ML20088A905
| ML20088A905 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 04/03/1984 |
| From: | Crouse R TOLEDO EDISON CO. |
| To: | Stolz J Office of Nuclear Reactor Regulation |
| References | |
| 1039, TAC-42508, NUDOCS 8404130311 | |
| Download: ML20088A905 (38) | |
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o Docket No. 50-346 70tego License No. NPF-3 Rcem p. cmuu Serial No. 1039 vc. pr -
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'd'9'258 522' April 3, 1984 Director of Nuclear Reactor Regulation Attention: Mr. John F. Stolz Operating Reactor Branch No. 4 Division of Operating Reactors United States Nuclear Regulatory Commission Washington, D.C. 20555
Dear Mr. Stolz:
On Decc=her 13, 1983 : =ccting was held between Toledo Edicen cnd the NRC Staff to discuss the resolutions of the deficiencies identified in the Technical Evaluation Report (TER) for Environmental Qualifications for Safety-Related Electrical Equipment (February 8, 1983 Log No. 1211). The enclosures contain the generic issues, resolution of the open-items and identified Justifications for Continued Operations (JCO) for the Davis-Besse Nuclear Power Station Unit No. 1.
Enclosure 1 contains the agenda of Generic Issues discussed at the December 13, 1983 meeting. Enclosure 2 (Category I.B), 3 (Category II.A),
4 (Category II.C) and 5 (Category IV) contain the identified TER components with their deficiencies. The enclosures describe each of the components /
manufseturers with the detailed method of resolution as discussed in our Decesser 13 1983 meeting.
During the meeting, two items (Amphenol penetrations and ASCO Solenoid Valves) were identified for which the Staff requested JCOs. An Amphenol penetration test report was located and provided resolution to the question of qualification. The ASCO Solenoid Valves JC0 is contained in Enclosure 6 and was reviewed by the Staff on December 22, 1983. The JC0 for the ASCO Solenoid Valve was found to be acceptable as was our response concerning the Amphenol penetration qualification.
Revision 2 to the Davis-Besse Environmental Qualification Manual was.
submitted on November 29,1983 (Serial No.1009). This includes data and analysis performed to resolve the TER concern and additional data on the continuing qualification of.certain specific items. We believe that the environmental qualification documents maintained in our central file comply with the requirements of 10CFR50.49.
Very truly yours, gp8 flhl 4PC m / w q) ,
RPC: GAB:lah cc: DB-1.NRC Resident Inspector THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE '. TOLEDO, OHIO 43652
,8404130311 840403 1
- RDR ADOCK 05000346 D '
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_ ENCLOSURE 1 l Generic Issues Introduction In the Franklin Research Center, " Davis-Besse-1 TER"; Section 4.3 provided the review of the " Methodology Used by the Licensee." This review concluded that satisfactory response to the NRC concern has been provided for the following items:
4.3.1 Completeness of Safety-Related Equipment List i 4.3.2 Containment Spray System (not subject to a disabling single
! - component failure) 4.3.3 Environmental Service Conditions 4.3.4 Chemical Spray 4.3.5 Submergence (including flooding outside containment) 4.3.6 Aging and Qualified Life Concerns have been raised with respect to certain generic issues which have been d'iscussed below. ,
[ Individual Generic Issues l
l G-1 Inadequate Aging and Radiation Analysis In some cases there were conunents in the TER concerning the aging and
! radiation material s analysis. The concern was that radiation values presented were not properly evaluated for the property of interest.
l Regarding aging, the concern was that the qualified life was not properly l
evaluated.
To address these issues TED has performed a comprehensive aging and radiation review of the DB-1 EQ Manual. All materials analysis and the j test reports were reviewed for radiation qualification. Similarly, I materials analysis ar.d test reports have been reviewed for themal aging l- qualification. .The detailed methodology used in the perfonnance of this
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effort has been included in the revised EQ Methodology report. The results are included in Revision 2 to the TED EQ Manual submitted on November 29.1983 (Serial No.- 1009).
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The TER comment, "the Licensee referenced two generic documents as a basis of radiation and thermal aging qualification for many items. These are Modern Plastics Encyclopedia and "The Use of Plastics and Elastomers in Nuclear Radiation," by Parkinson and Sissman. While these documents are useful for screening qualifiable materials, they are not adequate as a basis of environmental qualification."
For thermal aging, the temperature index data from the Modern Plastics Encyclopedia is not being used as th,e basis for environmental qualification. Such information is used as an input to the Arrhenius aging calculation only in a few cases where aging test data is not otherwise available.
For radiation aging, the Parkinson & Sissman paper was used with a number of other sources to evaluate the degradation effects taking into account the specific engineering properties of interest.
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G-2 Qualification by Analysis The TER comment stated that the Static-0-Ring pressure switches were required to function in the harsh environment and only a materials
- analysis was provided.
Qualification by analysis is allowed per IEEE standard 323-1974, D0R
- Guidelines, and the final rule 10CFR 50.49(f). In accordance with these provisions certain components have been qualified by analysis which is based on test information.
The switches are located in Rooms 500 & 501 which have peak temperature i and pressure conditions of 249'F and 0.9 psig and 267'F and 0.9 psig respectively during a High Energy Line Break (HELB). Conditions return to p ambient in 18 minutes. There .is no accident radiation dose contribution in this room. -
,' A materials analysis was performed on the list of materials provided by the manufacturer (Static-0-Ring). The materials analysis showed that the polyvinyl chloride (PVC) wire. insulation was the material most sensitive '
to thermal degradation.
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Considering that the ambient room temperature during the HELB exceeds the continuous service temperature of the most limiting material of the switch ]
(150*F), it i s still felt that the switch can tolerate thi s momentary i excursion (300 seconds). The decomposition temperature of the PVC is 1 298'F below which the electrical properties of the switch are retained and the switch function will not be impaired. Furthennere the PVC i s located within the airspace of the switch which will afford some thermal insulation for the switch internals. These pressure switches are pressure sensing inputs to the Steam and Feedwater Rupture control system sensing main steam line 182 pressure. The steam lines are located in Rooms 601 and 602 (Auxiliary building elevation 643' while the switches are located in rooms 500 and 501 directly below en elevation 623'. The harsh environment postulated to occur in rooms 601 and 602 is due to a HELB in the 36 inch main steam lines while the harsh environment in rooms 500 and 501 is due to a HELB in a 6 inch main steam lino.
The pressure switches are housed in aluminum gasketed enclosures rated as NEMA-4. The wiring to the switches is via qualified conax electric seal assemblies to ensure the integrity of the switch housings. The enclosure which is rated WEMA-4 is capable of satisfactorily excluding water when subjected to a water stream of 65 gpm from a one inch nozzle from a distance of 10 feet for 7.5 minutes. The impingement pressure on the seal during this test would be 1.2 psig. Therefore the sealing capability of the enclosure by virtue of its NEMA-4 rating exceeds the postulated peak room pressure of 0.9 psig which could occur as a result of the postulated HELB.
Maintenance instructions will be revised such tha't the gasket seal on
> these pressure switches is inspected at each switch calibration. If the
! gasket is found to be degraded then the switch would be refurbished. The qualified life of the gasket seal i s 36.5 years at 104*F based on l Arrhenius calculation. These switches are included in the-surveillance and maintenance program which will ensure that sufficient inspections and L maintenance are performed to prevent age related or environmental failure.
Based on this we conclude that by analysis, the Static-0-Ring Pressure Switches (SFRCS_ nputs) are qualified.
l G-3 Change of Qualification Status The qualification tatus of certain components have changed since the issuance of the EQ Janual Rev.- O. These are as follows:
A. Exemption of certain solenoid valves due to the argument that the..
failure of~ the solenoid valves would cause the solenoid valves to go to their fail-safe position. - Main steam isolation solenoid -
l valves and main steam line warm-up drain solenoid valves should not l be exempted. The MSIV and main steam warm-up line solenoid valves
! have been scheduled for replacement by 11-30-84 (schedule was provided in May.20,1983 submittal)'.
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As previously submitted with regard to the ASCO Solenoid Valves, we L have additional analysis to justify continued operation. The solenoid valves in question are those which when denergized close the Main Steam Isolation Valves (MSIV) to prevent the blowdown of ,
two steam generators and thus maintain heat removal capability. !
4 A test has been conducted on ASCO solenoid valves HTX8320A20Y by General Electric, which are identical to those installed at Davis-Besse. The results of this test (Rockwell Test Report
- 2792-03-02, Rev 1) show that the valves survive in an harsh steam environment at 340*F for 2 hrs. Room 601 temperature peaks at 280*F for lsec and stabilizes at 200*F for 50sec then decreases to ambient temperature in 7000sec. Room 602 temperature peaks at 344*F for 1sec and drops to 210*F at 2sec and stabilizes for 50sec then decreasing to ambient temperature in 3400sec. This time period and temperature profile will allow the valves to perform their intended safety function.
