment after the required operating time interval will not degrade safety function or mislead 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.
SCO'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 l
data and analysis used to demonstrate qualification of equipment envelop the required design operating time plus one-hour margin or an appropriate margin l
properly justified in accordance with NRC criteria. This issue is therefore l
considered resolved.
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-C.
.Containsent Transient Margins For Dresden and Quad Cities Stations, General Electric performed a drywell temperature analysis based on a main steam line break. h analysis considers main steam line break inside the drywell with break areas of 0.01 and 0.75 2
ft.
the peak temperature was calculated 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. h analysis performed for CECO (GE Report ESEO-52-0682) is based on a main steam line break with adequate margins. The margins include conservative decay best values, beat transfer coefficents, valve closure times and flowrates. h analysis will, therefore, supercede Appendix A, Figure A-2V and A-3 of the TER. This report was transmitted to the ERC by letter, Mr. T. Rausch to Mr. B.R. Denton, dated January 25, 1983.
D.
Aging and Qualified Life h ERC 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 related degradation which could affect performance of design safety functions. A qualified (designated) life should be established for equipment susceptible to significant aging based on engineering evaluations and judgment. Maintenance, surveillance and equipment or component replacement intervals should be based on the established qualified life so 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, establistument of ongoing programs to review surviellance and maintenance activities to identify equipment exhibiting age related degradation.
Arrhenius techniques are generally considered acceptable for assessment of l
~ N ws1 esing. These requirements are also implicitly established by ITTIJ0.49 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 of IEEE-323 (1974) must be applied and the equipment must be preconditioned prior to testing. Methods for compliance with established criteria are presented below.
For installed equipment, the licensee has identified electrical equipment l
whose materials are susceptible to significant age related degradation. A goalified (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:
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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 bills of material, material information, and technical data to identify age sensitive materials; review and engineering evaluation of industry references and technical literature to determine material radiation l
l threshold and thermal withstand capabilities; and engineering analyses to establish a reasonable qualified life and justified replacement schedule.
Calculations, assumptions, technical data and. references were incorporated l
into the respective equipment qualification 6cumentation. h results of the.se evaluation and analyses are incorporated into the existing plant maintenance and surveillance program to ensure that equipment qualifiction is maintained. Rased on these considerations, the licensee fully complies with the aging and qualified life criteria presented in the DOR guidelines.
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Nhen currently installed equipment (qualified to the DDR guidelines) is replaced, the new equipment will be qualified in accordance with the aging and qualified life criteria presented in 10CFR50.49, Section e(5), NUREG-0588, Revision 1 Section 4 and Regulatory Guide 1.89, Ravision 1. Section 7, unless there are sound reasons to the contrary to preclude upgrading. For this e
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 program are incorporated into the existing plant maintenance and surveillacce program to ensure that equipment qualification is maintained.
With respect to synergistic effects, the licensee recognises the limitations in the state-of-the-art; therefore, synergisms were not addressed unless known 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 Reguistory 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 for 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 D01 guidelines and 10CF150.49 require that on-going programs be implemented to establish and perform maintenance, surveillance, and equipment (or component) replacement activities for safety-related electrical equipment to ensure that equipment qualification is maintained on'a continuing basis.
l The program must incorporate the established values of designated life for l
equipment considered to be susceptible to significant aging. The licensee's j.
methodology, with respect to compliance with NRC criteria, is summarized below.
l To assure the continued qualification of installed equipment, Ceco has initiated a Qualification Maintenance Program. This program takes specific environmental qualification related surveillance and maintenance requirements and integrates them into existing surveillance, maintenance and testing programs. It was decided to take this approach, rather than to establish an independent program to take full advantage of these existing programs and the people that make them work.
l For each type of environmentally qualified equipment, a loose leaf binder is l
being prepared which contains all of the qualification documentation and specific EQ related surveillance and maintenance. Engineering and station personnel will review these binders and incorporate any qualification requirements into station surveillance and maintenance procedures or develop l
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 l
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establishes the date of the next surveillance and maintenance activity once 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 er working on an EQ piece of equipment. When EQ related surveillance and maintenance work is completed, this information will be entered into our computerised 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 i
manufacturer's recommendation.
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 personnal are also being involved in this program to assure an adequate supply of replacement parts.
Throagh the use of our recently modified Work Request form, we are establishing a mechanism tc upgrade qualification whenever equipment replacements are required. The company is developing its Qualification Maintenance Program based on two policies. When replacement parts are 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 Ouidelines or to CAT..II must be replaced it will be replaced with a component qualified to NUREC-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 manufacturer'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 maggered 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 operating personnel. To these ongoing surveillance and maintenance 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 Maintenance 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 recommendations and our operating experience. At the time of each check as-found and as-lef t data is recorded and transmitters beyond prescribed limits are recalibrated.. Transmitters requiring frequent recalibration beyond prescribed limits are replaced. During cali'uration checks each unit is 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 vill 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 maintenance, surveillance and testing program. To support this program we are taking steps to assure adequate supply of replac ment parts and components. The computerised General Surveillance Program provides an audible link of work performed and the Maintenance History File provides the potential to detect age related degradation.
l Based on the above considerations, the licensee concludes that the activities conducted thus far on environmental qualification, and the current development of a maintenance and surveillance program for electrical equipment requiring environmental qualificaton fully complies with the requirements of the DDR guidelines and 10CFR50.49 regarding maintenance and surveillance.
F.
Installed TMI Action Plan Items NMEG-0737 " Clarification of TMI Action Plan Baquirements" established actions to be taken by licensees regarding TMI Imssons Imarned Implementation. MRC IE Bulletin 79-01B, Supplement 3 Item 2, requires environmental qualification of
. installed electrical equipment 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 monitoring equipment" has been previcusly 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 Eulletin 79-01B, Supplement 3 and 10CFR50.49 qualification requirements.
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C.
Correspondence 1.
Correspondence to RC D. Peoples to J. Esppler - D, QC, QC2 Master Lists 03/04/80 3
1 F. Janacek to J. Esppler - QC, QC2 initiel response 04/22/80 1
IE Bulletin 79-01B Response D e D, QC, QC2 06/10/80 2
3 1
Revised IE Eulletin 79-01B response D2 08/22/80 J. Abel to J. Emppler - D, rC, 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 B.Denton' TER Response D. D, QC, QC2 09/04/81 2
3 1
TER Response Supplement QC, QC2 02/03/82 1
TER Besponse Supplement D3 02/23/82 TER Response Supplement D, D, QC, QC2 - YMI Equipment 04/29/82 2
3 1
E. Schwarts to D. Eisenhut - TMI Action Plan Equipment Qualification 08/02/82 T. Rausch to B. Denton - CE Dryuell Analysis 01/25/83 T. Rausch to H. Denton - Reaffirmance of JCOs 02/01/83
- 3. Ryback to B.Denton - Proprietory Meterial 02/14/83 B. Ryback to B. Denton TER Response D, D, QC, QC2 04/04/83 2
3 1
B. Ryback to H. Denton - 10CFR50.49 05/19/83 Response D2 D, QC, QC2 3
1 C. Reed to H. Denton - R.G.1.97 and C.L. 82-33 11/15/83 Commitments 2.
Correspondence from NRC IE Bulletin 79-01 02/08/79 IE Bulletin 79-01A 06/06/79 J. Kappler to C. Reed IE Bulletin 79-01B 01/16/80 R C 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 D, QC1 QCg 08/29/80 Staff Orders D s 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. Iainas to J. Abel - Partial MRC Review Dresden 2 02/13/81 T. Novak to J. Abel - Partial NRC Review Dresden 3 04/01/81
.T. Ippolito to J. Abel - NRC SEE-QC, QC2 06/03/81 1
T. Ippolito to J. Abel - MRC SEE-D3 06/03/81 D. Crutchfield to J. Abel - ERC SEE - D2 06/10/81 CL-82-09 04/20/82 Memorandum to D.Eisenhut from P.0'Connor - JC0 Evaluation 10/19/82 D. Crutchfield to L. De1 George ERC SEE-D, D3 12/29/82 2
D. Vassallo to L. De1 George - ERC SER-qc1, QC2 01/18/83 I-10
II.
