ML20091N431

Forwards Documentation of Discussions Held at 840323 Meeting Re Environ Qualification of safety-related Electrical Equipment.Documentation Includes Proposed Resolutions to Deficiencies Noted in 830111 Draft SER

ML20091N431
Person / Time
Site:	Fort Calhoun
Issue date:	05/31/1984
From:	William Jones OMAHA PUBLIC POWER DISTRICT
To:	Harold Denton Office of Nuclear Reactor Regulation
References
LIC-84-121, NUDOCS 8406120311
Download: ML20091N431 (60)

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Omaha Public Power District 1623 Harney Omaha, Nebraska 68102 402/539 4000 May 31, 1984 LIC-84-121 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C. 20555

Reference:

Docket No. 50-285

Dear Mr. Denton:

Environmental Qualification of Safety-Related Electrical Equipment On January 17, 1983, the Omaha Public Power District received the Safety Evaluation Report (SER) regarding the environmental qualifi-cation of safety-related electrical equipment at the Fort Calhoun Station Unit No. 1 (letter from R. A. Clark to W. C. Jones dated January 11, 1983). This SER contained a Technical Evaluation Re-port (TER) written by Franklin Research Center, while under con-tract with the Nuclear Regulatory Commission. This TER noted a number of deficiencies for safety-related electrical equipment. On March 23, 1984, a meeting was held with your staff to discuss the proposed resolutions to TER-identified deficiencies. These proposed resolutions, as discussed, are provided in Attachments 1 and 2 to this letter. Discussions were also held at the March 23, 1984 meeting regarding the District's general methodology for com-pliance with 10CFR50.49, " Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants". The pur-pose of this letter is to provide documentation of the discussions held during the March 23, 1984 meeting. contains the Justifications for Continued Operation (JCO's) currently being relied on by the District. These JCO's were most recently submitted to the Commission in a letter dated April 3, 1984 (Jones to Denton, LIC-84-093) which requested an ex-tension to September 30, 1984 to complete specific equipment quali-fication items. The District has included, in Attachment 3, a discussion of the methodology used for compliance with 10CFR50.49(b)(1), (b)(2), and (b)(3). A list of safety-related electrical equipment, as defined in 10CPR50.49(b)(1), was generated. This equipment is that which is required to remain functional during or following a design 8406120311 840531 PDR ADOCK 05000205 P PDR 0 Iv f g I i 45.St24 Employmen h at Opportumty

g 4 Mr.. Harold R. Denton LIC-84-121 ~ Page.Two - basis loss of coolant accident (LOCA) or a high energy line break (HELB)-accident..The LOCA/HELB accidents are the only design basis accidents which result in significantly adverse environments to electrical. equipment required for safe shutdown or accident mitigation. The list was based on reviews of the Final Safety - Analysis Report (FSAR), Technical Specifications, Emergency Oper-ating Procedures, Piping and Instrumentation Diagrams (P&ID's), and electrical distribution diagrams. The District conducted a review of electrical equipment to determine the equipment falling within the-scope of 10CFR50.49(b)(2). The results and methodology for this review are as described in Attachment 3, Section IV. Equipment within the scope of 10CFR50.49(b)(3) will be handled on the schedule negotiated for Regulatory Guide 1.97 equipment. Further information on this can also be found in Attachment 3, Section V.- The District believes that the post-accident environ-ment assumed for the purpose of the-equipment qualification pro-gram envelopes the worst case conditions and those environmental profiles and assumptions have been approved by the Commission. It is the. District's belief that the environmental qualification documentation currently maintained by the District adequately de-monstrates compliance with 10CFR50.49. This documentation is on file and available for-commission audit. The District also be-lieves that continued operation without risk to the health and safety of the public is justified based upon the District's cur-rent level of. compliance and supplemented by the JCO's provided -w th the District's April 3, 1984 extension request' discussed i above. The District-committed in a letter dated September 9, 1982 to pro-vide various test reports and SCEW sheets to the Franklin Research Center (FRC). Because these test' reports were received by the Dis-trict after the FRC completed their reviews,~they will not be sub-mitted to the FRC.- In a letter dated May 20, 1983, the District revised that commitment to submit the reports and SCEW sheets to. the Commission. Based on a recent telephone conversation with Mr. Paul 'Shemanski Hof the EQB, 'it was determined that submittal of these~ reports and SCEW sheets will not be necessary. The test re- ~ ports are ava'ilable in the Districts central file and the'SCEW sheets can:be-found in the District's Electrical Equipment Qualifi-cation' Manual. b e a

p=- Mr. Harold R. Denton LIC-84-121 Page Three .As discussed.at the March 23, 1984 meeting, it is requested that a final SER be issued to indicate-that the District's electrical equipment qualification program meets the requirements of 10CFR 50.49 and the deficiencies noted in the January 11, 1983 draft SER are considered resolved. S.incerely, j g@ W. C. Jones Divisiod Manager Produchion Operations WCJ/DJM:jmm Attachments cc: LeBoeuf, Lamb, Leiby & MacRae 1333.New' Hampshire Avenue, N.W. Washington, D.C. - 20036 Mr. E. G. Tourigny, Project Manager Mr. L. A.-Yandell, Senior Resident Inspector e J k 's n ~ M e

^ TER Meeting Response - Index and. Introduction Index x fItem by Item Resolution Pages 1-15 - LItem.byIItem'ResolutionNotes Pages 1-14 Compliance with 10CFR50.49. (b)(1) Pages 1-13 (b)(2) e~ . (b)(3) Penetration Test Schedule. EEQ: Manual Enclosure 9.- - . Containment Vent Fan Splice

Description Wyle - Lab-Report #26333 ~

. Attachment 6 ' . Splice. Eval uation -Currently Applicable JCOs Introduction 'The discussion provided represents the_ item by item discussion and-resolution

of.the March 23, 1984, mee. ting to discuss the: Franklin Research TER. The item by. item resolution presented at that meeting has -been modi fied and notes:added.

~ to. define qualification based on the meeting. ' - The, Distr'ct's methodology and efforts are described in the ;section entitied "Complicr.ce with 10CFR50.49 (b)(1), (b)(2), (b)(3)." and Wyle Report #26333-26 (Attachments'5.&'6) a_re supplied to. doc-ument qualification of the containment vent fan splices. .Several Jitems not.directly addressed at the-TER meeting-are' discussed in the - " Notes" section.nThese ' include submergence of:NAMCO limit switches, HCV-348 operating 1 time, and La. discussion of Limitorque= lubrication.. ~ c Since_ the TER meeting, thelsplices on the containment electrical penetrations forl equipment.-required to operate.during a' LOCA or MSLB, installed during ^ J pla'nt construction,/(as. discussed in the Attachment -7 JCO)1 have_ been ~ replaced. with Equalifled ' splices. JDuring the testing, the outer. jacket.'became'. brittle ~ ~ ~ (and cracked after 40 years Lequivalent' aging.E s. t j I T A m 1 5 L3 r'._- ] k I m.

O ATTACllMELT 1 4 l' L.:

fnser v 3 ITEtt-BY-ITEN RESOLUTION O QUALIFICATION FRC e EEQ PAGE # DESCRIPTION CATEGORY DEFICIENCIES RESOLUTION STATUS 1 6-61 Foxboro Flow transmit-II.a.

a. Radiation Upgraded to NE-10 Series See Note 1.

ter Model NE13DH in

b. T/P Exposure t ransmi t te r.

tbved above Containment for HFSI Duration flood level. Loops IA, 18, 2A, 2B, c Qualified Life

d. Submergence 2

6-109 Foxboro Pressure II.a.

a. T/P Exposure Upgraded to NE-10 Series See Note 1.