The design is such that if any. solenoid valve should fail due to a steam line break (by moving to its fail safe position, or by not moving at all) it will not prevent the MSIV from closing.
Therefore )He can sustain a failure of the single solenoid valve.
In addition, further analysis was performed to show that should
' multiple failures of solenoid. valves occur due to a main steam line break; and prevent the MSIV from closing, we would still be able to isolate the unaffected steam generator from the worst case main n
-steam line break (a break between the containment and an MSIV. )
This analysis utilizes a previous study performed on the Non Return Valve which shows that it will close and not fail should such an event occur. This provides two valve isolation (Main lurbine Stop Valves and the Non Return Valve) to mitigate this event.
4 NUREG 0136 " Davis Besse Nuclear Power Station Unit 1 Safety Evaluation Report" December 1976 Section 10.3 " Main Steam Supply System" pg 10-2 contains statements on the Non-Return Valves.
" Pneumatically operated, non-return valves downstream of the isolation valves, prevent reverse flow. ~ These ' valves close .
automatically upon closure of the. main steam isolation valves.
They can also be remote manually operated from the main control
. room. We have reviewed the main steam system design.and conclude t
the system is acceptable." . Therefore, we believe that the non-return valves will perform their function.
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t There are two other ways to detect smaller steam line break in the main steam line Rooms 601 and 602. The first would be by the fire detection system located within each room. Room 601 has 34 detectors and 602 has 8 detectors. All detectors are ionization type. Any steam reaching these detectors would actuate the fire alam for the associated room. These detectors are maintained in accordance with our Fire Protection Program. This has been verified every time the steam safety valves or atmospheric vent valves actuate which causes a steam environment in Rooms 601 and 602. The second method is provided by the sound from the steam leak. .
When the operator detemines there is a steam leak, the following actions will be taken:
- 1. If personnel safety is in question the operator will trip '
SFRCS manually which trip the reactor and closes MSIV's.
- 2. If the steam leak is small and no personnel safety is involved the operator will Shutdown the plant in a controlled manner.
This provides justification for continued operation until the affected solenoid valves can be replaced with qualified solenoid valves during our 1984 refueling outage.
The main steam line 1 and 2 warm-up drain isolation valves SV375 and SV394 (208H-025 and 208H-026) are 3 way solenoid valves which control the air to air operated valves HV394 and HV375. These Air ,
Operated Valves (A0Vs) control the flow of steam and condensate through 1 1/2 inch lines to a common.2 inch line and then to the condenser. The three way scienoid valves are nomally energized and must denergize to spring to the vent position to vent the air from the warm-up drain air operated valve diaphrages closing the i ADVs. ,
- Two Emergency Ventilation System components have been added to the EQ Manual in Revision 2 and are scheduled to be relocated. These
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l l: 1) PDY5000A 222H-028 l 2) PDYS0008 222H-029 l JC0 has been p'rovided for these two components. This JC0 is
'similar to-that for the Bailey controller and the Foxboro current
" repeater which was judged to be acceptable by the FRC TER evaluation.
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B. The items listed below are no longer scheduled for modification or replacement because additional data has been collected to demonstrate qualification by a combination of testing and analysis. Rev. 2 of the E.Q. manual reficcts this.
Items which are no longer scheduled for replacement Rees Pushbutton Switch 221n-159
- 2) -
22011-011 Limitorque Operators 210!!-014
- 3) 210f t-015 Barksdale Temperature Switch 20511-019
- 4) through 2051[-023 22311-024
- 5) Consip Delphi H2 Analyzer 2231t-023 C. Items deleted from the EQ Master List (harsh environment) because they provide no safety function. Rev. 2 of the EQ Hanual reflects this.
22411-013 General Electric Solenoid Valve Prestolite Leland HPI Lube.0il Pump 21111-012 21111-013 DC Motor-21111-014 United-Electric Pressure Differential Switch 211,11-015 G-4 Regulatory Guide 1.97 Components (Post Accident Monitoring)
Those RG 1.97 items already installed have been included in the EQ Manual.
TED is presently undergoing a RG 1.97 review in conjunction .with the .BLJ Owne rs Group. - This ef fort is part of our overall Emergency Response Capability Program (Generic Letter ~ 82-33) . .
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_ The' schedule for-implementing any RG 1.97 modifications' will' be ad resse in our. response to Generic Letter .82-33.
.Any changes _resulting from our RG 1.97. review,.and the associated
. qualification data will be incorporated in the EQ Manual as part of the
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- normal facility _ changes requesticlosecut process following installation.
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C-5 Methodology to Identify Equipment Within the Scope of 10CFR 50.49(b)(2)
Paragraph (b)(2) of~ 10CFR 50.49 requires that licensees identify "non safety-related electric equipment whose f ailure under postulated environ-mental condition could prevent satisf actory accomplishment of safety functions.. . ." The methodology that was used to create the DB-1 master list is summarized below:
- 1. A list of safety related systems required to achieve safe shutdown or accident mitigation was developed. Any systems or equipment which were support systems (i.e. mechanically connected or auxiliary systems) which are necessary for the required operation of the safety related equipment was included. This was determined by review of the FSAR and the Davis-Besse Unit 1 Piping and Instrumentation diagtams (P&lDu).
- 2. From theae systems determined in Step 1, a list was generated of safety-related elisetrie equipment as defined in paragra;:h (b)(1) of 10CFR 50.49 required to remain functional during or following design-basis Loss of Coolant Accident (LOCA) or liinh Energy Line Break (HELB) Accidents. The LOCA/HELB accidents are the only design-basis accidents which result in significantly adverse environments to electrical equipment which is required for safe shutdown or accident mitigation.
( The list of safety related electrical equipment was based on C reviews of the Davis-Besse Final Safety Analysis Report, Technical Specifications, Emergency Operating Procedures, Piping and Instrumentation Diagrams (P& ids), and electrical distribution diagrage.
- 3. The elementary wiring disgrams of the safety-related electrical equipment previously identified in Step 1-were reviewed to identify any auxiliary devices electrically connected,directly into the control or power circuitry of the safety-related equipment whose failure due to postulated environmental conditions could prevent the_ required operation of the safety-related equipment.
- 4. Nonsafety-related electrical circuits indirectly associated with the electrical equipment idiotified in Step 2 by common power supply or physical proximity were considered in the original DB-1 electrical design including the use of applicable industry standards (e.g. , IEEE, NEMA, ANSI, UL, and NEC) and the u.se of properly-coordinated protective relays, circuit breakers, and fuses for electrical circuit fault protection (Bef. FSAR Chap. 8).
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The methodology utilized to create the Master List for the DB-1 E.Q.
manual ensures that all equipment required for initiating protective actions, mitigating the consequences of the event, and monitoring of the event is included. Therefore the DB-1 E.Q. Manual Master List is judged .
to address all electrical equipment within the scope of the rule (10CFR50.49).
The flooding and environmental effects resulting from all postulated design-basis accidents including the loss-of-coolant accident (LOCA) and steam-line break accident (HELB) inside containment and the flooding and environmental effects resulting from HELBs outside containment were considered when identifying safety-related electrical equipment at Davis-Besse Unit I which was to be environmentally qualified. FSAR section 15.4 discusses the design basis accident considered and FSAR section 3.11 provides a discussion of the Environmental Design of Electrical Equipment.
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Concerning submergence inside. containment, deficiencies are addressed on the individual erstem component evaluation worksheets. Sufficient documentation has been obtained for some components to prove qualification for submergence. Documentation is included in the Central File verifying qualification. For all other components, the following information is provided:
o An assessment of the failure modes associated with the submergence of the applicable components.
O Assurance that the subsequent failure of the component will not adversely affect any other safety functions or mislead an
- operator.
o Discussions concerning operating time across the spectrum of events, in relation to the time of submergence.
Concerning submergence outside containment, the auxiliary building drainage to allow waterErstem and accumulated removal water leakof, lated component failure viaf paths to preclude safety-re submergence. Flooding resulting from postulated main steam line breaks is addressed within Davis-Besse Unit 1 FSAR Section 3.6.2.7.1.2 and 3.6.2.7.1.3. Flooding resulting from pstulated main feed line breaks is addressed within FSAR Section 3.6.2.7.1.4. All break locations are above grade level which provides additional flow paths for run off.
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4 G-6 TMI Action Items Davis-Besse 1 Facility Change Request (FCR) Procedure (AD 1845) includes provisions for EQ review as part of the normal FCR closeout procedure.
TED has submitted an action plan which addresses all TMI related items.
EQ requirements of safety-related items are being addressed as those items are completed. The EQ Manual Rev. 2 incorporates the EQ data for those items which are completed. This incorporation process will continue in accordance with the schedule for the items as given in the TED action plan.