70'SITIONS CONSIDERED CLOSED A.
EQUIPMENT PLACED IN NRC CATEG0KY 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, E 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 79-01B 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 (BELB) 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 equipment. A subsequent examination of plant operating experience, vendor information, industry standards, regulatory criteria, and potential failure mechanisms for equipment 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.
1 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 i
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, ventilating, and air conditioning (HVAC) system, or operation of equipment required l
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 i
temperature from the normal temperature to the maximum of 120F will be gradual. The resulting applied stresses on the equipment are relatively low and well within the maximum stress level capability of the equipment which is conservatively designed, fabricated, and installed as supported by equipment design specifications and manufacturers' data. Operability of similar equipment in such mild 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 i
evaluations or documentation are necessary to ensure that this i
equipment will perform its safety function.
II-1 L
-m.
,,,_.m.,
,_m._
G.
This justification was found satisfactory by Franklin in the January 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 can 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 1
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.
Temperature above 120 F 4 rads b.
Total radiation exposure above 5 x 10 c.
Pressure transient resulting from a LOCA or HELB inside the dryvell, the pressure suppression pool, and the main steam tunnel 2.
Qualification of humidity 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 dryvell, the pressure suppression pool, and the main steam tunnel; i.e., less than or equal to ata.ospheric 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.
II-2
~
TABLE 1
SUMMARY
OF QUALIFICATION METHODS Temperature Radiatior.
Mild ($120F)
Harsh (>120F)
Mild Ga5E04R)
Note a Note b Harsh (>5E04R)
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 qualified, 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, qualification testing, analysis, or by replacement with a fully qualified component. '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 ofz 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
Col 00MEALTH EDISON IIESOLUTION.0F ENVIRDIBENTAL QUALIFICATION SER AIID TER OPEN ITEM DEFICIElICIES FOR QUAD CITIES UNITS I AND 2 '
Ill. GEIIERIC DEFICIElICIES
~
Proposed Resolution Deficiency Reference A.
la many Instances, h IIconsee has cameltted TER, Section 5 A definitive schedule for h completion of corrective actions in compliance with IBIC
- ta replace equipment during a refueling outage Page 5-1 SER requirements has been established. The schedule for completion of corrective action fellowing receipt of the quellfled components was reflected in Section 1.3 of h Individual component sumeery_ sheets in Attachment i
.onsite. It is concluded h t h licensee has to h Dresden and Quad Cities TER responses for components in HRC Categories 1.8, not provided a definitlwe schedule for the
.fl.A, and 11.8.
h schedule was also reflected in h May, 19, 1983,- transmittal from-completion of corrective actions in compilance
- 8. Rybak to H. Denton.as required by IJ CFR 50.49
. with 15tC SER requirements.
' 8.
It appears h t h licensee has not resolved TER, Section 5 The resolution for this item is provided in Section 1 of this enclosure.
the 15tC concern regarding mergins applied to Page 5 W In-contalrunent temperature profile j
C.
Appendix D of W TER discussed concerns which TER, Section 5 Appendix 0 concerns were addressed in h 30-day response letter, Mr. T. Rausch to require resolution with regard to temperature Page 5-2 Mr. H.R. Denton, dated February I 1983. In addition, h temperature switch component switches and solenoid valves.
summary sheets were included in Abachment I to the Dresden and Quad Cities TER responses. Verbal approval of h February 1, 1983, submittel on justification for continued operation (JCO) was given to 8. Rybak from R. Gilbert on February 1, 1984.
It is r % elth Edison's understanding h t formal acceptance of this JCO will be glwen in h safety evaluation report.
i I
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l 0493c I11-l
C01040NWEALTH'EDISCH' RESOLUTION OF EleVIR010ElfTAL QUALIFICATl011 SER ANIfTER OPED ITEM DEFICIENCIES FOR QUAD CITIES UNITS I AND 2 LEGEIS:-
QCl.= Quad Cities Unit I i,
QC2 = Quad cities Unit 2 Ilone = Ito deficiencies noted or SCEWs provided subsequent to IstC review by FRC IV. SPECIFIC EQUIPIElfT EO DEFICIE11CIES 1
Description-(Manufacturer, 154C FRC lten Ilmber Model. Etc)
Category Deficiencies Proposed Resolution A.
ELECTRICAL CABLE QCis-49 General Electric 1.8 Documented evidence'of quellfication Testing and analysis had not been performed on this cable at h QC2: IIone cable Model SI-57275; inadequate time of h TER/SER review; hrefore, quellfication documenta-Vulkene insulated tion was noted as being inadequate by FRC. Qualification defici-i switchboard wire encies for qualification time, meterial aging, humidity, temperature, pressure, and radiation were originally to be resolved by type testing. However, prior to testing, EDS teuclear evaluated Wyle Test Report 44114-2 and concluded h t h qualification deficiencies for pressure, radiation, and relative 4
humidity could be resolved by h t test r t, and W remaining deficiencies could be resolved by an anal is utilizing Arrhenius methodology to extrapolate h test resul s.
All deficient parameters were satisfactorliv quellflod by Wyle Test Report i
44114-2 and EDS Analysis Environmental Qualification of General ElectricSI-57275ElectrIcalCableReport 04-0590-69, Rev 1, i
October 7, 1983. Therefore, h se quellfled components should be in NRC Category 1.A, Equipment Qualified.
QCIA51,53,55, General Electric and I.B -Documented evidence of qualification Testing and analysis had not been performed on this cable at h 56 Simplex cable; butyl inadequate time of the TER/SER review; hrefore, quellfication documenta-QC2: None rubber-Insulated with tion was noted as being inadequate by FRC. Qualification defici-PVC jacket; power and encies for qualification time, meterial aging, humidity, tempera-control functions ture, pressure, and radiation are being resolved by type j
testing. Prior to testing, it was determined that h form j
"Anhydrox XX" (identified as W Insulation meterial in QCl Item 56) was W Simplex nues for h ir butyl rubber insulation.
Because SCEWs existed for Simplex butyl rubber-Insulated cable, all references to cables with Anhydrox XX insulation have been i
deleted from the quellfication program to eliminate unnecessary i
duplication. All deficient parameters have been qualified by Wyle Test Plan 45916-03, Final Qualification Plan for Various t
Power Control and Instrumentation Cables. The test report is to be issued in February 1984, Subsequent to N January 26, 1984, meeting with h NRC staff, i
the final test report was issued. Final quellfication of these cables has been established. All tested cables are qualified for j
h ir Intended service. However, h GE butyl cable located in h stems tunnel is not quellfled for h 40-year plant life.
4 This cable will be replaced before h end of its designated life In accordance with h plant maintenance program. Therefore, h se qualified components should be in IW4C Category 1.A.
j Equipment Qualifled.
1 i
j 0494c IV-1 4
I V.' Specific Eautoment EO Defielencies (continued)
Description (Manufacturer, 15tC FRC lten llumber Model. Etc)
Catenorv Deftelencies Proposed Resolution A.
Electrical Cable (continued)
QCI: 54 General Electric cable; 1.8 Documented evidence of qualification Testing and analysis had not been performed on this cable at h
- QC2 None cross-linked poly-Inadequate time of h TER/SER revlow; h refore, qualification documentation ethylene (Vulkene)-
was noted as belr.g inadequate by FRC. Qualification deficiencies
. Insulated with PVC for quellfication time, material aging, humidity, temperature, Jacket; control pressure, and radiation were originally to be resolved by type functions testing, engineering analysis, or repi m t.
O w lth i
Edison has reviewed a comparison anal sls conducted by EDS EnvironmentalQualificationofGenerafElectricSI-58743and SI-58281 Electrical Cables, Report 04-0590-50, Rev 0, a
November 18, 1982. Although h analysis states h t h cables are quellfled, Connonwealth edison has determined that a more t
detalled analysis to establish similarity to previously tested 4
General Electric specimens will be conducted to fully document quellfication. If this analysis cannot demonstrate quellfication In Ceco's judgment, h cables will be type tested or replaced.