6-113 transmitter Models Duration transmitters. 6-116 NEllCM, and NE13CM in

b. Qualified Life Containment for Pressurizer Pressure &

Stean Generator Pres-su re. 3 6-123 Foxboro Level trans-II a.

a. Similarity Upgraded to NE-10 Series See Note 1.

mitter Model NEl3DH in

b. Qualified Life transmitter, containment for Steam Generator Level indication.

4 6-IA Foxboro Level trans-II.a.

a. P-T Exposure Upgraded to NE-10 Series See Note 1.

mitter NEllCM in Con-Duration transmitter. tairment for Pressur-

b. Similarity izer Level.

c. Qualifed Life 5

5-10 Barksdale Pressure I.b.

a. Radiation Barksdale has been Switch is qualified.

Switch 15055 in Con-

b. Terperature replaced with an Test Report'must

tainment,

c. Pressure ASCO Pressure Switch be incorporated

d. Qual. tiethod to resolve items a-e.

into files.

e. Relocation / Replacement-Adequate Schedule Not Provided 6

6-26 Alison Control Temp. I.b.

a. Documentation Analysis indicated that No further action 6-27 detecto rs (TE866,867) these temperature detectors required. SCEW 6-28 for monitoring of are not required for post-sheet to be removed.

charcoal filters in accident operation. There-containment. fore, these items are ocw considered outside of the scope of 10 CFR 50.49. . 4

,3r" "*1 ITEM-BY-ITEM RESOLUTION QUALIFICATIDN FRC i EEQ PACE # DESCRIPTION CATEGORY DEFICIENCIES RESOLUTION STATUS 7 6-IC Manco Limit Switch I.a. None None Required All switches are 6-4E EA-180-Il302 in con-Subne rgence qualified. 5-4G tainment for TCV-202, deficiency See Note 3. 6-188 HCV-241. HCV-238, resolved. See 6-1BD HCV-239, HCV-240, Note 2. 6-35B HCV-425A, HCV-425C, 6-35E HCV-438A, HCV-43SC, 6-3EB HCV-467A, HCV-467C, 6-770 PCV-742E, PCV-742G, 6-77F HCV-746A HCV-864, 6-79A HCV-855. HCY-2916, 6-988 UCV-2936. HCV-2956, 6-115B HCV-2576, PCV-2909, 6-1258 PCV-2929, PCV-2949, 6-125C PCV-2969, HCV-PSI, 6-129 HCV-Ed2, HCV-883A, HCV-884A, HCV-2603B, HCV-26048. HCV-2504A, HCV-2506A, HCV-2507 HCV-1387A, HCV-138BA. HCV-1107A, hCV-1108A, HCV-545 cSpecial note 6-7CC* ASCO nodel

• Franklin Research Center These solenoid valves X206-381-6RF electric reviewed these items as a are cualified. See #107.

solenoid valves on: part of the Item #7 M/PCO HCV-883C, HCV-883D, limit switches. These HCV-833E, HCV-883F, ASCO units do not have HCV-883G, HCV-883H, limit switches. HCV-820C, HCV-820D, HCV-82LE, HCV-820F, HCV-820C, HCV-82CH 8 6-3 Fisher 304 Limit II,a.

a. Radiation Radiation testing and aging These switches are 6-IIA Switches in Room 13

b. Preventive analysis complete.

qualified. 6-77B prcviding position Maintenance See Note 4, 6-91 indicaticn on HCV-204,

c. Docurxntation 6-125 HCV-206, HCV-4678, 6-127 HOV-467D HCV-43FB, HCV-43SD, HCV-349, HCV-350, FCV-326 HCV-341. HCV-1387B, HCV-13888 HCV-500A, HCV-5008, HCV-506A, HCV-506B, HCV-508A, HCV-5GEB, HCV-5C9A, HCV-509B

. q

p5t?" ITEM-BY-ITEM RESCLUTION ~ OUALIFICATIDN FRC # EEQ PACE e DESCRIPTION CATECORY DEFICIENCIES RES0tuTION STATUS 9 f-106 Fisher 304 Linit II.a.

a. Radiation Radiation testing and These switches are 6-8 Switches in Roon 21

b. Qualification aging analysis complete qualified.

providing pcsition Docunen ta tion a and b. See Note 4. indication on: HCV-2808C, HCV-2808D, HCV-2810C, HCV-28100, HCV-2812C, HCV-2812D, HCV-2813C, HCV-2813D, HCV-2808A, HCV-28088, HCV-2SICA, HCV-28108 HCV-2812A, HCV-28128, HCV-2813A, HCV-28133 10 6-104 Fisher 304 Limit II.a.

a. Radiation See Resolution of These switches are Switches in Room 22

b. Dualification Item #9 above, qualified.

providing position Docurer<tation "ae Note 4 indication on: HCV-28C?C, HCV-2SO90 HCV-7811C, HCV-2SilD. HCV-2814C, HCV-2814D, HCV-2815C, HCV-2815D 11 6-14 Fisher 304 Limit !!.a.

a. Radiatisa See Resoluticn of Item These switches are 6-?8 Switches located in

b. Qualification

1. 9 abnve.

qualified. 6-42 Room 59, providing Documentation See Note 4. 6-31 rcsition indication for HCV-4258, HCV 425D, HCV-2603A, HCV-2604A, HCV-344, HCV-345, HCV-742A, HCT-7428, FCV-742C, HCV-742D. IS 6-23 Fisher 304 Limit II.a.

a. Padiation See Resolutter of Item These switches are Switch in Room 60

b. Qualification

1. 9 above.

qualified. providing position Docunentation See Note 4 indication for Con-tainment HVAC on: PCV-742F, PCV-742H, HCV-74EB. 13 6-18 Fisher 304 Limit II.a.

a. Radiation See Resolutice of Iten These limit switches 6-45 Switches in Rocm 69

b. Cualification

1. 9 above.

are qualified. 6-81 providing position Documentation See Note 4 6-100 indicatien for: HCV-4CCC, HCV-401C, 4 FCV-402C, HCV-403C, HCV-1559A, hCV-1559A. HCV-1560A, HCV-150CB, PCV-1849. HCV-1749. < q

[ ) ITEM-BY-ITEM RESOLUTION QUALIFICATION FRC # EEQ PAGE # DESCRIPTION CATECORY DEFICIENCIES RESOLUTION STATUS 14 6-5 NAMCO EA-180 limit II.a.

a. Steam Exposure Fisher 304 limit Equipment has been f.95 switches in Room 81

b. Dualification were replaced with installed; document-6-102 providing pcsttion Docueentation fully qualified tion is in file. These indication on NANCO EA-180 switches switches are qualified.

NCV-2898A, HCV-2898C, to resolve a, b. 'See Note 3. HCV28988. ECV-289FD, HCV-2899A, BCV-28990, HCV-2899C, HCV-2899D. MS-291, MS-292 15 6-17 NAMCO Model EA-180 1.a. None None Required. Qualified. 6-108 limit switches in Room See Note 3. 69 providing pcsition indication on HCV-400A, HCV-4008 HCV-4CCD, HCV-401A, HCV-40!B, HCV-401D. HCV-402A, HCV-4028 HCV-4020, FCV-403A, HCV-4033, HCV-403D, HCV-40CE HCV-400F, HCV-401E, HCV-401F, HCV-402E, HCV-402F, HCV-403E, HCV-403F. 16 6-67 MAMCO Model EA-120 I.a. None None Required. Qualified. limit switches in Room See Note 3. 21 providing position indication fer LCV-383-1 and LCV-383-2. 17 6-74 KAFC0 Model EA-180 I.a. None None Required. Cualified. linit switches in Room See Note 3. 21 providing position indication for HCV-2917 and HCV-2927, 18 6-72 NAMCO tbdel EA-1E0 I.a. None None Required. Qualified. limit switches in Roon See Note 3. 21 providing position indication fcr HCV-2907 and HCV-2908. 19 6-77 NA!:C0 Model EA-180 I.a. None None Required. Dualified. linit switches in Room See Note 3. 13 providing position a ir.dtcatien for HCV-306 and HCV-307, 20 6-65 NAMCO Model D24COX II.a. a. Padiation NAftCO Model 02400X replaced Equipment has been limit switches in Room

• b.