G-7 Surveillance and Maintenance Maintenance of Equipment Qualification At Davis-Besse maintenance of equipment qualification is assured through a program consisting of the following ingredients:
a) Control of spare parts procurement and usage b) Surveillance testing and equipment maintenance c) Training and indoctrination of personnel will be provided d) Systematic review and updatelof EQ manual and documentation files e) Evaluation of failures Control of Spare Parts Procurement and Usage
- A' procedure is in place which controls the procurement of spare / replacement parts to assure that they are procured to the proper specifications, stored properly, and are in compliance with the Davis-Besse QA/QC program.
Equipment Surveillance ' and Maintenance -
Davis-Besse S&M programs and procedures _will bejreviewed and up/ id as necessary to incorporate EQ related requirements (i.e., schedult. for-parts replacement / repair).
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Training and Indoctrination Engineering personnel who have the respons,1bil_itLfar_Engipment sualification _
, have been and will continue to be provided(training on the equipment qualification.
requirments and their responsibilities. Training is being developed for maintenance personnel who have the responsibility for equipment mainten-ance.
Systematic Review and Update of EQ Manual Davis-Besse has in place a Procedure for Field Change Requests which requires a review for EQ impacts. This procedure requires update of the EQ manual and documentation files as Station modifications are completed.
Evaluation of Failures
-Records of failures of maintenance history will be reviewed periodically to assess the potential for common mode failures resulting from:
- a) age related desradation, and b) environmentally induced degradstion Such review will also ancompasses a review of the data from NPRDS, equipment vendors and other industry sources.
G-8 Review of Justification for Continued Operation (JCO)
As part of the continuing EQ affort and in accordance with the govarnion ,
documents TED has provided JC0 statements wherever appropriate. JCOs are l provided for outstanding items awaiting modification and for equipment which is undergoing qualificat, ion testing or analysis. JCOs are developed using the guidelines providad in 10CFR 50.49.
Enclosure 6 contains additional JC0 which was requested by your staf f at the December 13, 1983, Resolution of Safety Evaluation EQ meeting. With regard to ASCO Solanoid Valves and Amphenol Panatrations, this JC0 was
. submitted December 22, 1983.
JCOs were reviewed prior to the initial TER response submittal and again f
- prior to the May 20, 1983 response. JCOs have been reviewed again and are still valid and we believe that Davis-Besse Unit 1 can continue operation without undue risk to public health and safety. ,
C-9 Exemption Deficiencias l i
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The TER contains comments relative to a component being exempt from thu l stualification for IACA/MELB effects. These comments agreed with the basis l for the exemption from the harsh steam environments and stated that components must be qualified for increased post LOCA radiation. -
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As stated in the EQ methodology report, exemption from qualification would only be considered for those parameters on the individual SCEWs containing EXEMPT in the qualification parameters column. TED recognizes that outside containment HELBs and increased radiation post LOCA are separate effects. The only exemption considered in these cases is from the effects of the HELB and not from the radiation / aging. All outside containment locations always contain the increased radiation due to post LOCA recirculated fluids in the radiation specification value for these locations.
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ENCLOSURE 2 ,
TED CATEGORY I.B.
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I I l l' Component / , .TER l 'SCEW l 1 l l l Manufacturer l Number l Number l Designated Deficiency i Method of Resolution I
- I l I I l l l , I I . I I l l REES .
I 1* l 221H-259 l No schedule provided for l Further analysis has been performed l l Push Button Switch ~l 6* l 221H-246 l replacement. l to document qualification and therefore l l l 21
- l 221H-258 l l replacement is no longer required. l l~ l I I l ! I ,
I I l TEC l 35 1302H-012 i None l Modification has been performed to l l Amplifier (valve l l through l I ensure a qualified siystem configuration. I l flow monitoring l l 302H-017 I l l l siystem - PORY and l l l , I i
- l - Pzr. safety-relief. l ll l l l l valves) -l l l l l l l l l l 1 1 I I I Endevco .36 l l'302H-006 l None i Modification has been performed to l Accelerometer l I through l l ensure a qualified ;ystem configuration. l l;(valve flow monitor- l l 302H-011 l l l
-l ing slystem - PORY .l l l l l
- l and Pzr. safety-- l l l l l l relief valves) .I l l l l 1 I l- 1 l l l i I I l l l Bailey l 48 l 218H-004 l No JCO provided. No schedule l Components to be replaced. Qualification t l Transmitter l l through I for replacement. I data provided in lieu of a JCO. Schedulel l Model s BY l l 218H-Oll l l provided in May 20 submittal. l l 1 1 l l l
'l l 49 l 204H-005 l l l 1 'l l through l l l l l l 204H-008 l l l l 1 l l l 1
-l l 50 1 224H-004 l l l l l l l l 1
.I l l l l l l l l l l l
.9JC0 Acceptable in TER Page 1 of 9 m _
ENCLOSURE 2 TED CATEGORY I.B.
(continued) l I I I I l l Component / l TER l SCEW l l I l Manufacturer l Number l Number I Designated Deficiency i Method of Resolution l I I I I l I I I I I I l l R;semount i 51
- l 220H-007 i Snielding or replacement l These level transmitters monitor SG l l Transnitter l l 220H-Oli i not completed. Qualified I level s and provide inputs to the SFRCS. l l Model 1152 l l l life deficiency. I This transmitter is only required for thel l l l l I mitigation of a feedline break requiring l l l l l the initiation of auxiliary feedwater. 1 l l l l l Component failure will not impact safety l l l l l l related functions or mi slead the operator l l l l l as alternate instrumentation not affectedl l l l l
. by submergence and qualified for the l l l l l I accident radiation dose i s available and l l l l l l required. For thi s reason the 40 year l l l l l l non-accident radiation dose i s used here. l l 1 I I I I l l l l l 1. Similarity analysis will be performedl l l l I I to attempt to show that adequate l l l l l l similarity exi sts between the l l l l l l Rosemount 1152 and 1153 model trans- l l l l l l mitters to allow the qualified life l l l l l l of the Model 1153 to be assigned to l l l l l l the Model 1152. Analysi s to be l 1 l l l l done by 3/1/84. l I I I I I l l l l 2. If the similarity analysis proves to I l l I be unsuccessful, then an evaluation l l l l l l will be undertaken to detennine if I l ,
I l the qualified Rosemount 1153 elec- l l l ,
I l tronic assemblies could be installed i l l l l l in a Rosemount 1152 transmitter. l l l l l l Physical and operational compata- l l l l l l bility will have to be determined. I I I I I I l l 1 I l l l l 1 I I l 1
, 0JC0 Acceptable in TER Page 2 of 9
ENCLOSURE 2 TED CATEGORY I.B.
(continued)
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~l Component / .
l l SCEW l l I
~l I l TER l I I l . Manufacturer l Number l Number l Designated Deficiency 1 Method of Resolution I I I i 1 I l , I l l Victoreen l 54
- l 223H-017. I No schedule provided for l The schedule provided in the May 20, l I Radiation Monitor l l 223H-018 l replacement. Exemption I 1983 submittal indicated that the l
.I (Model 8411) l l l deficiency. I equipment replacement had been completed. l
-l Station Vent. l l l l This equipment i s only required for l l- l l l l accident monitoring and not for 1
-l I l l l accident mitigation. The replacement l I l l l l equipment has been installed l l l l l l and is currently undergoing i i l l l l testing to place it in service. Quali- l l l l l l fication test documents for the replace- l l l l l l ment components are being reviewed and l I l l l l this will be completed by 11/30/84. l l I l l l See generic di sussion item G-9 for a l l l l discussion resolving the exemption l
- 1. l l deficiency. l I I I I i l
~l l I I l 1 Victoreen Radiation 55
- l 223H-021 l No schedule for replacement, l Equipment replacement completed in l l Monitors l l 223H-022 l Exemption deficiency. I accordance with the May 20, 1983, i l l l l l submittal . See generic item G-9 for a l l l 56
- l 223H-019 l l discussion resolving the exemption l I I l 223H-020 1 1 deficiency. I l i I I I I l l 204
- l 223H-023 l l l l l 1 I I l I
I I 1 I I I I I I I I I I I I I l- 1 I I I I
'l I I I I I I I I I .I I I I I I I I I I I I I I
- *JC0 Acceptable in TER Page 3 of 9
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ENCLOSURE 2 TED CATEGORY I.B.