I QCI: 50 Simplex cable; poly-1.8 Documented evidence of quellfication Testing and analysis had not been performed on this cable at h QC2: None nylon-insulated single /
Inadequate time of the TER/SER reviews h refore, qualification documentation multipair instrumen-was noted as being inadequate by FRC. Quellfication deficiencies i
tation cable
. for quellfication 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 W polynylon-insulated cable
^
have been deleted from W 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.
Subsequent to N January 26, 1984, Final qualification of h se meeting with h NRC staff, h first test report was issued.
cables has been established, and they are quellfled for their intended service for the remaining 30 years of plant life.
Therefore, these quellfied components should be in 15tC i
Category 1.A, Equipment Qualified.
1 i
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i 0494c IV-2 1
IV. Soecific Eaulsenent EO Defielencl~t (continued)-
Description
-(Manufacturer, 151C FIIC lten llueber Model. Etc)
Cateaorv Deficiencies Procosed liesolution A.
Electrical Cable (Continued)
QCI: leone Simplex cable; three- -
IIA. None Qualification deficiencies for qualification time, meterial ag'I QC2: leone conductor twisted with humidityfesting. temperature, pressure, and radiation are to be resol overall shield; instru-by type All deficient parameters have been quellflod by mentation wire Wyle Test Plan 45916-03, Final Qualification Plan for Various Power, Control, and Instrumentation Cables. The test report is 5
to be Issued in February 1984.
Subsequent to h January 26, 1984, meeting with h INIC staff, h first test report was issued. Final qualification of h se-cables has been established, and b y are quellffed for their Intended service for h remaining 30 years of plant life.
1 Theref we hse qualIfled components should be in INIC Category I.A, Equipment Qualified.
I B.
DIFFERENTIAL PRESSURE AND llIDICATileG SWITCHES QCI: 32 Barton 289 1.8 Documented evidence of quellfication h se < = panents were scheduled for replaca= ant; however, no QC2: 32 Inadequate quellfled replacement was identified at h time of h TER/SER i
review. h refore, documented evidence of quellfication was Indicated as inadequate. They will be replaced by quellflod flosemount Model l153, Series B transmitters. Quellfication is required for temperature, pressure, humidity, and radiation during post-accident conditions. Rosemount has tested its Model 1855 Series 8 transmitters and provided h quellfication 1
1 documentatIoninTestReport 108025, Rev B, dated February 1983.
h report has been reviewed and evaluated and found to quellfy l
W transmitters for h required conditions. The quellfied life of h Model 1153, Series 8 transmitters has been determined by l
Rosemount to be 20 years; h refore, h se ca=panents will require replacement after this period. These quellflod i
reptar===nt components should be in IIRC Category 1. A, Equipment Qualifled.
I QCI: 35 Barton 288 1.B Documented evidence of qualification h se ca=paments were scheduled for replae== ant; however no QC2: 35 Inadequate quellflod repime===nt was identified at h time of h YER/SER review. b refore, documented evidence of quellfication was Indicated as inadequate, b y will be replaced by quellfled Rosemount Model 1153, Series B transmitters. Quellfication is required for temperature, pressuro humiditybstestedits and radiation p
during post-accident conditions.
.-r ---t i
Model 1153, Series B transmitters and provided W quellfication documentation in Test Report 108025, Rev 8, dated February 1983.
i h report has been reviewed and evaluated and found to quellfy the transmitters for h required conditions. The quellfled life of the Model 1153, Series B transmitters has been determined by i
Rosemount to be 20 years; h refore, h se ca=panents will j
require replacement after this period. These quellfled i
replacement cesponents should be In 154C Category I.A, Equipment j
QualIfled.
i 4
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J 0494c IV-3 l.
5
-~
IV. Specific Eeulement E0 Defielenclo= (continued)
Description
-(Menufacturer, ISIC
. FRC lten ihmber Model. Etc)
Catenory Deficiencies Procosed Resolution
' C.
DIFFEREllTI AL PRESSURE TRNISMITTERS D.
DISTRIBUTION PMIELS
'QCI: 44 Cutler-Hammer I.B Documented evidence of quellfication Qualification deficiency was identified as h radiation parameter
-QC2: 44 Inadequate and was originally to be resolved by analysis and/or testing.
This deficiency was appilcable because h se panels had not been quellflod to a harsh radiation environment.
- d x ; -.tly, W approach adopted for quellfication was a ceabination of analysis and testing. Bechtel performed an engineering analysis (Chron 7332) for nonmetallic components except h oe associated with h circuit breaker. This analysis Indicated h t all these nonmetallic e panents had radiation damege thresholds in eweess of N required radiation environment. A radiation test was conducted by Wyle for h breakers, and Wyle Test Report 45917-3 was evaluated. h deficiency is resolved by this analysis and h test report. These items are fully quellflod to all environmental parameters. Therefore, h se quellfled em paments should be in ISIC Category 1.A, Equipment Quellfled.
E.
ELECTRIC AIR HEATERS i
QCl 59 Chronolox l.B Documented evidence of quellfication h se heaters are used as e= =an equipment for both h Quad-l-113462/2-113462 Inadequate Cities Units I and 2.
This equipment was originally scheduled i
for replacement with a quellfled heater because h quellfication was not estabilshed at h time of TER/SER review. Radiation was the only harsh environment requiring quellfication; therefore, all N meterials were reevaluated to determine whe h r quellfication could be established by analysis. Subsequently W unit was quellflod by Engineering Analysis for 18onnotallic, j
r=.rts, Bechtel Power Corporation, July 8,1983 (Reference 3 of I)ualification Package 06.C332.01). Therefore, h :e quellfled '
components should be in IIRC Category I.A, Equipment QualIfled.
1 i
4
IV. Specific Eaulament'E0 Deficiencias (continued)
Description
-(Manufacturer.
ISIC FRC lten llumber Model. Etc)
Cateoorv Deficiencies' Proposed Resolution i
F.
ELECTRICAL PElIETRATICIIS
+
QCI: 52 General Electric
_II.A ;Doctamented evidence of quellfication The original documentation submitted during h TER/SER review was GE-IIEBS
. Inadequate incomplete because of h ongoing data search for h se penetra-QC2: Blone NA leone tions. Quellfication was required for all h accident and-norinal environment parameters inside h drywell. i ;; nt to W submittal of h TER response, environmental Information study, Report EldA-EAF98-94, was received frun General Electric (GE) along with ano h r report dated May 30, 1972 for h 4
electrical tration assedlies susenery data. Yhesereports as well as Itaport F-01 (April 30,1971), GE Report 994-75-0ll (April 29, 1975) and a special report for an Incident at Dresden Unit 2InJunelh70,havebeenreviewedandfoundtoadequately qualify these penetrations for h norinal and accident environment. h se electrical penetration assemblies contain metallic as well as nonmetallic meterials. Deterioration due to h nnel aging is Insignificant for nonorg mic and metallic 4
meterials under h specified environmental conditions.
h refore, e = panent aging is based on organic meterials. GE j
Report 994-75-011 demonstrates a cycling and aging test te simulate a nuclear power station startup and shutdown cycle.
This 100F temperature change and 120 cycle test is consistent with the requirement of IEEE Standard 317-1976 even though this standard was not in effect at h time of h quellfication i
test. Because h penetration assemblies successfully withstood the cycling and aging test, which represents significant thermal stressing, h aging quellfication is considered supportable by 1-this test. In addition, h penetration assemblies can be considered to have a remaining quellflod life of 30 years. This conclusion is based on h meterial analysis of h age-sensitive meterials used in h F01 canister design electric penetrations (GE Report EldA-EAF98-94), hir location within h assembly
}
(which is not subject to extreme temperature and radiation i
degradation), and h fact that h se assemblies continued to i
function during and subsequent to h June 5, 1970, depressurization Ir.::Ident. This 30-year quellfled life requires h t periodic maintenance and surveillance procedures be established and implemented. Survelliance procedures are being i
developed to detect e = =an-mode failure mechanisms. If 1
unidentlflod aging or degradation mechanisms become apparent, upgraded replar== ant or maintenance programs will be developed to I
address h se concerns.
Based on h above reports and h followup meetings with GE and h fact h t h y did perform satisfactorily during the June 5, 1970 incident, 17 Is concluded that h se penetratTons are quellfled. h refore h se quellfled components should be in IIRC Category I.A, Equlpment Quellfled, t
i i
l 0494c IV-5 i
l
IV. Soecific Eaulement E0 Deficiencies (continued)
Description Utenufacturer,.