Cualification with fully qualified NAMCO installed; documenta-21 providing position Documentation EA-IPO's to resolve a, b. tion is on file; these irdication for HCV-304 switches are qualified. and hCV-305. See Note 3. 1 4-q

f ITEti-BY-! TEM RESOLUTION CUALIFICATION FRC 8 EEQ PACE a CCaCRIPTION CATEGORY DEFICIENCIES RESOLUTION STATUS al 6-115 NAMCO ftodel EA-ICO I.a. Ncne None Required. Qualified. limit switches in Rocm See Note 3. 60 providirg position indication for HCV-25049 PCV-25068, and HCV-26C78. 22 6-29 NAt?CO Model EA-180 I.a. None None Pequired. Qualified. limit switches in See Note 3. rer.tainment providing position indication for PCV-742A ard PCV-740C. 23 6-34 NANCO Hodel EA-180 1.a. None None Required Oualified. linit switches in See Note 3. centainment providirg pcsition indication for hCV-724A, HCV-7248, bCV-725A, and HCV-7258. 24 6-33 NAMC0 Hodel EA-ISO I.a. None None Required. Qualified. limit switches in Room See Note 3. (9 providing position for PCV-7428 ard PCV-7420. 35 6-69 NAftCO Model EA-180 1.a. Ncne None Required. Qualified. 6-87 lir.it switch in Room See f:cte 3. 21 providing position indication for HCV-2947 HCV-2948 HCV-2918, and HCV-2928. 26 6-28 NANCO Medel EA-180 1.a. None Mone Required. Cualified. 6-40 limit switches in Paco See Note 3. 6-89 22 providing position indication for FCV-2937, HCV-2938, hCV-2957, HCV-2958, HCV-2967 PCV-2968 HCV-2977 and HCV-2978. 27 6-79A NAPCO Model EA-LEO I.a. None None Required. Qualified. linit switches in See f:ote 3. contairmer.t providing positten indication fer HCV-883A ar.d ECV-884A. e . 4

W^ ITEM-BY-!TEtt RESCtUTION CUALIFICATION FRC

• EE0 PACE #

DESCRIPTION CATEGORY DEFICIENCIES RE50tuTION STATUS 28 6-118 tinitorque SFS 4T II.a. a. Aging Items a, b and d to be - Motor branes were retor operated valve, b. Preventive ftaintenance resolved by incorporation replaced during 1984 timit and torque c. Similarity into Qualified Life Preqram. outage. Items are switches in Room 81 on d. Qualified Life Similarity (c) was estab-Qualified. HCV-1385 and HCV-1386. 11shed and documentation is on file. Inspection See f40te 7. was made this outage. Com-pleted in early May,1984 29 6-117 Linitorque Medel II.a. a. Aging Itens a and b have been See hote 6 S!T-00 motcr operated b. Qualifted Life resolved by incorporation valve, limit and c. Similarity into the Qualified Life torque switch in Room Program. Similarity (c) was 81 on HCY-13E4 established and documenta-tion is on file. 30 6-78 Valcor Soleroid Valves I.a. None kone Required. Qualified. in Rcon 59 for HCV-820A, hCV-821A, HCV-ES38, NCV-E348, 31 6-96 A Liniterque flodel II.a. a. Aging See resolution to Iteo #29. These iter.s are SMB-C0 Votorized Valve b. Qualtfied Life qualified. in Room 81 Actuators c. Similarity See Note 6. on HCV-ID41C and HCY-1042C. 32 6-75 Limitorque nodel II.a.

a. Similarity Similarity was established These itens are SMS-CCG Valve

b. Docurentation and documentation is on file qualified.

Actuator and limit

c. Aging to resolve a, b.

Items c See Note 6. switch in Room 13

d. Dua11fied Life

& d have been resolved by fer HCV-3C8 incorporation into the Qualified Life Program. 33 6-92 Limitorque ibdel II.a.

a. Similarity See Item #32.

These items are SMS-2 Valve

b. Docurentation qualified.

Actuator and limit

c. Aging See fLote 6.

Switch in Room 13 for

d. Qualified Life hCV-347, 34 E-63 Limiterque Model II.a.

a. Similarity See Item #29.

These itens are qualified. SFS-0 motor operated

b. Ouilified Life See Note 6.

valve and limit

c. Aging switches in contairment for HCV-353-3, FCV-383-4

. q

ITEM-BY-ITEM RESDLUTION CUALIFICATION FRC # EEQ PACE

• DESCRIPT!DN CATEGORY DEFICIENCIES RES0tuTION STATUS 35 6 62A Limitorque Model SMB-0 II.c.

a. Aging See Item #29.

These items are qualified. Valve Actuators and

b. Qualified Life See Note 5.

Ifnit switches in

c. Similarity centainmect for HCV-311, FCV-312 HCV-314. HCV-315, FCV-317. HCV-318, FCV-320 and HCV-321.

36 6-f? Linitorque >kdel II.b.

a. Aging See Item #29.

These items are qualified. SMS-C0 Valve Actuators

b. Qualified Life See Note S.

and limit switches in

c. $1milarity centainmer.t for HCV-2914, HCV-2934, HCV-2954, PCV-2974.

37 6-E4 Limitorque Model SPB-0 II.a.

a. Aging See Item #29.

These items are qualified. Yalve Actuators in

b. Cualified Life See Note 5.

centainment for

c. Similarity NCV-327 HCV-329, PCV-331, hCV-333.

3? E-Il3a Limitorque Model II.a.

a. Aging Itens to be part of CLP No further action to SMS-00 noter crerated

b. Qualified Life and remain in EEQ Progran, be taken.

valve ard limit

c. Similarity See Note 8.

switches in cortainment for See FRC TER 38, page 4b. FCV-150, FCV-ISI. 39 6-E5 Limitorque Model Sits-3 II.a.

a. Aging See Item #29.

These items are qualified. nctor operated valve

b. Oualified Life See Note 5.

and limit switch in

c. Similarity containment for HCV-348.

40 6-4 Limitorque SFB-00 II.a.

a. Aging Deleted from the sccpe Failure effects rcter cperated valve

b. Similarity of IDCFRSO.49 aralysis cer.plete.

ard limit switches in

c. Qualified Life F.oem 7 for LCV-218-3.

41 6-83 GE Electric Motor in II.a.

a. Aging Degradation Aging ard radiation test items are qualified.

Roon 21 & 22 fer LPSI

b. Aging Simulation reports reviewed in resolve purps SI-IA, 51-18.

c. Cualified Life a, b, c ard d.

Required

d. Radiation splices will be analyzed or replaced durirg 1954 outage. Lubrication included.

42 6-E0 CE Electric Motor for II.a.

a. Aging Degradatice See Item i41.

See item #41. PPSI Purps SI-2A,

b. Aging Simulation 51-23 and SI-2C.

. c. Qualified Life

d. Radiation 9 g

s e ITfH-BY-ITEN RESOLUTION CUALIFICATIDM FEC a EEQ PACE A DESCRIPTIGP. CATEGORY CEFICIENCIES RESOLUT!DN STATUS 43 6-3E CE Electric tbtor for !!.a.

a. Aging Degradatien S(e iten #41.

See Item #41. Containeent Spray

b. Aging Simulation Purps SI-3A, 51-38 and

c. Qualified Life SI-3C.

d. Radiation 44 6-24 Reliance Motor for II.b.

a. Aging Degradation Aging analysis performed to Oualified.