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(continued) i i l l l l l . Component / l TER SCEW I l l l l Manufacturer l Number l Number l Designated Ceficiency 1 Method of Resolution 1 l l I I I l l l l l 1 Prestolite
- I 73
- l 211H-006 l No schedule provided for l Schedule was provided in the May 20, I l Leland Motors l l l replacement. I 1983, submittal . AC lube oil pump l l HPI Lube Oil Motors l 74
- l 211H-007 l l motors to be replaced with qualified l l (AC) l l l l equipment by 11/30/84 in accordance l l l l l l with FCR 83-063. l l l 1 1 I I l l l l l l 1 Prestolite 1 75
- l 211H-013 l No schedule provided for l Since these DC motors are backup equip- l l Leland Motors l l l replacement. I ment for the AC motors, upon replace- l l HPI Lube Oil Motors l 76
- l 211H-012 l I ment of the HPI AC lube. oil pump rrotor l l (DC) l l l l these items will be deleted from the l l l l l l master li st. Failure of thi s equipment l l l l l l will not adversely impact other safety l l l l l l related equipment or mislead the l l l l l l operator. I I I I I l l l 1 1 I l l l Bailey l 77
- l 222H-017 l No schedule provided for l Equipment to be relocated in accordance l l Model 701 Contrc11er l l l modification. Exemption I with schedule provided in May 20, 1983, I I l l l deficiency. I submittal. See generic item G-9 for l I l l l l a discussion resolving the exemption l l l l l l deficiency. l I I I I I I I I I i l United Electric l 82
- l 211H-014 l No schedule provided for l Since these components activate the l l Pressure Differential l l - I replacement. l HPI DC lube oil pump motor, these l l Switch (Model 357) l 83
- l 211H-015 l l switches will be deleted from the l l l l l l master list upon satisfactory replace- l l l l ment of the HPI AC lube oil pump motor. l l l l Failure of this equipment will not l l l l l l adversely impact other safety related l l l l l l equipment or mislead the operator. l l l l l l 1
,oJC0 Acceptable in TER Page 4 of 9 ldj.:.). ll}l.,ll.iyQ.jf}{,:{Gy.'{;.l*fW.'.!k}_*.yQ.[- i .
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ENCLOSURE 2 TED CATEGORY I.B.
(continued) i l I i l l Component / I TER l SCEW l l l Manufacturer l Number l Number I Designated Deficiency i Method of Resolution i I i i i l l l l 1 I I l l Static-0-Ring I 87
- l 210H-020 i No schedule provided for l In accordance with the May 20, 1983 l l Pressure Switch l l l replacement. I response, this component i s l I l l l l scheduled for replacement when it is l l l l l l determined that the replacement componentl l l is fully qualified. If required, a l l l schedule extension will be forwarded to l l l l l 1 the NRC with a target date for comple- l l l l l tion of this action as soon as qualified l l l l l l equipment becomes available. I I I I I >
I I I I I I I l l Buchanan l 96
- l 221H-317 l No schedule provided for l Selective replacement required. The l l Terminal Block I l l replacement. I specific items requiring replacerrant l l Model 0721 l 97
- l 221H-315 l l will be completed by 11/30/84. l l (Outside contain- 1 I I l l l ment) I 98
- l 221H-316 l l l l l 221H-319 l l l 1 1 I I I I I I i 1 1 I l l l 1 I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I i l l General Electric l 168
- l 224H-013 I No schedule provided for l No schedule was provided. Thi s item i I Solenoid Valve l l l replacement. I has been deleted in Revision 2 as it is l l l 1 1 I not nuclear safety-related. I I I I I I I i l l l l l l l 1 1 I I CJC0 Acceptable in TER Page 5 of 9 e
ENCLOSURE 2 TED CATEGORY I.B.
(continued) 4 l l 1 I l 1 Component / l TER l 3CEW l l I l Manufacturer l Number l Number l Designated Deficiency l Method of Resolution l
.I I I I I I i .
I i l l l 169
- I 225H-005 l l l
-l ASCO l 177
- l 210H-021 i No schedule provided for l Schedule for replacement (by 11-30-84) l I Solenoid Valve l l 210H-022 I replacement. I was provided in the May 20, 1983, I l l l l l submittal. l l l 183
- l 210H-023 l l l l l l 'hrough t l l l
~l l l 210H-026 l l l l l l l l 1 l l 187.* l 216H-054 l l l l 1- 1 I I I i-l '.189
, I l
- 1 I -
1 I_ , I I l l 1 91
-l 193
- l 208H-031 l l l
.l l 208H-032 l l l l l l l l l . I ,
I I
- I Barksdale . I 198
- l. 205H-022 1 No schedule for replacement. I Additional analy si s has been performed l l Temperature Switch I' l 205H-023 l Exemption deficiency. I to demonstrate qualification. Componentsl
'l l l l l are no longer scheduled for replacement. l l l 199
- l 205H-021 l l The Barksdale temperature switches are l ,
l l l l l located in the ECCS rooms 105,113, and l l l 200
- l 205H-019 I l 115. Peak temperature and pressures for i l l i 205H-020 l l these rooms are 130*F/1.36 psig, 1 l l l l l 155'F/1.36 psig, ar 1 177'F/0.9 psig I
_l l. l l l respectively. Com;xnents are qualified I i l l l l l by analysis of test data and materials I l' l l l l analysis for aging / radiation. The l I l l l l switches automatically control cooler fani l l I I l l
^
- JC0 Acceptable in TER Page 6 of 9
ENCLOSURE 2 TED CATEGORY I.B.
(continued) r 3
< ,1
' l '. 'f
. l I . l '
l_
TER: i. SCEW g < J
/; ,l '. ; iComponentLg ( :
Method of Res'olutio'n 1 1
'i .l; Manufacturer 'l Numbei- l Number ')J ' Designated Deficiency 1 I
3 p '
.i / S u- rl I \' l~ l I
I .f I
'l 1 I v ,
I l1 '
l 'l e r I motors in the ECCS rooms.
.1 Barksdale' .
-' l d il , Temperature Switch i I i j l l The switches are housed in gasketed l l
~ l (cont.) 1 NEMA-4 enclosures which exclude a water [,
l l
'l' l '
l / 1:
l l stream when sprayed from a 1 inch nozzle l l
l l at 65 gpm. The HELBs are relatively mildl ., .
l \l I I only lasting for 24, 7,' and 7sr.inutes I i ')
~ , il I
('.ll-.
1 l respectively in rooms 105,113,- and 115. I l' l v l I il/ l l Maintenance instructions will be revised l !
1 I such that the gasket seal on these I
.I. l l 1 1 pressure switches i s inspec.ted at each I
-l' -e 4
l? ,s l l l switch calibration. See generic item I
, _, lQ l l 1 G-3 for a discussion resolving the i
_(l
~; gl *, ., ,I l ' ;I I exemption deficiency. ,
gl + ,
'l'
~'
l l1 -
'l > l l
1 I l- '. '
l l- i I I I I 1 i
l 'I I 4 I 1 Equipment to be relocated in accordance i .
- l. 202 * ' l 222H-022 l' No sch'edule provided forf g I'Foxboro_,
l modification. -! with schedsle provided in the May 20, ! [
"7, ~ d Current.kepeater l' .
--l .
' l 1983, subaittal . !
l/,
-- ^
l / l l - l
. 't -
'l , y ll e, . l I l/
i I
l i I Ic ,, -7., I I I I , I
(. ' I
,- ,. .' I I
I i
I l
I l
/
l V '.
t,, l l 7,& 'l, I
?[' I l.
I i
I I I
' I I
- 1, v 7 1 I l l
b,t es i I I,s
~
J I/.i i l
i i 1 i
' i l-I '
l- ^
.1 -
- I 1
I l i i l r - - l I l' I I 1 Page 7 of 9
-*J,00 Acceptable in TER
i ENCLOSURE 2 ,
TED CATEGORY I.B.
(continued) l l l l l l l ' Component / I TER l SCEW I l l l Manufacturer l Number l Number I Designated Deficiency 1 Method of Resolution i I I I I I I I I I I I I I I I I I l
.I COMSIP-DELPHI l 203
- I 223H-024 l No schedule provided for l Analysis has been performed to demon- l lH2 Analyzer l l l modification / analysis. I strate qualification. No modification l l l l l l i s required. I I I I I l l l l The H2 analyzer is located outside l I l l l containment in Room 304. Equipment is l l l l not needed to mitigate the HELB in this l l l ,
l vicinity. Only harsh environment in i l l l l - l which the equipment is required to l l l l l l operate i s for post LOCA H2 l l l l l l monitoring. Calculations show that when I l l l l l taking all radiation sources within the l l
l l l Analyzer cabinets (no external radiation l l l l l sources affect this area) thakt the 40 l l l l l l year background plus 1 year accident dosel l l l l to the electronic components within the l l l l l cabinet is less than 1000 rads and doses l l l l l l to non-electronic electrical equipment l I l l l l experience total accident plus backgroundl l l l l l doses of less than 10,000 rads. l l l l l l Therefore this equipment i s located in a l I l l l l mi.ld environment. Additionally, failuresi l l l l l would not prevent sampling and analy si s l l l l l l since grab samples can be taken for this l l l . l l purpose (reference procedure AD 1850.04).I I I I I I h I I I I l
1 I I I I I I I I I I I I I I I I I l
, CJC0 Acceptable in TER Page 8 of 9
F' s t
. ENCLOSURE 2
- W :
.,. 1 1_ W ~~ ~ '
TED CATEGORY I.B.