-ISIC
- FHC lien llumber Itodel. Etc)
Categorv Deficiencies Proposed Resolution G.
FLOW SWITCHES QCI: II' Barton, 289 1.8, Documented evidence of quellfication h se campanents were scheduled for repimeamant; however, no
'QC2: 11 Inadequate qualIfled repIac== ant was IdontIfled at h time of h.TER/SER review, hrefore, c cumented evidence of quellfication was.
Indicated as inadequate. h y will be replaced by quellfled l
Rosemount Model 1153, Series 8 transmitters. Quellfication is required for post-accident radiation only. Rosamaant Test 1-Report 108025, Rev B, dated February 1983, has been evaluated and i
found to quellfy h Rosemount Model l153, Series B transmitters for the normal service conditions and h postulated post-accident radiation at h Quad Cities units. h Installed l
operational life of h Model 1853, Series 8 has been determined by Rosemount to be 20 years; therefore, these cogonents will require replacement at the end of this period. These quellflod repl=e== ant components should be In ISIC Category I.A, Equipment Quellfled.
QCl 63 Marcold, DA5333 1.B Documented evidence of quellfication h se components were scheduled for shleiding or replacement, and inadequate qualification was not avallable at h time of the TER/SER review.
Therefore, h documented evidence of quellfication was considered Inadequate by FHC. Quellfication was required for post-accident radiation only. h shielding design for these c-panents has been completed, and h radiation environment is i
now mlId. h refore, h se components shoutd be in IEIC Category ill.8, Equipment Isot in the Scope of the Review.
j H.
FLOW TRANSMITTERS QCI: 10,31 General Electric l.B Documented evidence of qualif'estion At the time of TER/SER review, hse components were scheduled for QC2: 10,31 GE/MAC 553 Inadequate ol h r testing or analysis. h decision was mede to test h component for radiation because redletion caused by a design basis accident is the only harsh environment to which these components are ever subjected. Subsequently, the GE/MAC 553 transmitters were tested by Wyle Laboratories. Qualification was provided in Wyle Test Report 45917-1, July 30, 1982. Review and i
evaluation of the test report revealed that these e =ranents are quellfled for h required conditions. h refore, these i
quellfled campanents should be in IIRC Category l.A, Equipment l
QualIfled.
QCI: 61 Leeds And IIorthrup 1.8 Documented evidence of qualification This component was originally scheduled for replaeamant; however, 000-0300-0300 Inadequate no qualified replae== ant was identified at the time of TER/SER i
review. W refore, documented evidence of quellfication was Indicated as inadequate. Subsequently, It was determined h t j
this ca=panent would perform no safety-related function. It j
provides only flow Indication for the SGTS and does not provide j
any control function. The required control function for N system is provided by FSL I/2-7541-8A,B and -35A,B.
Therefore, this component should be in NRC Category lit.A, Equipment Exempt 1
from Qualification.
i 0494c IV-6
IV. Soecific Eaulement EO Deficiencia (continued):
. Description (Manufacturer, 15tC
. FIIC lten Nueber Model. Etc)
'Cateeorv Deficiencies
' Proposed Resolutica LI. HYDIIOGEN SEllSORS gg,,,
J.
LEVEL-INDICATilIG TRANSMITTER SWITCHES
.QCI: 42.
.Yarway 4418C and 4418CE I.8 Documented evidence of quellfication hse components were scheduled for repl=e== anti however no.
i QC3: 42 Inadequate-qualified repl=e===nt was identified at the time of h IER/SER '
review. Therefore, documented evidence of quellfication was Indicated as inadequate. They will be replaced by quellflod Rosemount Model 1153, Series B transmitters. Qualification is required for post-accident radiation only. Itosemount Test Report 10802'>, Rev 8, dated February 1983, has been evaluated and found to qualify h Rosemount Model'l153, Series B transmitters for N normal service conditions and h postulated post-accident radiation at Dresden and Quad Cities units. The quellfied life i
of h Model 1153, Series B has been determined by Rosemount to be 20 yearsi hreforv, hse components will require replacement i
at h end of this period. h qualified replacement < = panents should be in NRC Category I.A, Equipment Quellfled.
K.
LEVEL SWITCHES QCI: None Magnetrol 291 NA None N se components were originally considered to be in a mild j
QC2: None area; W refore, h y were deleted from W quellfication Later it was found h t h se components would be program.
subjected to a b sh temperature environeent for a short period of time during a LOCA. These ca=panents were previousiv tested, and the test results are provided in Wyle Test Report 43235-1, May 2, 1977. This report has been reviewed and evaluated and i
found to encompass N required time and temperature environment l
for Quad Cities units. Therefore, these quellfied components should be in 154C Category 1.A, Equipment Quellfled.
l L.
LEVEL TRAllSMITTERS M.
LOCAL CONTf4DL PAIIELS l
QCI: 65 Harlo, DRAW-D/297 1.8 Documented evidence of quellfication h se components were scheduled for replacementi however, no inadequate.
quellfled replacement was identified at h time of h TER/SER review. Therefore, documented evidence of qualification was indicated as inadequate. These panels are required to be quellflod for radiation only. A review of possible repI=e== ant panels on the market revealed that none were quellflod to meet h required radiation dose. Therefore the panels will be physically shielded to reduce h ir red lation dose to that of a mild environment. h panel shielding will be completed by March 1985. Therefore the shielded panels should be in 154C i
Category 111.8,EquipmentNotintheScopeoftheReview.
i i
i 0494c IV-7 1
i i
'IV.
Saecific Eaulement EO Deficiencies (continued) i Description FHC lten llumber.
(Manufacturer,
.15tC 4
Model. Etc)
Cateeorv Deficiencies Proposed Resolution
. N.
LOCAL PANELS-Ilone 0.
MONITORS, ACOUSTIC QCI: leone NDT Instruments 1.8 None, pending modifications This equipment Item has been removed from the environmental QC2: 104 Model 400A quellfication program pending completion of h following items 3
preampilflers
- a. Detalled control room design review
- b. Response to ISIC concerning compliance with Regulatory Guide 1.97, Rev 2
- c. Determination of electrical equipment located in harsh envi-ronments required for TMl lessons-learned Implementation (NUREG 0737) In accordance with IE Bulletin 79-018, 1
Supplement 3, item 2 Further details are included in Section I of this enclosure, P.
MOTOR CONTROL CENTERS QCI: 45 General Electric 1.B Documented evidence of quellfication Qualification deficiency was identified as h radiation para-QC2: 43 7700 Series inadequate meter and was originally to be resolved by analysis and/or i
testing. This deficiency was applicable because these MCCs had not been quellfled to a harsh radiation environment. Later, h quellfication was selected to be by h method of testing. A catelled walkdown of h MDCs was completed to identify the specific e =rw=mnts of each MCC. An investigative study was j
undertaken to properly select h e = panents to be included in h test progree. h ee e= panents, which were obtained from W 4
stations with consideration for the vintage, were assembled into a test model designed to be representative of all MDCs. A radiation test was conducted for this model. Wyle Test Report j
45917-30 was evaluated. N deficiency is resolved by this test report, and this item is fully quellfled to all environmental parameters. hrefore, hse quellfled components should be In j
NRC Category 1.A, Equipment Quallfled.
4 j
Q.
MOTOR-DRIVEN PUIFS l
QCI: 2 General Electric 1.B Documented evidence of quellfication h quellfication of hse components was not estabilshed at h QC2: 2 5K6338XC23A Inadequate time of TER/SER review, and the components were slated to be quellflod for radiation during a post-08A operation only.
General Electric has provided quellfication documentation in its Report NEDC-30067/83NE0025 (February 1983) for h motors at Quad Cities. Based on h evaluation of h date In h se reports, W se motors are quellflod for h normal and h postulated i
j post-08A environmental conditions. h refore these quellfled componentsshouldbeinNRCCategoryI.A,EquIpmentQuellfled.
i t
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0494c IV-8 i
'lV.