Jov Vane Axial Fans

b. Similarity resolve (a). Similarity VA-3A and VA-3B in

c. Qualified Li'e deficiency (b) resolved by conta irset t,

d. Pressure-Teraerature fact that tested fan is one Duration of four installed. Incor-

e. Pressure-Ter;erature teration into Qualified Life Prof fie Program resolves c.

Verift-

f. Spray cation performed to resolve

g. Radiation d, e.

Items f & g esolved by analysis. 45 f-S Reliance Motor for II.a.

a. Aging See Item a44 See Item 444 Jcy Vare Amial Fan fcr

b. Similarity VA-7C and VA-7D in

c. Qualified Life containment.

d. Pressure-Temperature Duraticn

e. Pressure-Terperature Profile

f. Spray

g. Radiation 46 6-21 Trare motor for III.a.

None Mone Required. Exempt f rom qualifi-Control Rocn air Emerpt cation. SCEW Sheet conditioning cnits to be removed. VA 46A and VA-45B 47 6-22 ILC Industries Fan I!!.a. Fore None Fequired. Exempt from qualifi-Motcr VA-63 for cations. SCEW Sheet Control Rooa to te removed. Ventilation. 23 6-15 Allis Chalmers Mctor II.a.

a. Documentation Documentation based on Qualified.

for compcrent cooltrg radiation and aging analysis water purps AC-3A, has been added to the fil; AC-38 and AC-3C. to resolve a. 49 6-115A ASCG Solenoid in con-I.a. Ncne None reouired. Dualified. tairment for remote operation of HCY-2EC4A, HCV-2SC6A, HCV-2507A. 50 6-96 ASCO Soleroid in Room II.c.

a. Qualified Life Deficiency (a) has been Dualified.

81 for HCV-IC41 A. resolved. Qualified life established, required maintenance included in Dualified Life Progran. 9 -T. - 1

3 ITEf1-BY-ITD1 RESCLUTION CUALIFICATICN FaC a EEQ PAGE e DESCRIPTICM CATEGORY DEFICIENCIES RESOLUTION STATUS 51 E-96 ASCO Solenoid in Room II.c.

a. Cualified Life See Item #50.

Item is cualified. El for FCV-lD42A, 52 6-29 A ASCO Solenoid in cen-I.a. Ecne none Required. Items are qualified. tainment for remote operation of PCV-742A and FCV-742C. 53 6-7EA ASCO Solenoid for II.a. Similarity Same as #81 Same as #81. remote operation of FCV-ES3A and hCV-ES4A. 54 6-78 Valcor solenoid in II.c.

a. Qualified Life Valcor solenoids incor-Item is qualified.

Pcom 59 foe HCV-883B & porated into the Oualified FCV-8848. Life Program. 55 6-120 ASCO Solenoid in Room II.c.

a. Qualified Life Resolved (a) by incorpora-

!! ems are qualified. El for HCV-11078 and tinn into Qualified Life HCV.IIGEB. Program. 55 6-90 ASCO Solenoid in Room II.c.

a. Qualified Life Fesolved (a) by incorpora-Items are qualified.

13 for FCV-326 and tien into Oualified Life HCV-341. P rogram. 57 6-97 ASCO Solenoids in Roem II.c.

a. Qualified Life Pesolved (a) by incorpora-Items are qualified.

59 for HCV-2603A and tion irto Qualified Life 2E04A. Program. E8 6-80 ASCO Solenoids in Room !!.c.

a. Qualified Life Resolved (a) by incorpora-

!tems are qualified. 6-99 69 fcr FCV-1E49, tion into Qualified Life 6-137 hCV-1749 HCV-400E, F rogram. hCV-40CF, HCV-401E, HCV-401F, HCV-402E, FCV-402F, FCV-4C3E, FCV-403F. 59 6-119 ASCO Solenoids in Recm II.c.

a. Cualified Life Pesolved (a) by incorpcra-Items are qualified.

81 for HCV-1107E ard tion into Cualified Life HCV-11G88. Program. 60 6-13 ASCO Solenoids in !!.c.

a. Cualified Life Resolved (a) by incorpora-Iters are qualified.

6-135, containment for: tion into Qualified Life 6-IEC. TCV-202, HCV-241, Program. 6-35A, HCV-425A, HCV-425C, 6-353 HCV 467A, HCV-467C, 6-77C, FCV-745A, HCV-2956, E-77E, HCV-2976 FCV-2916, 6-9EA, FCV-2936, FCV-2603B, 6-125A HCV-2fC42. HCV-1187A, FCV-135EA, PCV-742E, PCV-742G, FCV-2909 PCV-2929, PCV-2949, PCV-2969 . q

pe, war ITEM-BY-ITEli FE50tuTION DL'ALIFICATICh FRC

• EE0 PACE e DESCRIPT10t CATECDRY CEFICIENCIES RE50t0TICN STATUS 61 6-40 ASCO Solenoids in II.c.

a. Qualified Life Resolved (a) by incorpora-Itens are qualified.

6-4F containsect for tion irto Oualifed Life HCV-238 HCV-239, Program. HCV-240. (2 0-128 ASCO Solecoid in !!!.a. None TER refererces #49. Items are qualified, containsent for Emerpt Items are qualified, not and included in HCV-545. exempt. EEQ program. 63 6-77A ASCO Solencids in Rone II.a.

a. Decurentation Feplaced by qualtfled Items are qualified.

13 for HCV-349, ASCO solenoids in HCV-350 resolve a. 64 6-ICS ASCO Solenoids in Room III.a. None Dualified ACSO. Items are qualified. 21 fer HCV-28 CEC, Item should be included HCV-?SCED, bCV-ISIOC, in EEQ Program. HCV-ZSICD, HCV-2812C, HCV-2812D, HCV-2813C, HCV-2S130 65 f-103 ASCO Solenoids in Rcom III.a. Ncce Dualified ASCO. Items are qualified. C-7 21 for HCV-2808A, Items should be included MCV-2ECES, hCV-?SIDA, in EEQ Program. HCV-2 SICS, HCV-2812A, HCV-2212B, HCV-2813A, HCV-2813B, HCV-ISCSA, HCV-2809B, KCV-2811A, HCV-28118, HCV-?S14A, HCV-2E14B, HCV-2315A, HCV-2215B. 66 6-35 ASCO Scienoid in Roce II.c.

a. Qualified Life Resolved (a) by incorpora-Items are cualified.

60 for PCV-742F, tion into Qualified Life PCV-742H, HCV-7468. Program. 67 6-101 ASCO Solencids in Room II.c.

a. Qualified Life Resolved (a) by incorpora-Iters are qualified.

6-6 81 for HCV-2893C, tion into Qualified Life FCV-22980, HCV-2S99C, P rogram. HCV-2899D, HCV-2 ESSA, HC7-2E9EB, HCV-2299A. HCV-28SSB. 63 6-76 ASCO Solencids in Room !!.c.

a. Cualified Life Resolved (a) by incorpora-These items are 6-2 13 for bCV-3C6, tion into Oualified Life qualified.

6-11 FCV-302, HCV-2C4, Program. HCV-206 HCV-4673 FCV-467D, FCV-43EB, hCV-436D. 69 6-f6 ASCO Soteroids in Roce !!.c.

a. Cualified Life Resolved (a) by incorpora.

These item are 6-126 21 for LLV-353-1, tion into Oualified Life qualified. LCV-353-2, HCV-304, Program. ECV-3C5. 1 q

3 q s&< ITU!-BY-IVEtt FE50tVTIort CUALIFICATIC!i FRC a EEQ PACE = DESCRIPTIch CATEGORY DEFICIENCIES RESOLUTION STATUS 70 f-41 ASCO Solenoids in Room II.c.

a. Qualified Life Pesolved (a) by incorpora-These items are 6-30 59 for hCV-344, tion into Qualified Life qualified.