7-a~~
s
.; (continued)
~
--C M 4' u -
.l 'A. k. et L. _ ; .I .
l 1- . I 1; ' Cosspcnent/ . A . TER g 1 SCEW l~ ,l l l' , Manufacturer l~ Number';l Number l Designated Deficiency 1 Method of Resolution l
,g v 2 a g-g l [
C i l- -- l . ..
T+
l l l 4 f3. l ' _4 ~l- _
- _l l l
' l' r . l s . - l l
. I 1 ll* Westinghouse l 205
- l -221H-027; l To be tested or analyzed by # l These MCC's have been qualified based on I
'laMotor Costrol, Centersi "-
l analysis,a certificate of compliance
%l R ' <l,1/1/83. l
'Wl4%
ff ;l
~
- l : 206 W *J l 221 H-022 i l ' ' ' ' ~ ,_
~
t l-and a statement of qualified life for _ l ,'
' I- Ni 1 221H-025 l ,1 Equipment Qualification based'on 'l '
, %l g: -- i -
l -l 221H-028 l r -
'I analy si s is available. Additional l 7 i 41 %
'" --l' . . . l - wt I report based on a performance test on l IW s l 207.* 3 221H-023 l - - .- .1,used devices taken from DB-1 type W l N } ' l -,c --
u4 Ff' , W l ' l 221H-024 l l'MCCs is scheduled to be available by -l 1221H-035 l l 9-1 -84. Qualification data will be
~
l
- T
' >Q l'.208
- l 221H-036 l
.I l'f ' .-
'. n l incorporated by 11-30-84. !
I
, l l l l' l1 221H-026 l .
^ l l
, "gp --
V l 1: 1 1 1
. si l l l l l
( :l' i l l l -
l l
'l
~
'~
-l
, l li. l l l , . 4, n. V ,l f '
l ," W I -"
. I i a e -1 u 1...g 2 : l - -
g [w >IN . . g; g ,l, -l j s.
7 l l l l
- - -r y^ ;, _
-l~- - y, .
.i
.g -
14 -
m 1;
g_
- , i i
, l i l T : 1-. lE l >
.I l "l'
I I ; I l I
.1 l .
.I L I l l
IN u <
l' '
-l l . .
, I 1, x l l l l t
l l~ . I - - 'i .
~
-l l l
- l q at w lv 7 l l- i i I , 7 I .I l l l
~l -
1 I :l l 1
<l 1 l- l l- l
- JCQ Acceptable in TER Page 9 of 9
ENCLOSURE 3 ,
TED CATEGORY II.A.
.I I I I I i l Component / l TER I SCEW l .I l l '" Manufacturer ) Number l Number l Designated Deficiency i Method of Resolution I l- 1 I l~ l' l l~ l l I I l l REES . . I 2- l 221H-179 l Exemption deficiency. I See generic item G-9 for di scussion I l . Pu shbutton Switch l l l Aging / radiation analysis l resolving exemption deficiency. See I
- l _- -l 4 1 221H-180 l deficiency. I generic item G-1 for discussion resolving l l- l l 221H-181 l l aging / radiation analysis deficiency. l 1 l 1
- 5 221H-241 1 I I 221H-242 l l
-l I l . l l 1 l- l 7 , l 221H-244 '
l l l l l 221H-245 , ,- 1 l l l l 221H-246 I I l l- 1 I I I l 8 l 221H-177 l l l l- l 221H-178 l l l l ,
l 221H-191 ,
I I I I i l l I l l 9 1 221H-216 l l l l l 221H-222 l l l
'l l 221H-224 l l l l l l 1 l l l l 10 1 221H-250 l l l l l l 221H-261 l 1 l l l l 221H-237 l l l l l l 221H-236 l l l l l l 221H-208 l l l l l l 221H-211 l l i l l l 221H 212 l l l l 1 1 I l l l l 14 l 221H-214 l l l l l 1 16 221H-235 l l Items 221H-234 and 221H-235 have been l l l l 1 1 deleted as they have been replaced by l l l l l l another monitoring system (Kaman l l l l l Sciences).
i l l l. I I
- JC0 Acceptable in TER Page 1 of 13
ENCLOSURE 3 ,
TED CATEGORY II.A.
I I I I I I l Component / l TER l SCEW l l l Manufacturer l Number l Number l Designated Deficiency i Method of Resolution 1 I I I I I i l 1 1 I i l l REES l 17 l 221H-200 l 1 l l Pushbutton Switch l l 221H-227 l l 1
-l (continued) I i l l l l 1 20 1 221H-199 l l l l l l 221H-226 l l l 1 1 I I I I I I 24 l 221H-201 l l l l l l 221H-202 l l l l l l 221H-203 l l l l l l l l l l l 25 1 221H-183 I l l l 1 l 1 I l l 26 221H-234 l l l l l 221H-182 l '
l l l l 1 I l l l 27 l 221H-238 l l l 1 l 221H-251 l l l l 1 30 1 221 H-217 l l l l 221H-232 l l l l l 1 l l l I 1 32 l 221H-219 l l l 1 I I I I I l 33 1 221H-217 l 1 1 I I i 1 I I I I I I I I I I I I I I I I I i l I I I I I I I I I I I I I I l l l l l l 1 1 I I I I I I I I I I I I I I
,I I I I I l OJC0 Acceptable in TER Page 2 of 13
. ENCLOSURE 3 TED CATEGORY II.A. -
=
l' l- 1 I i l i _ Component / l TER l SCEW l l l
'l- ? Manufacturer Number I Number Designated Deficiency Method of Resolution I i l I
'l l I I I I l REES. .
l 34 1 221H-219 - I l 1.Pushbutton Switch l l 221H-240 l l 1-(continued) l I 221H-239 l l l l l 221H-204 l. l l l~ l 221H-205 l 1 I
.I l. I 221H-206 l l 1 l l l 221H-207 l l l
l l l -l l 221H-230 I l l
' l- l l 221H-229 l l l 1 -l l 221H-225 l l l l l 1 l- 1 I l <l i I i . I l l Microswitch . l 15 l 221H-188 l Exemption deficiency. Aging / l Equipment has been deleted. Equipment l
- l Pushbutton Switch l l l radiation analysis deficiency.1 has been replaced with another monitoringl
-l ! 23 , 221H-189 l l system (Kaman Sciences). I I I I 1 I I I I I I l l Cutler Hamer I 18 l 221H-194 Exemption deficiency. I TER states that equipment associated l l Pushbutton Switch l l 221H-195 l l with the MSIV operation must be I l l l l l qualified for the environments to 1
-l l 19 l 221H-193 l l which it may become exposed. FMEA I l l l 221H-192 l l analysis on the switch and circuit has l l l l l l been performed which supports the l l l. l l l exemption. l I I I I I I l- 1 l l l l- 1 I l l
'l. l l l l l 1 I I i l l l 1- 1 I I I I I I l l I I l' I I I I I I I I I l
. OJC0 Acceptable in TER Page 3 of 13 n
ENCLOSURE 3 TED CATEGORY II.A.
o l I I I I l l Component / .l TER .I SCEW _l l. I Designated Deficiency Method of Resolution
~
Manufacturer Number l Number -
.I l I I I _I l Analysis has been performed to justify L l Boston Insulated 1 37 l 221H-171 l Aging-qualified life l 4 l Wire Cabling l l thrcugh I deficiency. Submergence I the 40-year qualified life. All l l l l 221H-175 1 deficiency. l cabling inside containment is housed in l i
i l l l I conduit. Submergence analy si s has been l l 1- 1 l l performed. All components which are l I l l l l located below containment flood level l l l 1 l l have been identified as well as the l
'l' i l i I cabling which serves these components. l 1 l l l l The effect of cable submergence failures l l l .1 l on the equipment served has been analyzedi l 1 -1 i l and found to cause no additional l l l 'l l Failure would not adversely l safety-related failures or mislead the i 1 l' l l impact safety functions or l operator. Based on this inalysis the l 1 I i l mislead the operator. I cables can be exempt from suomergence l l 1 l l l qualification as its associated 1 l' ,
l l l .
I components would have performed their l l l l l l function prior to submergence or their i ! 'l l l subsequent submergence would not impact l l l l l safety functions or mislead an operator. l l i i i i l
- l.0konite Cabling 'l' 38 l
- 221H-012 l Documented evidence of l Additional data reference has been pro- l l 'l I 221H-013 l qualification deficiency i vided to SCEW sheets to demonstrate test l l l. l l 221H-020 l (test report-applicability). I report applicability. See item 37 for i ,
I l l .1 Submergence deficiency. i method of resolution for submetgence l
- I l l l deficiency. l l'
l l l l I I .