Seecific Eaulement EO Defl*lencies (continued)
Description Utenufacturer, ISIC FilC lten thsaber Model. Etc)
Cateeory Deficiencies Proposed nosolution-O.
Motor-Driven Pumps (Continued)
QCI: 3
' General Electric 1.8 Documented evidence of quellfication
~ h qualification of h se m ts was not established at h QC2: 3 SK6336MC193 Inadequate time of TER/SER review, and h ca=penents were stated to be i
. qualified for radiation during a post-DBA operation only.
General Electric has provided qualification documentation in its Report NEDC-30067/8311ED025 (February 1983) for h motors at Quad Cities. Based on the evaluation of h data In these reports, h se motors are quellflod for h normal and h postulated post-DBA environmental conditions. h refore h oe quellfled ca=panents should be In 151C Category 1.A, EquIpsont Quellfled.
R.
MOTOR EXHAUST FANS QCI: 60 General Electric l.B Documented evidence of quellfication h quellfication of these - =-: _-.ts was determined to be inado-SK256BK2038 is inadequata quate at the time of h TER/ SIR review because quellflod replae== ants were not identified. h refore, h y will be replaced by quellflod liestinghouse motors. Quellfication is required for radiation only. Radiation qualification is.
j documented in tiestinghouse Test Report 1999112 dated January 1982. Review of the test report revealed h l h se fan motors are quellfled for the required radiation dose rate. h refore, hse qualified ca=panents should be in 151C Category I.A, Equipment Quellfled.
i l
i I
1 4
9 e
j-0494c IV-9
IV. Specific Eaulsenent E0 Deficiencies (continued)
S.. MOTOR OPERATORS Ilote: Resolution of identifled deficiencies for motors operators is complex because of N large number of different models involved and W verlety of environments encountered for which qualification is required. The cross-reference table below provides h plant identification numbers of h operators included in each FRC Item and references h specific deficiency and resolution for each operator. The numeric and letter entries of the cross-reference table correspond to deficiency and resolution descriptions that follow in continuation of W resolution table.
Unit 1 Unit 1 Unit 2 Deficiency Deficiency Deficiency FRC Valve Number Number Resolutions FRC Valve IksnLer Number Resolutions FHC Valve ilumber Number Resolutions 4 E l-1402-3A,B 3
D 25 E l-1001 16A BI 3
B.I, G 4
MO-2-1402-3A,B 3
D 4
D MD-I-100i-185k,B; 4
1, J 4
,D MD-I-1091-19A,B; 5
MD-I-1402-4A,8 3
B.1, G MD-I-1001-4A,B 5
MD-2-1402-4A,8 3
B.1, G 4
l, J
. MO-I-IO01-23A,B 3
B.4, G 4
1J 26 6
MO-1-1001-26A,B 3
B.4, G 4
H, 1, J 6
MO-2-101-26A,8 3
B.4, G 4
H, I, J 4
H, I, J 27 MD-t-1001-28A,B; 1
B.I 7
M0-1-1402-25A,B; 3
B.4, G MD-I-1001-34A,B 2
E 7 E l-1402-25A,8; 3
B.4, G MO-l-1402-24A,B 4
H, 1, J 3
G MD-I-1402-24A,8 4
H, I, J 4
1, J 8
MO-t-1402-38A,8 1
B.3 8
MD-2-1402-38A,B 1
B.4 2
E 28 MD-1-1001-63 1
A.2 2
E 3
G 3
G 4
H, 1, J 29 MD-I-1001-50 i
A.I 4
H, I, J 13 MD-I-2301-4 1
A.2 34 MD-I-1001-60 I
B.2 13 MD-2-2301-4 1
A.2 2
A.2 2
E 39 MD-1-1201-2 1
A.I 14 E l-2301-5 1
B.2 MD-I-1301-16
.I A.2 14 MD-2-2301-5 1
B.2 MD-t-1201-2 2
E 19 MO-l-220-1 i
A.2 MD-I-1301-16 2
A.2 19 MO-2-220-1 l
A.2 2
A.2 2
E 40.MD-I-1201-5 1
B.I 22 MD-I-1001-7A,B C,0 3
D 22 MO-2-1001-7A,B,C,0 3
B.1, G 4
D 41 MD-1-3706 i
A.2 4
1, J MD-1-3703 i
B.1 23 M0-1-1001-5A,B 3
B.4, G MD-1-3706 2
A.2 23 MD-2f-1001-5A,B 3
B.4, G 4
H, I, J MD-1-3703 2
E 4
H, I, J 24 MD-I-1001-18A,B 3
B.1, G 45 MD-1-3702 3
B.I. G 24 MO-2-1001-18A,B 3
B.1, G MD-I-1001-29A,B 3
B.4, G 4
1, J 4
1, J h l-1001-36A,8 3
B.1 MD-2-1001-29A,B 3
B.4, G E l-1001-37A,B 3
B.I 46 MD-I-202-5A,B 1
A.3 4
H, I, J h l-1001-18A,8 4
- 1. J MO-l-202-9A,B 1
C MD-2-1001-36A,B; 3
B.I. G MD-1-1001-29A,B 4
H,1 J MD-I-202-6A,B 1
C 4
1, J MD-I-1001-36A,B 4
1, J MO-2-1001-37A,B 3
B.1, G MO-1-1001-37A,B 4
1, J 68 MD-I-202-4A,B I
C 4
1, J 051ic IV-10
IV. Soecific Eaulpoent EO Deficiencies (continued)
Unit 2 Deficiency FRC Velve llumber '
Ilumber Resolutions 25 MO-2-1001-16A,B 3
B.1, G.
MO-2-1001-185A,8; 4
1, J MD-2-1001-19A,8; MD-2-1001-4A,B 26 MD-2-1001-23A,8
.3 B.4, G 4
H, I, J 27 MD-2-1001-2BA,8; 1
B.I, B.4 MO-2-1001-34A,8 (348 only) 2 E
3 G
a 4
H, 1, J 28 MO-2-1001-63 1
A.2 29 MO-2-1001-50 1
A.1 34 MD-2-1001-60 i
B.2 39 MD-2-1201-2 i
A.I 2
E 40 MD-2-1301-16 I
A.2 MO-2-1201-5 i
B.1 41 MO-2-3706 l
A.2 MO-2-3703 1
8.1 45 MD-2-3702 2
8.1, E 46 MO-2-202-5A,B 1
A.3 2
E MO-2-202-9A,B I
C 2
C M)-2-202-6A,8 1
C 2
C 4
4 j
0511c IV-Il
IV. 'Scecific Eaulement EQ Deficiencl^s (continued)
Description (Menufacturer, 154C FIIC lten llumber Model. Etc)
Catecory Deficiencies Prososed Resolution 9
S.
Motor Operators (continued) a
'QCI: 8,13,14,-
Limitorque Type SBS 1.B, I. Documented evidence of quellfication A. Limitorques inside the Drywell 19,27,28,29, ac motors: Peerless, ll.A, inadequate I) Operators inside h drywell with Type 8 motor Insulation, 34,39,40,41, Rollance, Limitorque, no motor breakes and operating times less than 2 minutes 46,68 de motor: Peerless, arebeingqualifIedutilizingTestIteportWCAP-7410L,
.Itellence supplemented by Bechtel hrmal Analysis IIUC-31, which QC2s 8 13 14' Limitorque Type SBS 1.B,-
demonstrates h t h operators complete h ir function 19,$7,$8,$9,acmotors: Peerless, ll.A before exceeding the WCAP-7410L test temperature.. Test 34,39,40,41 Reliance, Electric Report WCAP-7410L has been evaluated and found acceptable to Apparatus, Limitorque quellfy W se components to the required environment at Quad de motors: Peerless, Cities. Therefore, these components quellfled by h above Reliance test report and h analysis should be in 154C Category I.A, Equipment Quellfled.
- 2) All SIS-000 size operators inside the drywell and all operators with operating time greater than 2 minutes are being replaced with operators quellfled to LimI1rorque Test Report 600376. This test report has been evaluated and found acceptable to quellfy these components to h required environment at Quad Cities. Therefore, W se replacement components should be in IIRC Category 1.A, Equipment Quellfled.