6-13 HCV-345, A/PCV-742 Program. C/HCV-742, B/HCV-742, P/HCV-742. HCV-4258, HCV-4250. 71 6-16 ASCO Solenoid in Room II.c.

a. Qualified Life Resolved (a) by incorpora-These items are 6-44 69 for HCV-1559A, tica into Qualified life qualified.

HCV-15598. HCV-1560A, Program. HCV-15608. HCV-400A, HCV-40CS, HCV-4 DOC, HCV-40CD, HCV-401A, ICV-4018, HCV-401C, HCV-401D NCV-402A, ICV-40ZB, HCV-402C, itCV-402D, HCV-403A. HCV-4033. HCV-4G3C, NCV-403D 72 6-E6 ASCO Solenoids in Reca I.b.

a. Documentation Replaced with fully Incorporated 6-37 21 fer HCV-2917, qualified ASCO NP-1 into EEQ Program.

6-73 HCV-2927 HCV-2947, solenoid to resolve a. Itens are qualified. HCV-2948. HCV-2957 HCV-2958 73 6-88 ASCO Scienoids in Room I b.

a. Docunentation Replaced with fully quali-These items are 6-70 22 for HCV-2907, fied soleroids to resolve qualified. HCV-2937 6-39 hCV-2937. FCV-2967, a.

incorporated into 6-ESA HCV-2968, HCV-2977 EEQ Program. MCV-2978. HCV-2938. 74 6-32 ASCO Solenoids in Fcom II.c.

a. Qualified Life Incorperated into Ocalified These items are (9 for PCV-742B, Life Progran to resolve a.

cualified. PCV-7420. (See Kote 1). 75 6-68 ASCO Solenoid in Room I.b.

a. Documentation To be replaced with fully To be incorporated 21 for HCV-2918, qualified solenoids to irto EEQ Program.

HCV-2928 resolve a. 76 E-71 ASCO Scler.oid in Foom I.b.

a. Documentatien To be replaced with To he incorrerated 22 for HCV-2908 fully qualified into EED Program, solenoids to resolve a.

, q

ITEM-BY-ITER RESOLUTIC4 00ALIFICATICN FRC d EE0 PACE # DESCRIPTION CATECORY DEFICIEf.CIES RESDt0 TION STATUS 77 6-126 ASCO Soleroids in Room II.C.

a. Dualified Life Incorporated into Qualified items are qualified.

6-124 13 for HCV-13878, Life Program to resolve a. HCV-135CS, HCV-50CA, HCV-5CCB, HCV-EC6A. HCV-5068, HCV-507A, HCV-5078. HCV-508A, HCV-50S3, HCV-509A, HCV-5098. 73 6-114 ASCO Solenoid in Room II.c.

a. Qualified Life incorporated into Qualified Items are qualified.

60 for HCV-25C*C, Life Program to resolve a. HCV-25068. HCV-2507B. 79 6-34a ASCO Solenoids in I.a. None None Required. Items are qualified. containment for Incorporated into Qualified HCV-724A, HCV-7248 Life Program. hCV-725A, HCV-7258. E0 6-94 ASCO Solenoids in Room II.c.

a. Qualified Life item (a) resolved by Items are qualified.

81 for MS-291, MS-292. implementation into Qualified Life Prcgran. 81 6-19 Valcor Solecoid Valve !.b.

a. Documentation Replaced with fully quali-Items are qualified.

6-36A for HCV-43EA, fied ASCO ttodel KP-1 6-793 HCV-43EC, HCV-864, Solenoids. 6-125D HCV-E65 HCV-881, 6-7BA HCV-882. HCV-1107A, HCV-IIC6A, HCV-F83A, HCV-EE4A. 82 6-113b Target Fcck Model li.e. Similarity District has documentation These itens are PCB-CCI-7 solecoids en fron Target Rock to establish qualified. HCV-176, HCV-177, similarity between test HCV-178 HCV-179, specinErs & those installed. HCV-180. HCV-181. 83 6-20 Jcheson Certrois !!C ~ III.a. None None Required. Exempt fren Qualifica-Parels AI-1C6A and tion SCEW Sheet to be AI-106S. removed. 24 6-91A Fisher Cor.trols E/P IV Decumentation not made Letter - Jores to Clark Qualification documen-Transducer for available. 5/11/83. Aging established tation is en file - FCV-326 hCV-341. using CCR Guidelines. itens are qualified. Replacement-in-kind 10 year interva's. 65 6-55 Cerro Wire & Cable Co. II.a.

a. Aging Being tested to resolve Eeing tested.

W-57 ard W-59 cable.

b. Qualified Life

a. b, 3.

Additional data See hote 9.

c. Radiation has been cbteined to

d. Similarity resolve c.

Agirg Being tested to resolve See Note 9. E5 6-5E3 W-11 Cerro Pcwer Catle II.c. .s. Located in Room 69.

b. Qualified Life a, b.

4 q

F 1 ITDt-BY-ITDi RESOLUTION OtALIFIC ATION FEC # E 0 PAGE a CESCRIPTION CATEGORY DEFICIEf!CIES RESOLUTION STATUS 87 6-TBA W-10 Cerro Cable !!.a.

a. Ag!rg Being tested to resolve See Note 9.

located in Contain-

b. Qualified Life a, b, c.

rent.

c. Radi6 tion P8 6-57 Cerro Cable W-14 II.a.

a. Agirg Ceing tested to resolve See Note 9.

W-16, W-17. W-18,

b. Qualified Life a, b, c.

W-19. U-21.

c. Radiation 89 6-56 Cerro Cable W-37 II.a.

a. Aging Being tested to resolve See f:ote 9.

W-38. W-39. W-40,

b. Qualified Life a, b, c.

W-41 W-42

c. Radiation 90 6-59 A acenda SKY

!.a. None None Required Iten is qualified. Twer Cable W-3. 91 6-5G AM? Cable splices at II.a.

a. Cualification Docurentation Transmitters upgraded & no see Note 10.

solenoids and at

b. Preventive Maintenance longer require cable transmitters.

c. JC0 splices. They use trans-mitter terminal blocks.

Solenoids which operate or energize post-LOCA have been upgraded. 92 6-49 Cable Splice at II.a.

a. Aging Being tested to resolve See Item #85.

electrical

b. Qualified Life a, b, c, d. (Valcor See Note 9.

roetrations and

c. Radiation solenoids have been Splices replaced -

valcer scienoids.

d. Test Sequence replaced - see a81) see introduction.

93 6-47 Electric scalant 3 faone None Required Items are qualified. Ocw-Coening RTV-2144/3145 94 6-48 Burndy Teminal III.b. Ncne None Required See item #103. Part Lugs. of Raychem Splice System. 35 6-51 Cable Spitees 9 4SCY I.b.

a. Occurentatic,n District believes these Items are cualified.

Cor.ta rtert Vent Fans are qualified. See f:ote 11. 96 6-52 Cor.tainment Vent F:a II.a.

a. Docurentation See Iten a95.

See Iten 795 above. fictor Lead Splices at the electrical penetra tiens. 97 6-53 States 4, 6, 8 and II.a.

a. Similarity Sinilarity established by Items are (,ualified.

12 point teminal

b. Docurentation reference to vendors catalec See Note 12.

blocks. to verify installed terminal blocks are type f1T. Docu-nentation on file, this resolves a,b. 92 6-54 Hof fran Juncticn !!I.a. . '. ace Exempt - fiene Fequired. Exempt from Cualification. Ecues. 4 aq

!TEff-BY-!TEft RE5JtuTION CUALIFICATION FEC # EEQ PACE a DESCRIPTICM CATEGORY CEFICIff;CIES RESOLUTION STATUS 99 6-46 Ccean Electrical !!.a.

a. Radiatien See item eC5.