I I I I Kerite Cabling 39 l 221H-037 l Documented evidence of l Additional data reference ha s been pro- l l through l qualification deficiency i vided to SCEW sheets to demonstrate test l l l l 221H-050 l (test report applicability). I report applicability. See item 37 for l l l l l Submergence deficiency. I method of resolution for submergence !
l l l 221H-065 1 I deficiency. l
'l .l l through l l l 1 l l 221H-069 l l l l' I I l 1 i
' *JC0 Acceptable in TER '
Page 4 of 13
_ ___ .~ _ . _ _ _ _ . - - - --
ENCLOSURE 3 TED CATEGORY II.A. ,
I i l
'l l I
'SCEW I l l Component /' l TER I 1
Designated Deficiency l Method of Resolution l l Manufacturer l Number 'l Number l I
I I I I I I I I 1 1 l l l l - Kerite . Cabling 1 40 1 221H-014 l l l through l l l (continued) l l
l l l l 221H-018 l 1 l 1 l l l 1 l l l l 221H-021 l 1 1 1 l l 1 l l
I I l .221H-029. l l
- l. 1 -l through 'l l l
[
I I I 221H-034 l I I
I I I 1 I I i 1 I i
l 41 l 219H-007 l Adequate similarity between l Additional reference data has been l Foxboro I through I component and units which I added to the SCEWs to demonstrate test l I Transmitter I: 1 report /MCA series applicability. See l
.) Model E11GH l l 219H-010 l underwent testing. Aging-I l qualified life deficiency. I generic item G-1 for a discussion re- l l .
I I solving the aging methodology deficiency.I l Model E11 AH - l 43 1. 219H-006 l ' l Components have a short qualified life. I
- i. l' i l l This will be handled as follows: l I l 44 l 219H-005 l I I l' I I i 1. Similarity analy si 5 will be performed l ;
I 45 l 219H-004 l l
.1 l l 1 to demonstrate that sufficient I l l similarity exi sts between Foxboro I
'l l I l l- l E-10 series and Foxboro N-E-10 series !
- I l l transmitters to allow the assignment I l l I l l l I of the qualified life of the N-E-10 l
< l l series to the E-10 series transmitter.1 l l l I l This will be completed by 3/1/84. i l I I l l I I I I 1 I l l l 2. If similarity proves unsuccessful, l
.1 l l l then analysi s will be undertaken to l l l l determine if it is possible to l I l l l I i l install a qualified N-E-10 series l l l I
l l l amplifier in an E-10 series trans- 1 l l l l 1 mitter.
I l l l I
l' I I I
Page 5 of 13
- JC0' Acceptable in TER
ENCLOSURE 3 TED CATEGORY II.A.
i l l . I I I
. Component / TER l SCEW l l I l l l ' Manufacturer l Number .I Number l Designated Deficiency l' Method of Resolution 1 i l l I I i
I I i l l I l Additional analy sis has been completed l General Electric l 59 l 205H-005 l Documented qualification I i Motor (ECCS Room l l l evidence inadequate. I utilizing a detailed material s list 1
-l Unit Cooler Fan ] 60 l- 205H-006 l Similarity deficiency I supplied by the manufacturer to demon- l l Motor)- 1 I 205H-007 i radiation / aging qualified I strate qualification for these compon- l l l l l .11fe analy sis deficiency. I ents. I 61 1205H-008 l Lubrication and splices not l l I l l l 1 205H-009 l addressed. These motors are ECCS Room Cooler unit l l l l l fan motors located in Rooms 105, 113, I I l l l l 115. Motors are subjected to a mild HELBl l l l l l and post LOCA recirculated fluids l I l l l l increased radiation. The motors are l l l l l l rated as NEMA design A with an ambient l l l -l l I temperature rating of 70*C/158'F. The l l l l l l transient in the rooms peak at 130, 155 l l l l l l and 177*F respectively. The room's l 1 l l l .
' l pressure peaks at 0.9,1.36, and 1.36 l l l 1 I psig respectively. The transients last i
_l l l l l l for 6.7, 6.7 and 24 minutes l l l l l l respectively. The motor specification l l l l l ! call s for a heat shock acceptance test of f I l l l l the polyesterimide stator winding of I l l l l l 200*C/392*F for 30 minutes. The mild l l l l l l steam HELB harsh environment should not i l l l l l adversely affect motor operation. See l l 1 l l l generic item G-1 for adiscussion l I l l l l resolving the aging /radiationanalysis l l l l l l deficiency. Motor lubricationand splicesi l l l l have been addressed generically in l l l l l Chapter 2.21 of theE.Q. Manual Rev. 2. l I I I I l l l~ l i I I I I I I I I I I I i l ei I l l l l l l' I I I l l
- OJC0 Acceptable in TER Page 6 of 13
A ENCLOSURE 3
~
,TED CATEGORY II.A.
l .
I I .I I lj Component /. l .TER l SCEW l l
l l
- 1. Manufacturer l Number -l Number l Designated Deficiency I
1 Method of Resolution l 1.
I -1 I 'l i I I I I l General- Electric LI 62 I .206H-004 ) Documented qualification l Additional analysis has been perfonned l
l Motor (lE Switchgear l l l evidence inadequate. I to demonstrate qualification for this l
l Room Ventilation 1 I i Similarity deficiency l device despite. the fact that the l
l Fan Motor) l 1 i radiation / aging qualified l exemption argument provided is felt to l l 1 1 life analysis deficiency. l be justified.
l l l' l Lubrication and splices not l l
l l l l addre ssed. Plus exemption l l This component is a vent fan supplying I l analy si s questioned. I backup ventilation to Room 428 (1E l l l l 1 l Switchgear room). Material s analysis hasl l l l l been performed for qualification for l l
l l l l thermal aging and radiation. l l l 1 1 1 1 I i l l This motor is a 2 horsepower, continuous l
'll l l l l duty, totally enclosed, air over cooled 1 l-I l l l
I motor, rated NEMA design B with a Class FI l l l I high temperature insulation system. Thisl i 1.
l l l l motor is not utilized during normal plant l l l
'l l 1 operation and is operated only during l l l .I l emergency conditions. Room 515 l l l
l l
l l conditions peak at 203*F and 15.6 psia l l l l
.l l l in 40 seconds and return to ambient in l i
l l l approximately 18 minutes. The low 1
.I i 1 l pressure of less than 1.0 psig and the l l l l- 1 1 100% relative humidity will not affect l ' l l'
l l. I this totally enclosed motor. Class F l l l l insulation systems are rated at 155*C l l .I. l l l (311*F) continuous duty. An 18-minute l l l
1 l l l transient peaking at 203*F will not be I
l l l l approaching the thermal limit of the !
l l 1 l insulation system. The motor leads are l l .I l~
l 1 l attached with qualified heat shrink l l i l I connections. Bearing lubrication is l l l l 1 l l l addressed is addressed through normal l l l l plant maintenance procedures.
I I I I I
, * *JC0 Acceptable in TER Page 7 of 13
ENCLOSURE 3
.TED CATEGORY II.A.
i l I I i i l l l Component / l TER I SCEW l Manufacturer l Number l Number i Designated Deficiency l Method of Resolution l l l I I I l I
I l 1 I I l l
.I I l General Electric l l l Although we feel thi s motor i s qualifled,l
~l Motor (IE Switchgear l l l l
l 1t is exempt because the harsh l 1 Room' Ventilation l l l environment seen by this component is duel I Fan Motor) ! ! 1 l to a main steam to auxiliary fed pump l 1.(cont.) l l l l l l l l turbine line break. This ventilation l l l l l fan, MC0712, is a backup ventilation l I
l l l l g stem for Room 428 located in Room 515. I l
l Cooling of the 1E Switchgear Room 428 is l l' I l l l normally supplied by equipment located in' l l l l l l l l l Room 516. Both of these rooms are (
I non-harsh and would not be af fected by I
l l l 1 l l l' I thi s high energy line break. The !
l l l l component is exempted from qualification i l i l l l since its failure would not affect normall l l l l .