- 3) Operators inside h drywell with short operating times and motor brakes will have replacement motors that do not require brakes. These replacement motors are qualified to Test Report 600376. Test Report 600376 has been evaluated 4
and found acceptable to quellfy these new motors to N required environment at Quad Cities. Therefore, h se operators with quellfled replae== ant motors should be In IIRC Category I.A, Equipment Qualifled.
- 4) This operator, located inside the drywelllng h WCAP-7410L with an Electric Apparatus motor is being quellflod utiliz test report supplemented by a statement from Limitorque that, for purposes of environmental qualification, h 1
Electric Apparatus motor is equivalent to a Reliance motor as used in the WCAP test. With the above qualification, i
this operator should be in IIRC Category 1.A, Equipment i
Quellfled.
i B. Lim 1 torques Outside the Drywell
{
l) Limitorque has stated by letter h t, for h purpose of l
equipment qualification, the Class B Insulation system of Dresden and Quad Cities de motors is similar to the ac motors quellflod in Test Report B0003. Test Report i
j 600461-80003 has been evaluated and found applicable to J
quellfy these operators to their environmental service conditions at Quad Cities, h refore, these operators should be in IIRC Category 1.A, Equipment Qualified.
i l
1
o IV. Specific Equipment EQ Deficiencies (continued)
' Description (Monufacturer, 15tC FRC lten llumber ModelLEte)
Cateeory Deficiencies Proposed Resolution
/
S.
Motor Operators (continued)
J
- 2) Operators in h steam tunnel and torus with short 3
(
0, operating times are quellfled by Test Report P0003 supplemented by Bechtel Thermal Analysis NUC-19. Yhe k)\\
/
3 3
analysis shows that h hrmally sensitive materials will p
r 4
not exceed h qualification test temperature in Test X;)
3 s
a i;
.?
Report 90003. Therefore, these operators should be In Inc
,{*
3-ir Category 1.A Equipment Quellfled.
+
f
- ,s
- 3) Operators wifh unquellflod motors,w1Il have replea= ant 1.. f
/
4 1
motors quellflod to the service condiflons and Limitorque 9
- 3 Test Report 600461-80003. Therefore, h se p lified
<4:
I replacements should be in NRC Category I.A, Equipment QualIfled.
,/
- 4) The motors'wlth brakes will be replaced'wlth new motors N
i that do not require brakes. The new motors will be quellfled to Roport 80003, or h operators will be
- I completely replaced with new eperators quellflod to ei ther 4
)
Test Regurt 600376 or B0003 depending on the service condiflons. These quellflod replacements should be in IIRC t
s l f,
'4 Category l.A Equipment Quellfled.
?
2 r
. \\s 4
C. Non-Class lE Items, providing no safety-related functions,
. have been deleted from the program. Therefore W se operators should be in NRC Category ill.A, Equlpment Exempt w
t from Quellfication.
t D. Operators located in mild environment have been deleted from the program. Therefore, these operators should be in NRC Category III.B. Equipment Not in the Scope of W Review, i
QCI: 8,13,19, Limitorque Type Sf6 1.B,
- 2. Demonstrate adequate similarity between E. Letters (referenced on SCEW sheets) from Limitorque state h 27,39,41,46 ac motors: Reliance, ll.A h equipment and the test specimen applicability of h B0003 and WCAP-7410L test reports for Limitorque, Peerless
~'
3 1
each shop order and provide evidence of similarity to h test de motors: NA J
specimens, i
QC2: 8,13,19, Limitorque Type Sf6 1.8,,
27,39,41 ac motor: Reliance, ll.A 5
\\
de motors:'NA j
QCI: 4,5,6,7 8, Limitorque Type Sie 1C
- 3. Evaluate age-related degradation for F. Mobil 28 grease has been Installed on all torque and limit 22,23,24,$5, ac motors: Peerless, 31.C h se operators switches for operators located Inside h drywell and steam 26,27,45 Rollance, Limitorque tunnel to replace Beacon 325, which hardened due to elevated de motors: NA temperatures.
QC2: 4 5,6,7 8, Limitorque Type Sfe I.B.
22,$3,24,$5, ac motors: Peerless, ll.C G. A motor analysis is being pr red by Bechtel utilizing Test 26,27,45 Reliance, Limitorque Reports B0058, B0003, and
-7410L. This analysis will de motors: NA demonstrate that Class B motors can wiinstand a design basis accident following 40 years of instelled life.
4 1
i 0494c' IV-13 i
_ _ _ ~ _ _ _ _ _ _ _ _ _ _ _ _,
s IV. Specific Eau'imment EO Deficiencies (continued)
Description.
(Manufacturer, IEEC FHC lten llueber Model. Etc)
Catenorv Deficiencies Proposed Resolution S.
Motor Operators'(continued)
'QCI: 4,5,6,7,8, Limitorque Type SSB
.l.B,
- 4. Quellfled life or repae===nt schedule H. Specific outage detes have been'provided for all replacenaent
~ 22,23,24,25, ac motors: Peerless, ll.C not established items.
26,27,45 Rollance, Limitorque de motors: IIA
- 1. No ohr weak-11nk materials (t:esides h grease in QC2: 4,5,6,7,8, Limitorque Type SfB 1.B, resolution F above) have been identified by Limitorque or 22,23,24,25, ac motors: Peerless, ll.C Bechtel that require ongoing maintenance or replae===nt, 26,27,45 Reliance, Limitorque i
de motors: IIA J. Limitorque tests have preconditioned h motors to h ir end-of-life condition in accordance with 10 CFR 50.49 (Test i
. Reports 80058, 600461-80003, 600376, and WCAP-7410L).
l l
T.
POSITION SWITCHES QCI: 58 NAMCo, EA000lll00 f.B Documented evidence of qualification At h time of TER/SER review, adequate evidence of quellfication QC2: None inadequate was not established for h se position switches because qualified replacement switches were not Identified. Qualification is j
required for all h accident environmental parameters, and aging j
is required because these components are subjected to harsh levels i
of radiation and temportture during norieel operation. At Quad Cities Unit I, the original switch has already been replaced with 1
a NAMCo snap-lock Model EA180-Il302 durlag flovember and December j
of 1982. At Quad Cities Unit 2, h exis, ting switch will be replaced with h above NAMCo model duri h next station 3
outage. Quellfication data for these replacement switches is provided in linMCo Test Report QTR 105, Rev 3, l
August 20, 1981. This report has been reviewed and found to quellfy h se new switches for the required accident environment. To establish a designated life, an analysis is being perforined based on the data provided in the NAMCo test report. h se quellfled replacement e = ranents should be placed j
in NRC Category I.A, Equipment Quellfled.
U.
PRESSURE SWITCHES 4
QCI: 21-Static-0-Ring 1.B Documented evidence of quellfication hse coupo.wnts were scheduled for replacement; however no QC2: 21 12NN-KK215VX is inadequate quellfled replacement was identified at h time of W YER/SER
]
review. h refore, documented evidence of qualification was l'
Indicated as inadequate. They will be replaced by quellflod Rosemount Model 1153, Series B transmitters. The harsh environment parameters this equipment will encounter are temperature, pressure, and humidity during post-0BA operation.
Radiation Is considered alId at <l.0E04 rads. Rosemount Test J
Report 108025, Rev B, dated February 1983, which provides the qualification data for h se transmitters, Indicates that the transmitters are quellflod for the required environmental conditions. The quellflod life of h Model 1853, Series B transmitters has been determined by Rosemount to be 20 years; h refore, h se ea panents will require replacement at the end 1
of this period.. These quellfled replacement components should be j
In NRC Category l.A, Equipment Qualified.
J I
0494c IV-14 2
IV. Specific Eaulement EO Deficiencim (continued)'
Description (Manufacturer, 15tC FRC lten llu6er Model. Etc)
~Cateoorv Deficiencies Presosed nosolution U.
Pressure Switches (continued)
QCI: 33 Static-O-Ring II.A Documented evidence of quellfication Not applicable hae=ase h se ea-panents are not subjected to
.* QC2: 33
'. 99.-3 is inadequate harsh environmental conditions; therefore, they are deleted fren
~,
7 h qualification program. These - -- _ c.ts shoutd be In 15tC Category 111.8, Equipment Not in the 5 cope of W Review.