See flote 10. Penetrations in

b. Test Sequence cectainrent.

c. Aging

d. Qualified Life 100 6-59A Cenax Electrical II.a.

a. Similarity Similarity establisted by items are qualified.

Ccroactor Seal

1) reporting snodel *,

Assertly

2) providing cert, of cceferrance.

101 0-12CE Fisher 304 Limit I.a. home Limit switches were items are qualified. Switches in Room El replaced during 1984 for T:V-1C45A, outage with qualified TCV-1045B, HCV-1107B N/PCO-EA-180's, and HCV-110EB. 102 6-65 MA,1CO EA-180 Linit I.a. Nane None Required. Items are qualified. Switch providing See Note 3. Dositice indication for KV-3C4 and brY-305 103 6-593 hyctem Cable Splices II.a.

a. Similarity Splices are correctly.

These splices are 6-59C in containment and Raychem f1Me? WCSF-f; cualified. E-59 Auxiliary Buildirg. inline splices. These are qualified per FRC TER #103 pg. Sg. This resolves (a). 2 Analyzer Cce: sip II.c.

a. Qualified Life vender naterial data was Item is qualified.

104 6-7EC H

b. Aging Cegradation verified usirg Arrtenius See f40te 13.

c. ;ging Sisstation Method and found acceptable.

105 6-59E Rockbestos Firewall I.a. f.one f4one Fecuired Fully Qualified. 6-59F III Cable 6-5CG ICE E-ICCA Victcreen High Range II.a.

a. Similarity The similarity prebim arose Items are fully 6-10C8 Containcent Radiation from incorrectly reported qualified.

Area Moniter. f'odel rodel nunter. Test report 877-1 and cables a.d cited various cegradatices - ccreecters. cables are enclosed in stainless steel tubing to resolve this. 107 6-720 ASCO Solenoids in !!.c.

a. Cualified Life Incorporated into Ocalified Fully Cualified.

certairrent for Life Program to resolve HCV E83C, HOV-853D, (a). HCV-E83E, hCY-E83F, FCV-883G, HCV-883H, HCV-E2CC, ECir-82CD, C-820E, KV-820F, HCV-220G, KY-E2CH. 9 1

ITEM-BY-ITEM RES%t;TICt CUALIFICATIO*: FRC

• EEG PAGE s CESCRIPTION CATEGOPY CEFICIEt;CIES RESOLUT!CN STATUS ICS 6-78A ASCO Soleccid in

!!.a.

a. Sini1arity See tal.

Fully Oualified. ccr.tairrent for HCY-ESIA, t:CV-884A 109 6-9 ASCO Scienoids in koca II.c.

a. Cualified Life See Iten #107.

Fully Oualified. 22 for hCV-28C9A. HCV-7EC93. HCY-2511A, HCV-2811B, HCV-2Cl4A, PCV-28145, HCV-2515A, HCY-25158. 11) 6-1200 ASCO Scienoids in Eoca II.c.

a. Oualified Life See Iten #107.

Fully Qualifted. 81 for YCV-1045A. YCV-10458. 111 6-!!CA ASCO Soleroid Valves II.c.

a. Qualified Life These soleroids are ret Nt located in a 6-I*5C fo-FCV-13f8 within the scope of harsh environment.

FCV-1369, YCV-1045. 10 CFR 50.49. SCEV to be deleted. 112 6-3:A ASCO Solencies in II.c.

a. Qualified Life See Item #31.

See Iten #81. rcetainment for FCY-865, bCV-E64. 113 6-19 ASCO Soleroids in II.c.

a. Qualified Life See Item e81.

See Itee 581. E-1250 certairzet fee bCV-43SA. HCV-433C. ECV-1107A, FCV-11CSA. 114 6-7E3 Yalcer Selecolcs in I.a. Itere Items have been tricorrorated Fully qualified. contairrect for into Qualified Life Progrm. HCY-8208 and FCV-821B. . q

J 3 a. 2. i l ATTACHMENT 2 1 R.k

FRC-TER ITEM BY ITEM RESOLUTION NOTES 1. TER-Items 1, 2, 3, 4 Foxboro Pressure and Differential Pressure Transmitters The District is upgrading all transmitters which are required to operate in a harsh environment to latest models of NE-10 Series Foxboro which have been tested to meet the requirement of IEEE/323-1974. The District will have completed any necessary hardware upgrade by the end of the current refueling outage scheduled to be completed in early May of 1984. Due to the late arrival of the test reports and the work required to insure similarity, review power supply voltages, review accuracy data, update the qualified life program and update the central file an extention to September 30, 1984 has been requested. This includes a justification for continued operation. The transmitter upgrade will resolve the radiation

exposure, T/P (temperature and pressure) exposure duration, and provide a transmitter qualified life which will be factored into the District's Qualified Lift Program. All transmitters are now installed above the flood level.

2. TER Items 7 - NAMC0 Limit Switches The limit switches listed in Table 1-Note 2 are limit switches which are installed on valves whose location is below the maximum projected flood level in containment. It is the District's judgment that the switches should remain operable in a flood condition. A review of the test report indicates that the switches were flooded several times due to malfunctioning test equipment with no indicated failures. Flooding and-potential failure of these limit switches will' not jeopardize the safe shutdown of the reactor in a DBA. As Itsted in Table 1, all limit switches ' provide position indication only. Although the switches may cause - a short or a ground of the circuit, no problems are expected. A short is expected to cause both position indications to be on. In the event of ground only one lead to ground is possible; the-other is isolated by the-indicating light. The lead which could be grounded is provided -(modification complete the end of the 1984 refueling outage) with a fuse to isolate this portion of the circuit from the remaining circuit to preclude the possibility' of the loss;of the control function in the event grounding would occur. . c

7 2. TER Item 7 - See Table 1-Note 2 (Continued) Thi system includes Conax Seals, Raychem Splices, and Pyrotrol III Cable. The District believes that the -insulation system should be adequate for the low. voltage (130 VDC or 120 VAC) position indication power. . Based on this evidence, the District believes that these limit switches have been adequately addressed. E o ens 8 6,~ 9

TABLE 1 NOTE 2 Tag. System Limit Switch Elevation Accident Fail _No. Function Position Position Position' HCV241 Let Down Position 1,000' C C CVCS Indication Containment Isolation HCV238 Charging Position 399' 0 Accident 0 Long Term Indication C Long Term Core Cooling Core Cooling HCV239 Charging Position 1,000' 0 Accident 0 Long Term Indication C Long Term Core Cosling Core Cooling HCV438A CCW to Position 996' 9" C 0 RC Pumps Indication Containment Isolation HCV438C CCW to Position 997' C 0 RC Pumps Indication Containnent Isolation HCV467A CCW to Position 999' 5" C C Nuclear Indication Detector Well Cosling Containment Isolation HCY467C CCW to Position 999' 2" C C Nuclear Indication Detector Well Cooling Containment Isolation HCV1387A Blowdown Position 1000' C C from SGA Indication Cont **nnent Isolation HCV1388A Blowdown Position .1000' C C from SGB Indication -Containment Isolation MAXIMuti PROJECTED FLOOD LEVEL 1000.9' INCLUDING ENTIRE RCS INVENTORY 3. TER Item 7, 14, 15, 16, 17, 18, 19, ?.0, 21, 2C, 23, 24, 25, 26, 27 The FRC-TER indicated the NAMCO EA 180 limit switches as fully qualified. It should be noted that these are qualified but require periodic refurbishment. These limit switches have been incorporated in the District's Qualified Life Program. 4. TER Item No. 8, 9, 10, 11, 12, 13 - Fisher 304 Limit Switches The District has completed qualification by a combination of test and analysis. Several switches (with approximately 10 years service) were removed from operating systems in the plant and irradiated to 2.24 x 10 R. The switches remained operable following irradiation with no 7 apparent degradation. Table C-1 of the 00R Guidelines was used to identify materials with significant aging. None were identified. The District considers the switches fully qualified with radiation as the only harsh environment parameter. The testing of naturally aged (ibcluding vibration) limit switches removed from the plant accounts for synergistic effects. 5. TER Items 35, 36, 37, 39 - Limitorque Motor Operators It is the District's judgment that the Limitorque Operators are qualified for the intendad service at the Fort Calhoun Station. For those operators in containment, Report number 600198 demonstrates qualification for steam, temperature, and chemical spray. Test 80003 and related Test B0058 are used to demonstrate aging and radiation quali fication. Class H insulated motors are installed on the in-containment operators. Limitorque has indicated that the characteristics of the Class H Hotors are equal or better than the Class B Hotors tested in B0003 and related Test B0058. Since the Class H 110ters have an inherently higher i :ermal rating than the Class B, qualification for the high LOCA/MSLB temperatures is assured, with radiation and aging characteristics similar to Class B insulation system. 4-