l Ventilation. It does not perform l l ! l essential safety functions and its l l l l l l l l failure in the harsh environment would l l l l l not mislead the operator. See generic l I
l l l -l I item G-1 for a discussion resolving the l l l l l l aging / radiation analysis deficiency. I l l l l l Motor lubrication and splices have been I l l l i i addressed generically in Chapter 2.21 of l I l l 1 1 the E.Q. Manual Rev. 2. I 1 1 I l l l i l 1 I i i i 1 General Dynamics l 63 l 214H-005 l Radiation / aging analysis l See generic item G-1 for a discussion l l Motor (Containment 1 l l deficiency. Lubricant and I resolving the aging / radiation analy sis l i Spray Motor) l 64 1 214H-004 l splices not addressed. I deficiency. Lubricant and splices l l have been addressed generically in 4
l l l l l 1 I l I l Chapter 2.21 of the E.Q. Manual Rev. 2.. l 1 1 l l l l I I I I I I 1 l I l l l l l l l l l
- JC0 Acceptable in TER Page 8 of 13
ENCLOSURE 3 TED CATEGORY II.A. -
l .I I I I l
-l -Component / l TER l SCEW l l l l . Manufacturer ' i Number -l _ Number l Designated Deficiency 1 Method of Resolution l l l l l 1 1 I I I 1 I l l .Wastinghouse Motor l 65 l 210H-007 - 1 Similarity deficiency. l Additional references have been added I l .(Decay Heat / Low l -l l Aging-qualified life I to the SCEWs to demonstrate similarity l
- 1. Pressure Injection) l 66 l 210H-006 1 deficiency. Lubrication- l of motor. Aging-qualified life i ,
I l 'l i bearings and splices not I developed using referenced test data l 1 1 l . I addressed. l and plant operating time. Lubrication- I ,
l I .I l l bearings and splices have been addressed l l l- l l l generically in Chapter 2.21 of the E.Q. l
- l. l .I l l Manual Rev. 2. l I I l l 1 1 I I I I l Westinghouse Motor I '67.* l 211H-005 l No schedule for completion of 1 Additional references have been added l I (High Pressure l l l additional analy sis. Docu- l to demonstrate similarity of motors.
1 Injection) l 68 * -l 211H-004 l mented . evidence of qualifica- , Additional analy sis has been completed 1 -l. 1 l tion, similarity, aging- ll to demonstrate qualification for this l l l 1 l qualified life, and harsh I device. Aging-qualified life deter- l l l l l steam envionment deficiencies.1 mined using referenced test data and l l- l l -l Lubrication-bearings and l plant operating data. Lubrication- l 4 I i _l l splices not addressed. I bearings and splices have been addressed 1 1 -l l l l generically in Chapter 2.21 of the E.Q. I t
I- l l l l Manual Rev. 2. l '
4 I i l l l 1 I. I I I I l l Westinghouse Motors l' 69 l 215H-008 l Aging-qualified life l Additional aging and qualified life 1 l (H2 Dilution) 1 l I deficiency. Lubricant-bearing l analysis using test data performed l 1 -l ' 70 1 215H-007 l and splices not addressed. I to demonstrate qualification. l
, I l l l l Lubrication-bearing and splices l 4
l l l l l have been addressed generically in l l 1 l l l Chapter 2.21 of the E.Q. Manual Rev. 2.. l l l l l l l l 1 l l 1 l l l l l l l l 1 l l 1 l l l l l l l 1 l l l l l l- l l I l l NCO Acceptable in TER . Page 9 of 13
ENCLOSURE 3 ,
TED CATEGORY II.A. .
l I I I I I l~ ' Component /- 1 TER I SCEW l l i
, l Manufacturer l Number i Number 1. Designated Deficiency I Hethod of Resolution 1 :
i l l' l I l i l, . . I I I I l l Voy/ Reliance 1 71 1 217H-004 l Similarity deficiency. I Additional references have been added to l l Fan Motor- l l 217H-005.1 Inadequate basis for limiting i the SCEWs to demonstrate test report i l (Containment Air i l 217H-006. l. component thermal aging i applicability. Thermal aging-qualifi- l l Cooler and Contain- l l- l analy si s. Surveillance and l cation has been reviewed. Surveillance 1 l mont Recirculation ! 72 l 215H-005 l maintenance program data for I and maintenance program for maintenance l l of equipment qualification i s being 3
! 1_ Fans) l- l 215H-006 l motor-splice-lead cable and l i l I bearing system not provided. I developed. Test report material s l l l l No insulation life character- l analysis has been reviewed and the l l 1 l l 1stic plot provided. Test i insulation system is the limiting l l' l _l l report radiation valves I component. Radiation data has been I
- l l l l could not be checked because l checked using Appendix A and F which l i 1 'l l I they were not identified by I identified the materials by name and l
.l l l 1 material (only Reliance I reliance part number and the analysis was!
l l l l specification number I found to be sati sfactory. Based on this I i l I i provided). I materials analysis the motor is felt to l l- l l l l be full qualified. l l nercola i as I zian-ulJ l it.K states that Decause the I Add 1tional c1 art tication has been added l l Pressure Switch l l l switch measures containment I to the SCEW to demonstrate qualification l I l l l atmospheric pressure that it I for thi s component. Components aging l I and radiation analysis has been revised. I
, I l l l must be qualified for LOCA.
i i l l ! Qualified life calculation i See generic item G-1 for di a:ussion. I l 1 -l inot available.- l l t .I ,
I I i .
I I I Static-C-Ring i 88 -l 220H-023 l HELB qualification analysi s l See generic item G-1 for a discussion l l l - Pre ssure Switch l l 220H-030 l inadequate. Aging-qualified I resolving the aging-qualified life l E ~l,(SFRCS Inputs) l l .
I life analysis deficiency. I deficiency. See generic item G-2 for l
, I l 'l through I surveillance and maintenance. I fication by analysis deficiency. l I l l 220H-022 l l Surveillance and maintenance program I l 1 s in development. Maintenance instruc- l
, I l l l l l l l l tions will be revised such that the l
- I l l l l gasket seal on these pressure switches I l .. l l l l 1s inspected at each switch cam 5 ration. l 4
I I I I I l CJC0 Acceptable in TER Page 10 of 13
~
- .-.-a
ENCLOSURE 3
- TED CATEGORY II.A.
l 1 i .
I I i Component / l TER I SCEW l l l 1.
l Manufacturer l Number l Number i Designated Deficiency Method of Resolution l il i I l 1'
I I I I i
'I'l Static-0-Ring I 92 l 220H-024 l l l l through l l l i Pressure Switch l l (SFRCS Inputs) l l 220H-029-l l l l . (continued) l l. l l l
, I l -l 220H-031 l l l 1.- l l through l l l l l .I 220H-040 l l l
' I l l l I l Static-0-Ring l 89 l 223H-016 l Exemption deficiency. TER l See generic item G-9 for a discussion l l Pressure Switch l l l states that since these I resolving the exemption deficiency. l
, I l 90 1 223H-015 l switches measure containment i Additional clarification has been added l I l l l pressure, they must be quali- l to the SCEWs to demonstrate qualifica- l t
l l l l fied for LOCA exposure. I tion. Aging and radiation analysis has l l l l l Calculation of qualified life been revi sed. See generic item G-1 l
- I l l l not available. I for discussion resolving the qualified l l l l .I I life deficiency. Maintenance instruc- l l l l l l tions will be revi sed such that the I
- 1 l l l l gasket seal on these pressure switches isl l l l l l inspected at each switch calibration. l 1 I I I l l l States 1 1 01 .l See-5/20/l Test report data provided. l The test report has been obtained and 1
-l Terminal Block i 102 l 83 TER l Test report was not available i is available in the qualification file.
I (Outside contain- l 103 l response I for review. I i 1- ment) I 104 1 for i l i l i 105 l li sting. I l l l' l l l l l 1 Stanwick i 106 i See 5/20/1 Test report not available for l Pertirent qualification information l l Teminal Block .Ithrough l 83 TER l review. I have been obtained from the owner of l (Outside contain-- I .114 - l respon se l I the test report and compared against I
- I ment) l l for i i the Davis-Besse parameters to establish l I l 116 l li sting. l l qualification. Efforts are underway to l j l lthrough l l 1 obtain the test report. l
- I l 119 l. l I I 1 1 I I I I I i i i I i l i
~ NJC0 Acceptable in TER Page 11 of 13
ENCLOSURE 3 TED CATEGORY II.A.