I QCl 36 Static-O-Ring II.A Documented evidence of quellfication Not applicable because h se ea panents are not subjected to QC2: 36 12N-AA5-PP is inadequate harsh environmental conditions; therefore, they are deleted fran h quellfication program.,These - ---- n _1ts should be in IWIC Category 111.8, Equipment Not in h hcope of h Review.
- QCI: None Berksdale 82T-Al2SS NA None hse -- - -1.ts were locaed in mild environments at h time of QC2: flone the TER/SER review; h refore, no deficiency was identitled.
Subsequently, deficiencies were identified for pressure, temperature, and humidity only, h refore, h se Berksdale 4
B2T-Al2SS pressure sultches will be replaced with quellflod 4
Rosemount Model 1853, Series 8 transmitters. Rosemount has tested its Model 1153, Series B transmitters and provided h quellflod documentation In Test Report 108025,Rev8luatedand dated I
February 1983. The report has been reviewed and eve found to quellfy the transeltters for h required conditions.
J h quellflod life of h Model 1853, Series B transeltters has been determined by Rosemount to be 20 years; W refore, these e w ts will require replacement after this period. These quellflod repI=e===nt components should be placed in IWIC Category 1.A, Equipment Quellfled.
V.
PRESSURE TRANSMITTERS i
QCl None Belley, B&W NA None At h time of h TER/SER review, no deficiency was identified j
QC2 None KG556220BAAlWFE for h se Belley pressure transmitters. However, h se I
transmitters are required to be quellflod for post-accident j
radiation only. Wyle has conducted testing on h se transmitters and provided quellfication documentation in Test Report 45917-40, Septenter 1983. h report has been reviewed and evaluated, and 1
i it has been determined that h se transmitters are quellflod for W required accident radiation dose, h refore, h se quellflod components should be placed in 154C Category 1.A, Equipment QualIfled.
i i
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0494c IV-15 i
IV. Specific Eaulsument EO Deficiencies (continued)
Description (Manufacturer, ISIC FitC lten Humber Model. Etc)
Category Deficiencies Proposed Resolution V.
Pressure Transmitters (continued)
QCI: 9,30 GE/MAC 551 1.B Documented evidence of qualification At h time of TER/SER review, hse er ranents were scheduled for QC2: 9,30 Inadequate ol h r testing or analysis. The decision was made to test h cr= parent for radiation because radiation caused by a design basis accident is W only harsh environment to which these e<=panents are ever subjected. E d n n -fly, h GE/MAC Model 551 and 553 transmitters were tested by Wyle Laboratories.
Qualification was provided in Wyle Test Itaport 45917-1, July 30, 1982. Iteview and evaluation of h test report revealed ht h se components are quellfled for h required conditions, hrefore, these quellflod e<=panients should be In INIC Category 1.A, Equipsment Qualified.
W.
RADIATION DETECTOR None X.
ELECTRIC MOTORS (RDOM C00LCR Fall MOTORS)
QCI: 37 General Electric Model l.B Doctmeented evidence of qualification hse e<=pasants were scheduled for replacement; however no QC2: 37 5K215AK2476 Inadequate quellfled repime===nt was identified at h time of W IER/SER review. Therefore, documented evidence of quellfication was indicated as inadequate. They will be replaced by quellflod Westinghouse motors. The c<=panents are required to be quellflod for post-accident radiation only. Westinghouse has provided h radiation quellfled for h repime===nt motors in Test Report 1949112, dated January 1982. Based on review and evaluation of this report, it has been determined h t h Westinghouse motors are quellflod for h postulated accident radiation dose.
Therefore, thue quellfled replacement e<=panents should be in IEIC Category 1.A. Equigament Quellfled.
l I
t 1
i i
l, i
0494c IV-16
- 13. Saecific Eaulement EO Deft-lencies (continued)
DeecrIptIon (Manufacturer, 151C Elton llumber Itodel. Etc)
Catenorv Defielextes ri __ -f Resolution X.
Electric Hotors (Room Cooler Fan flotors) (continued)
~
QCI: 3G General Electric flodel I.8 nae m ted evidence of quellfication These P s were scheduled for repl - t; however no t
QC2: 38 EIB4AL215l Inadequate quellfled replacement was identifled at h time of h MR review. Therefore, dae-ted evidence of quellfication was Indicated as Irn ;-_:te.
They will be replaced by guellflod tiestin@ouse motors.
The P s are rosysired to be quellflod t
for post-accident radiation only. tiestinghouse has provided h radiation quellfled fc-h replacement motors In Test Report i
1919112, dated January 1982. Bened on review and evaluetlen of this report, it has been determined that h isostinghouse meters are quellfied for h postulated accident radiation does.
Therefore, these speellfied replacements should be In IEE Category I.A, Egulpment Quellfled.
1 Y.
SOLEIIDID VALVES i
QCI: 16 AVCo C5512 1.8 Documented evidence of quellfication The llovember 1980 sutunittal identifled these components as QC2: 16 Gould, 320K39/320K30 lead taate requiring quellfication by testing or replacement. leo information on lacement epsellfication was avellable at ht timal therefore, determined that documented evidence of t
quelIfIcation was Ir o ;-:te. ?-t ; -tly, Ceco joined a l
generic test program for these valves ; ::M by TVA. The TVA test progree was Initiated at ifyle Laboratories to envelop all harsh environmental conditions at Quod Cities. The ongoing test program has currently established a 5-year epsellfleetion for j
these solenoid valves. In addition, an analysis will be performed to take credit for h tests being conducted to i
environmental conditions beyond h ee required and to establish a reasonable estimate of h epsellfled life and appropriate maintenance and repl-t requirements.
~
x QCI: 17 AVCo/ Target Rock li.C Ing degradetion not identified quell-At h time of h TER/SER review, these <= panents were identi-QC2: 17 C5450-5 edlifeandreplae===gtschedulenot fled as Dresser Industries walve Model C5450-5. FRC noted that established oni age degradetion was not Identified and quellfled life and rep me===gt schedule were not established. T-t::;
-tly, these 4
components were identified as Automatic Valve Corporation (AVCo) i Model C5450-5 operators on Target Rock relief valves. As a result, these operators are required to be quellflod to harsh environmental conditions due to temperature, humidityIng Is also
- pressure, t
radiation, and dominerellaed water spray. Thermal ag i
required to no addressed. General Electric Plant Design
[
]
Engineering Memorandus 126-62, dated January 15, 1975, establishes quellfication for these AVCo/Terget Rock solenoid t
valves to the Quod Cities harsh environmental conditions. In addition, this report has been supplemented by a Bechtel analysis performed to establish a reasonable estimate of h designated 4
life. Therefore, these quellfied ea-panents should be in IsIC l
j Category 1.A, Equipment Quellfled.
i E
i i
{
0494c IV-17 i
IV. Soecifla Equismont EO Deficiencies (continued)
Description (Manufacturer, ISIC FIE Itee Number Model. Etc)
Categorv Deficiencies E- _ --f Resolution Y.
Solenoid Valves (conti w od)
QCI: 18 Dresser 1525VX ll.C AgingdegradetionnotIdentifiedlenotquell-During h TER/SER review, FRC Indicated h t a0 ag degradetion 1
QC2: 18 fled life and replae== ant schedu for these Dresser solenoid valves was evaluated inadequately and established h t quellfled life and repime== ant schedule were not established. Later, it was also determined h t h se components would be exposed to higher levels of radiation and temperature than h orlainal values stated in N Ilovember 1980 report.
h refore, t6ese P ts are required to be quellflod for temperature, redletion, and aging. Ilortheast Utilities Millstone i Project Engineering Progree 42963,Section I, demonstrates partial quellfication for h se valves. This report is being supplemented by a tiestec analysis to establish compbte environmental quellfication and proper maintenance and repime== ant requirements. tiestec has identified all se--
,-_t poterials and confirmed h t a high-temperature insulation system was employed in these valves. This Insulation system was also j
setIsfactoriIy sulmeergence-tested. h oneIysIs Is scheduled for completion In March 1984.