s P 5., TER ltems 35, 36, 37, 39 - Limitorque liotor Operators (Continued) IICV348 Failure Modes Analysis. Purpose This analysis evaluates the effects of a failure of ItCV-348 that may be caused by a radiation exposure in excess of the motor operator's environmental qualification. EE0 Problem flCV-348 is a motor operated valve whose Limitorque operator has been qualified to 2 x 107 Rads. The maximum post-LOCA total integrated dose has been calculated to be 2.7 x 10/ Rads. EV-348 Function a. liCV-348 is the safety injection shutdown cooling isolation valve. it is opened to supply water from the RCS hot leg to the LPSI pump suction so that shutdown cooling may be initiated. b. ItCV-348 is locked closed during normal operations and is a containment isolation valve. c. If a LOCA occurs while SDC is aligned for operation. EP-5A indicates that liCV-348 is to be closed as one of the first steps. d. ItCV-348 remains closed for long term core cooling as this flow path is not required. Failure Modes and Effects The only failure that will be considerej here is one that could be attributed to excessive radiation. All other failures are within the design basis of Fort Calhoun Station, as discussed in the USAR. The only credible failuru due to radiation would be a failure of tile motor operator to operate when required. There is no mechanism fse spurious actuation. The effects of a failure to actuate are negligible because there are no operations required after the radiation dose exceeds the qualified dose (about 250 hours post LOCA). a. The valve is a containment isolation valve and is closed while the RCS is pressurized. 5-

5. TER ltems 35, 36, 37, 39 - Limitorque Motor Operators (Continued) b. Operation is not required for long term cooling after either small or large break LOCAs because the flow path through IICV-348 is not used. Opening the valve for shutdown cooling after a MSL8 would not be c. prgvented because the radiation cuposure associated with a itSLB (5 x 100 Rads) is less than the qualif ted dose. d. Depending on the severity and isolability of a LOCA, it might be desirable to be able to open llCV-348 for shutdown cooling. In all likelihood, however, for any LOCA that could be isolated so that shutdown cooling could be utilized, either the system alignment through HCV-348 would be accompitshed before 250 hours, or the dose would be lod enough that the exposure limit would not be reached by the time the motor operator had to function. Limitorque Motor Operator Lubrication: The District has taken steps to insure that lubrication of the operators will also be qualif ted. The operators' gear trains were qualt fled with Exxon flebula EP-1. Limitorque recommends the use of Exxon fletula EP-0. During conversations with Limitorque the District asked if any other greases could be used. Limitorque stated that the only information available to them indicated the use of the Exxon grease. However, other lubricant vendors could be contacted for greaso qualification. As a result of this, the District has several of its valve operators using Texaco Marfac-2 as the lubricant. Texaco has provided qualification information which the District believes is adequate. The remaining valves have the Exxon flebula EP-0 lubricant. Limitorque Limit Switch Lubrication: The limit switches on these items are lubricated with either Becon 325 or Mobli 28. The District believes the valves are fully qualtf ted. 4 -G-

6. TER Items 29. 31. 33, 34, 40 - Limitorque tiotor Operators it is the District's judgment that the Limitorque Operators are qualified for the intended service at the Fort Calhoun Station. For those operators outside containment Test Report 80003 and related Report B0058 established qualification for all parameters. HCV347 is located in Room 13. However, qualification and operation are the same as those provided for llCV348. Room 13 is a hign radiation area only. LCV218-3 has been reviewed and found to operate prior to being exposed to a harsh environment. It is located on the charging system suction for which no credit is taken. Although not expected to fail, a failure modes and ef fects analysis indicates that no problens should be encountered. Limitorque Motor Operator Lubrication: The District has taken steps to insure that lubrication of the operators will also be qualified. The operators' gear trains were qualified with Exxon tiebula EP-1. Limitorque reconnends the use of Exxon tiebula EP-0. During conversations with limitorque the District asked if any other greases could be used. Limitorque stated that the only infonnation available to them indicated the use of the Exxon grease. However, other lubricant vendors could be contacted for grease qualification. As a result of this, the District has several of its valve operators using Texaco itarfac-2 as the lubricant. Texaco has provided qualification information which the District believes is adequate. The renaining valves have the Exxon tiebula EP-0 lubricant. Limitorque limit Switch Lubrication: The limit switches on these iterns are lubricated with either Becon 325 or Mobil 28. The District believes the valves are fully qualified. 7. TER ltem 28 - Limitorque Motor Operators It is the District's judgment that the Limitorque Operators are qualified i for the intended service at the Fort Calhoun Station. For those opurators in Roon 81 Report F-C3271 establishes environmentnl qusilfication based on similarity of the operators. Reports B0003 and B0058 establish a quallfled life. The brakes on these operators wore upgraded daring the 1984 outage. Limitorque Motor Operator l,ubrication: The District has taken steps to insure that lubrication of the operators will also be qualified. The operators' gear trains wore quallfled with Exxon flebula EP 1. Limitorque reconnends the use of Exxon flebula EP-0. DJring conversations with Limitorque the District asked if any other greases could bu used. Limitorque stated that the only information available to them indicated the use of the Exxon gruase. However, other lubricant vendors could be contacted for grease qualification. , ~