I I i I I l l l Component / I TER I SCEW l l
l Number i Designated Deficiency i Method of Resolution l l Manufacturer l Number I l
l 1 I l I l
l l 1 l
l 221H-1521 Aging / qualified life l See generic item G-1 for a discussion l i Raychem i 115 l deficiency. Submergence I resolving tht: aging / qualified life defi- 1 I Splice l l I deficiency. I ciency. Additional analy si s has been l I (WCSF Heat Shrink) i 1 l l performed to address the submergence l
'l l l l deficiency. I l -l l 1 i
I l' I I I I I l
1 I 1
l 204H-0101 No schedule provided. Aging / 1 Schedule has been provided in the May 20,1 l Limitorque i 124
- l radiation analysis deficiency.1 1983 submittal. Operators are scheduled I i Valve Motor Operator 1 i l for brake coil or motor / brake replacementi i l 128
- l 204H-012 l I as required. Additional analysis has l l l i i l been performed to resolve the l l l 134
- I 210H-015 l l aging / radiation deficiency. See generic l l l l l l discussion item G-1 for detail s resolvingl l l 136
- l 210H-014 l l the aging / qualified life deficiency. l i l l l I
.I i 138
I I 1 51
- l 204H-011 l I
i I I I l i l
1 1 165
- l 204H-009 (
I i
I I I l
i i I i 1
l 208H-026 i Exemption failure mode l Component to be replaced in accordance l i ASCO l 1 81 I with schedules provided in May 20, 1983, 1 I Solenoid Valve l l l analysis questioned.
l 182 l 208H-025 l l submittal. FMEA to justify continued l I
l l l operation included in the E.Q. Manual. l I l l 184 l 208H-020 l l See Generic discussion item G-3 for JC0 l 1 l through l I discussion. l l
l 208H-024 I i l l '
l l .I I I l
l l 185 1 208H-014 l l l 1 l through l l l
l l l l 208H-018 l l I I I I I Page 12 of 13
, *JC0 Acceptable in TER
. .. . .. - .,- - . - - ~ -- ~. - - . _ - . . -
ENCLOSURE 3 ..
TED CATEGORY II.A.
l i i l i l 1- Component / l TER l SCEW l i I l Manufacturer l Number l Number l Designated Deficiency i Method of Resolution i t
I I I I i l "
l- 1 I I i ~l l Amphenol I 21 0 l 221H-267 l Aging-qualified life deft- 1 Additional analy sis has been performed i I Electric Penetration l l through I ciency. Chemical spray I to resolve the aging-qualified life l l Assembly -l 1. 221H-284 l deficiency. Functional i deficiency. See generic item G-1. l l l l l testing deficiency. l Additional analy sis has been added to l l l l l 1 the SCEWs to resolve the chemical spray I l deficiency. Additional Amphenol test l l l l l '
"l . l l l l data has been submitted as well as l l -l' l i l analysis which substantiates the I <
l l l l l qualification of the penetration while l l l l l l energized. The analysis shows the most l l l l l l limiting case (i.e., highest heat up) l t i l l l l and this value of heating when added to i 1 l l l l the postulated LOCA temperature is less l l l l l than the test report temperature. l l
I l l l l A response has been transmitted to the i l l l 1 -
l NRC for this equipment. Ba sed on the !
l I l l l additional test data and analysis we 1 l l l l l feel this equipment is qualified. l l 1 1 1 l- l l l l I
l l l l 1 l 221H-243 l Exemption deficiency. Aging / l See generic item G-1 for a discussion
! REES l 21 2 I l Pushbutton Switch l l l radiation analysis deficiency.1 resolving the aging / radiation deficiency.1 l l 21 3 l 221H-190 l l See generic item G-9 for a discussion i l l l l 1 resolving the exemption deficiency. l l l 21 4 l 221H-257 l (213 and 214 only) l (213 and 214 only) l l l l 1 Failure mode exemption anal- l Failure modes and effects analysis has I l l l y si s questioned. I been reviewed and found to be valid. I l i 1 1 l l I I I I I I l l l 1 I I I I I I l t
i I l- I I I l I I I I I I I I I i l
- *JC0 Acceptable in TER Page 13 of 13 o_ - _
L ENCLOSURE 4 ,-
TED CATEGORY II.C In the revision of the TED E.Q. Manual a comprehensive review of all components was performed. Thi s review utilized Arrhenius methodology to determine the qualified lives of all the components either by utilization of test report heat aging data or by analysis of vendor supplied data. The results of this analysis has been incorporated into E.Q. Manual Revision 2 so that all components have had their qualified lives re-established and replacement periods are redefined.
d Page 1 of 1 O
a
ENCLOSURE 5 ;
6 TED CATEGORY IV i i I I I i l' Component / _l 'TER l SCEW l l I I Manufacturer i Number l Number i Designated Deficiency 1 Method of Resolution i
.I I I I I I I I I I i l Rosemount/ 46 _ l 218H-019 l Documentation not available. I Required document (general reference AG).I i 177 HW RTD I I through l I was forwarded with May 20th submittal. I l i 218H-022 l ,
1 1 1 I I I I I I I I I I I I I I I I I I I I I I I I I I l I I I I I i l l ,
I I -
1 I I I I I I I I I l l l l l l l l l l l .
I I I l i I I I I I I I I I I I I I I I I I I I I I I I I I I i 1 I l I I I I I I I I l l' I I I i l i i I i ! -
1 I I I I I l l I I l l l l l l l l l l l l 1 1 I l I i l l i l i I i I i i l I I I I I I I I I I I I I I I I I I I I I- I r 1 I I I I I
(" )
o-
-1 O
ENCLOSURE 6 RESPONSE TO EQUIPMENT QUALIFICATIONS CONCERNS JUSTIFICATION FOR CONTINUED OPERATION During our meeting, on December 13, 1983, we were requested to respond within 10 days on two specific items regarding their qualification status, and justification for Continued Operation. The items are Amphenol Pene-trations (TER item 210) and ASCO Solenoid Valves (TER items 181, 182, 184, and 185).
With regard to the Amphenol Penetrations, we had indicated that " additional efforts were underway to resolve the functional testing deficiency" where the penetration was not energized and conducting current during the LOCA profile testing.
We have located and reviewed additional Amphenol test reports which resolve this test deficiency.
Thermal load tests were performed by Amphenol with 37.67 Watts /f t generated by current flow. At Davis-Besse heat generated by current flow is between 1.99 and 29.96 Watts /ft. The temperature rise due to the test current was 270F. The temperature rise at Davis-Besse will be less than the 27oF.
. Thermal cycle tests were performed 'o which show that the penetrations can -
survive temperatures to 3500F and still perform their intended function.
The 270F conservative temperature rise due to current loading _ combined with
- our LOCA profile maximum temperature of 2830F is 400F less than the 3500F thermal loading test. On this basis, we deem the penetration to be fully qualified.
With regard to the ASCO Solenoid Valves, we have additional analysis to justify continued operation. The solenoid valves in question are those which when denergtzed close the Main Steam Isolation Valves (MSIV) to prevent the blowdown of two steam generators and thus maintain heat removal capability.
A test has been conducted on ASCO Solenoid Valves HTX8320A20V by General Electric, which are identical to those installed at Davis-Besse. The ' results of this test (Rockwell Test Report #2792-03-02, Rav 1)'show that the valves survive in an harsh steam environment at 3400F for 2 hrs. Room 601 tempera-ture peaks at 2800F for(1sec and stabilizes at 2000F for 50 cec then
- decreases to ambient temperature in ' 7000 cec. Room 602 temperature ' peaks at 3440F for ( lsec and drops to 2100F at 2sec and stabilizes for 50 cec then decreasing to ambient temperature in 3400sec. 'This time period and: tempera-ture profile will . allow the valves to perform their intended safety function.
late design is'such' that if anh so:enoid valve should fail due to a s[eam line ,
break (by moving to its fail safe p3sition, or by not moving at all)-it will
~
not prevent the MSIV from closing. 'Aberefore we can sustain a failure of- the
- . single solenoid valve.
e I ', J. ,
s.
k-
(
ge In addition, further analysis was performed to show that should multiple failures of solenoids valves occur due to a main steam line break; and p revent the MSIV from closing, we would still be able to isolate the unaf-fected steam generator from the worst case main steam line break (a break between the containment and an MSIV.)
This analysis utilizes a previous study performed on the Non-Return Valve which shows that it will close and not fail should such an event occur.
This provides two valve isolation (Main Turbine Stop Talves and the Non-Return Valve) to citigate this event.
NUREG 0136 " Davis-Besse Nuclear Power Station Unit 1 Safety Evaluation Report" December 1976 Section 10.3 " Main Steam Supply System" pg 10-2 contains state-ments on the Non-Return Valves.
There are two other ways to detect smaller steam line break in the main steam line Rooms 601 and 602. The first would be by the fire detection system located within each room. Room 601 has 34 detectors and 602 has 8 detectors. All detectors are ionization type. Any steam reaching these detectors would actuate the fire alarm for the assoctated room. These detectors are maintained in accordance with our Fire Protection Program.
his has been verified every time the steam safetv valves or atmospheric vent valves actuate which causes a steam environment to Rocms 601 and 602. The second method is provided by the sound from the steam leak.
When the operator determines there is a steam leak, the following actions will be taken:
- 1. If personnel safety is in question the operator will trip SFRCS manually which trip the reactor and closes MSIV's.
- 2. If the steem leak is small and no personnel safety is involved the operator will shutdown the plant in a controlled manner.
This provides justification for continued operation until the affected solenoid valves can be replaced with qualified solenoid valves during our 1984 refueling outage.
2
.