QCI: 47 Versa VPS2502/VGS4522/
l.B Documented evidence of qualification At h time of TER/SER review, evidence of quellfication was not QC2: 47 VGS4472 Inadequate adequately established for h se Verse solenolds walves because quellfled replacements were not Identified. h versa valves will be replaced by ASCo solenold valve Model Ir8344A73V at Quod Cities. Besed on h evaluation of ASco Test Report AQR47368, Rev 0, these ASCo valves are quellflod to N required environmental conditions at Quod Cities. Therefore, these I
quellfled replae== ant ev=panents should be in MitC Category B.A, Equipment Quellfled.
QCI: 66 Versa VWS2302 1.8 Documented evidence of quellfication TER/SER review identified h t h quellfication documentation was inadequate inadequate because a quellflod replae===nt was not identifled for
- this Verse solenold valve. After reevaluating h quellfication requirements, it was determined h t h SGTS butterfly velve is of h fell-open type and is normally open during system operation. It is not required to change position following an accident. Failure of this valve will not effect system safety functions; hrefore, this component should be in INIC i
3 Category ill.A, Equipment Exempt from Quellfication.
QCI: Ilone ASCo NP-l ll.C A ing degradation not Identifled quell-An aging analysis had not been performed on this ev=panent at h 0
j QC2: 49 "806300-3RVF fledlifeandrepl=e==antscheduIenot time of h TER/SER revlow; hrefore, aging degradetion was not established Identified as a quellfication parameter. N quellfled life and replacement schedule were not established. Aging and qualsfied life were addressed generically In Attactruent 5 to the TER/SER
~
response. Bechtel has performed an analysis (Bechtel Calculation NUC-32, Rev 0, dated July 20, 1983) to determine h quellfled life of h solenold valve s@--- %xts on h bests of ASCo
=
Test Report AQR47368 Rev 0. -Si t replac== ant schedules have been established and are being incorporated in W plant meintenance and surwelliance program. h quellflod Ilfe for W subconponents is as follows: Viton A static seel, 37 years and i
solenold coll, 30 years. h refore, h se quellflod ev=panents i
f should be In INIC Category 1.A, Equipment Qualified.
1 I
0494c IV-18
IV. Soecific Eosisment EO Defl*Iencies (continued)
Description (Manufacturer, ISIC FMC lten Humber Model. Etc)
Catesory Deficiencies Prosoned Resolution l
I Z.
SWITCHGEAR None AA. TElfERATURE ELEDENTS QCI: 1 Minco (for Penalerm) 1.8 Documented evidence of quellfication h Identlflod deficiency was tegerature and was originally to be QC2: 1 S51-1-103 Inadequate resolved by meterial enelysis. A literature search revoeled that all teflon w ts of N Minco temperature element were Inadequate for h required enviromeent. Therefore, h owlsting resistence temperature detectors TE-1291-60A through -60H will be replaced with environmentally quellflod temperature detectors manufactured by Conew corporation. These Conan temperatore detectors will provide en enviromeentally quellflod system, dich will have redundant sensing trains to detect steme leaks. Conow Test Report IPS-875 was evaluated, and h replacement components i
are fultp quelIfled for N required envIromeent. These quellfled replacement components should be In ISIC Category 1.A, Equipment Quellfled.
BB. TEIFERATURE SWITCHES QCI: 15 UEC Type F7, Model 88B II.A Documented evidence of quellfication h TER/SER evaluations concluded that the quellfleetion h -
QC2 15 Inadequate tetton was inadequete for these __
c fs because CECO's periodic calibration did not provide evidence of quellficetten In accordance with the DDR guidelines. h se temperature switches are required to be quellfled to harsh enviromeental condiflons of temperature, hueldity, pressure, and redletion. Thermal and 4
redletion aging effects must also be established. Therefore, it was determined that the quellfleetton would be established by m _ f y, it was decided to i
either enelysis or replacement. Si l
replace the microswitch to establish meterial traceability and to
]
quellfy N components by enelysis. An analysis Is being performed using MCC Powers Test Report 734-79-002, Rev I Farr
+
Company Test Report L-71063, Rev A; and h manufacturers' technical literature.
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l 1
t 1
1 i
0494c IV-19 1
_I V.
Soecific Eaulement EO Deficiencies (continued)
Description
'(Manufacturer, INIC FIIC lten lluster Model. Etc)
Catenerv Deficiencies ri__ __fIlesolution W.
Teneerature Switches (continued)-
QCI: 20,48
'Fenwel Model 17002-40 ll.A Docismented evidence of qualification h TER/SER evaluation concluded that h qualification h te-QC2: 20,48 Inadequate tion was In' ute for these components because Ceco's periodic calibration did not provide evidence of qualification in accordance with h DDR guidelines. These temperature switches are required to be quellflod to harsh environmental conditions of temperature,humiditybpressure,andradiation.
Thernel and radiation aging effee aust also be established. These sw'^-hos have a very short operating time, and h actident radiati e
- se i s wi.-. ; --fingly smell. They are very simple devices wi m
.'*,e most sensitive meterial (terdon) located only on h lead i, ires.
Therefore, qualification is being established by meterial analysis based on h manufacturer's technical literaturel GE Report KDD24217; GE Amport DV145C3004; ifyle Report 43054-1 of TVAg and Bechtel Chron 7089, dated florcti 11, 1983.
QCI: 64 Chromelox bimetal I.8 fum ted evidence of qualification The TER/SER stated het qualification documentation was I- ' ;_-de thermoswitch manufac-Inadequate for h thermoswitch because quellflod repl-ts were not iden-turer unknown tified. In h TER response, it ises stated h t quellfication was required for harsh temperature, humidity, pressure, and radiation for h components and ht quellflod replacehents would be installed during or before critical outages at h stations. Subsequently, h stations removed these sultches freso N circuitry because they isore not required for system operation. Therefore, the camponents should be deleted from h IE Bulletin 79-018 and placed in 151C Category ill.A, Equipment Leempt from lification.
QCI: 67 Pall Trinity micro-1.8 n e m ted evidence of qualification The SER/TER stated that qualification docusertfation was inadosysete switch 14-T-2H Inadequate for h thor===ple because quellfled replacensents were not identified. Quellfication is not required fu these components because an envirosumentally qualified supprest lon pool temperature monitoring (SPTIO system will be Installed te monitor water temperature, thereby providing h same functfion as h subject W rmocouples.
The SPTM system Ses been removed from h enoironmental quellfication program pending completion of W following lines a.
Detailed control room design review b.
Response to ISIC concerning compliance with Regulatory Guide 1.97, Rev 2 c.
Determination of electrical equignment located in harsh envi-ronments required for TM1 lessons-learned Implementation (HUEG 0737) In accordance with IE Bulletin 79-018, Supplement 3, item 2 Fur h r details are included n Section I of this enclosure.
0494c IV-20
I V.' Specific Eaulement E0 Deficiencies (continued)
Description (Menufacturer, IStC FiqC lten llumber Model. Etc)
Cateaorv Deficiencies Proposed Mesolution
. CC. TEltlillAL BL0 m S QCI: 51 Allen-Bradley 1.8 Documented evidence of quellfication h se components were scheduled for replacement; however, no QC2: leone Allen-8radley inadequate quellflod repIwa==nt was identified at h flee of the TER/SER review. h refore, documented evidence of quellfication was indicated as inadequate. They will be replaced by Mora+ hon Series 1500 terminal blocks. h equipment is required to be quellflod for harsh environment due to temperature, pressure, humidity, radletion, and domineralized water spray durleg post-0BA operation. In addition, thermal aging at 150F is required for h remaining 30 years. The Marathon Series 1500 terminal blocks were tested by Wyle Laboratories and quellfled by Wyle Test Meport TIE-45603-1, February 18, 1982. Based on review and evaluation of this report, it has been determined h t h equipment has a quellflod life of 40 years and is quellflod for the postulated accident environment. h se qualified reple===ait components should be in 354C Category I.A, Equipment Qualified.
DD. OILS AND GREASES None Mobil 28 None leone Quellflod by Mobil Technical Bulletin, May 1974; used in Limitorques.
None Mobil DTE medlun heavy None None Qualified by Mobil Technical Bulletin, May 19741 used in General Electric LPCI, core spray, ID5t, and shutdown cooling pump motors.
0494c IV-21