7. TER Item 28 - Limitorque Motor Operators (Continued) As a result of this, the Disi.rict has several of its valve operators using Texaco Marfac-2 as the lubricant. Texaco has provided qualification information which the District believes is adequate. The remaining valves have the Exxon Nebula EP-0 lubricant. Limitorque Limit Switch Lubrication: The limit switches on these items are lubricated with either Becon 325 or Mobil 28. The District believes the valves are fully qualified. 8. TER Item 38 - HCV150 and HCV151 The PORVs and their associated block valves were addressed in the IE Bulletin 79-018 submi ttal as part of the equipment referenced in the plant emergenc-nrocedures (EP's). Under the EPs, the PORVs potentially function in two different areas. The first is as a possible source of a LOC 1 in which the PORV may open and fail to close. As a result of the TER meeting with the NRC staff held on March 23, 1984 ' the District has conducted further investigation into the qualification of HCV150 and HCV151, Limitorque motor operators on the PORY block valves. These motor operators have been qualified to 40 psig, 250*F. The District is in the process of obtaining a computer-generated small break LOCA containment response expected in late May, 1984. There has not been sufficient time to complete this response information. In the interim, the District has made a simple heat balance calculation to obtain the time in which either.the qualification test temperature or pressure was exceeded. This modeled only the containment atmosphere and the saturated steam, (2150 psig) from one " failed PORV". The operating time was demonstrated to be 22.8 minutes at which time the containment reaches 40 psig. No credit was taken for -heat sinks in containment, or drop in RCS. temperature and pressure. as the pressurizer empties. The analysis takes no credi t for containment spray which initiates at approximately 4 PSIG and would be expected to limit to pressure and temperature transients. Addi tional operating time is available since.the harsh environment is delayed until the pressurizer quench tank. rupture disc is ruptured. Based on this information and the availability of PORV posi tion indication via the qualified acoustic position indication, the District believes these operators are qualified for their intended eervice: manual isolation of the PORVs. Th'e District also believes that this system's failure is bounded by the small break LOCA, and.that this alont. is adequate. 8. TER Item 38 - HCV150 and HCV151 (Continued) Challenges to the PORV's are expected to be very infrequent. The NSSS design inherently minimizes the challenges to the PORVs. This is discussed in the District's NUREG-0737 submittals. The second use of the PORVs is that of a backup to the steam generators for long term cooling, if the primary system is above 700 psia. This* would require the failure of the redundant auxiliary feedwater system. It is felt that the auxiliary feedwater system is adequate. In addition, the size of the PORVs would limit their effectiveness in providing cooling. The District plans to leave the equipment in the EPs to provide maximum flexibility in accident mitigation. Limitorque Motor Operator Lubrication: The District has taken steps to insure that lubrication of the opera, tors will also be quali fied. The operators' gear trains were qualified with Exxon Nebula EP-1. Limitorque recommends the use of Exxon Nebula EP-0. During conversations with Limitorque the District asked if any other greases could be used. Limitorque stated that the only infomation available to them indicated the use of the Exxon grease. However, other lubricant vendors could be contacted for grease qualification. As a result of this, the District has several of its valve operators using Texaco Marfac-2 as the lubricant. Texaco has provided qualification information which the District believes is adequate. The remaining valves have the Exxon Nebula EP-0 lubricant. Limitorque Limit Switch Lubrication: The limit switches on these items are lubricated with either Becon 325 or Mobil 28, 9. TER Item 85, 86, 897, 88, 89, 92, 99, 103 Pyrotrol III Cable, Cable Splice, Electrical Penetrations, Raychem Splices The Fort Calhoun Station is equipped with approximately 400 electrical penetration subassemblies which are used to provide electrical paths for instrumentation, control, and power for normal plant operation, and certain accident and post-accident functions. These electrical penetration subassemblies were manufactured by the Conax Corporation using TFE teflon for the seal, and FEP teflon for the lead wire insulation. As part of the preparation of the response to IE Bulletin .79-01B, testing information as described in Section 5.9 of the USAR was reviewed. Upon completion of a re-review of the available vendor-supplied documentation in February 1981, the District concluded that additional testing was necessary to meet-the 00R Guidelines. A separate radiation test was-dcne on the ' assemblies, and was not done in sequence as part of a LOCA. test. This was not in full compliance the D0R Guidelines which require sequential testing if a material is known to degrade severely under a stress parameter (in this -case radiation). Therefore, a purchase order for testing was issued to Wyle Laboratories on August 31, 1981 i

l 9. TER Item 85,. 86, 897, 88, 89, 92, 99, 103 Pyrotrol III Cable, Cable Splice, Electrical Penetrations, Raychem Splices (Continued) The time between purchase order issuance and the beginning of actual testing was used to determine what alternate' methods of sealing (RTV or Raychem sleeving) could potentially be tested and for preparing the test fixture and test samples. In preparation for final testing by Wyle, in March of_ 1982, a test sample consisting of seal and lead wire was irradiated to 9.9 x 106R gamma at Iowa State University. Although some material degradation was noted, the sample showed no leakage, the lead wire insulation remained flexible, and the insulation withstood a 500 VDC insulation resistance test -while immersed in salt water. NOTE: After experimentation with the alternate methods (RTV or Raychem sleeving) it was determined that the alternates could not be acceptably implemented and were subsequently dropped. The initial testing at Wyle Laboratories began in the fall of 1982, and consisted of the 40-year accelerated aging test. At the end of this

testing, excessive leakage was found.

This was reported to the Commission in a letter dated December 30, 1982. This seemed to be contrary to infomation contained in the District's surveillance test program which indicated no leakage. The District then began a research effort to identify the failure mechanism. A test sample was aged using the original criteria with leakage testing conducted at more frequent intervals. Failure was found -to occur between 20 and 30 years of qualified life. This was reported to the Commission in a letter datad March 8, 1983. Contact was then made with Conax and DuPont. The problem was identified as a cold flow problem due to high accelerated aging temperatures in which the seal material " flowed" in the subassembly tubing. Conax then developed a new aging criteria to more accurately model aging. This was completed in August of 1983. A second test sample was then aged, and no leakage was measured. The District restarted the test program with a modification such that the penetrations would be aged at the new temperature and then spliced on the already aged penetration lead wires, splice, and cable system.

However, due to a communications problem, the aged cable splices were destroyed in mid-February, 1984.

Subsequent to mid-February, the District attempted to locate part s,- construct new assemblies, and evaluate the impact on the schedule to determine if the' overall commitment date could be met. It then became necessary to age the lead wire, splice and cable assembly. The aging began-on March 20, 1984. On April 11, 1984 the splices addressed in Item 92 exhibited. severe cracking of-the outer heat shrink jacket following the aging test. The District has replaced these splices with qualified Raychem splices. ~ Testing, issuance and review of the final report, will be completed by September 30, 1984. This is after the District's

- 9 '. TER Item 85, 86, 897, 88, 89, 92, 99, 103 Pyrotrol III Cable, Cable Splice, Electrical Penetrations, Raychem Splices (Continued) commitment date of the end of the present refueling outage (early itary 1984). Thus, an exemption from this deadline was requested. Continued safe operation is justified as discussed below. j Justification for Continued Operation: (Franklin TER Items 85, 86, 87, I 88, 89, 92, 99, 103) The District elected to resolve specific qualification deficiencies in the above noted Franklin TER items by testing. 2 Specifically, Items 85 through 89, Rockbestos Pyrotrol III cable, were cited - for deficiencies related to aging, qualified life, and radiation. j Item 92, cable splices at electrical penetrations, were cited for deficiencies related to radiation, test sequence, aging, and qualified life. Item 103, Raychem cable splices, lacked adequate similarity (which j ~ has been resolved.) To summarize,. the Conax penetrations (Item 99) are being re-tested to insure the proper test sequence (eliminating separate effects) is completed. Items 92 and 103 are being tested to insure the penetration / splice system under proper test sequence is accounted fo r. The cables,- Items 85 through 89, are being tested to account for radiation and aging in proper test sequence. t i It is the District's engineering judgment.that safe operation is justified _until the test is completed and eval uated. Based on the information supplied by the vendor, the District believes the Pyrotrol III cable is similar. to the qualified Firewal. III which has a 40-year 1 quali fied life _ at 90*C.- Since - the cable is similar and. operates at significantly -lower than 90*C (qualification level of the Firewall III), the District expects littleJaging degradation. It - should be noted that the Pyrotrol III has successfully completed B . several -- LOCA tests, including radiation up to 1.79 x 10 R. Based on . similarity-to Firewall III and the several tests, the District believes 1that continued operation with Pyrotrol III is justified.- On - April.11, 1984 the splices -' addressed in Item,92 exhibi_ted; severe t cracking of the= outer heat ' shrink jacket af ter the _40' year aging test. The JDistrict has. elected to replace these ' splices. with. fully qualified splices-asL addressed in TER Item 103. The District plans' to continue the - interface. testing with the:Raychem.; i ~ It should also be' noted = that - the LDistrict has irradiated a ' penetration 6 10 R-a.t' Iowa State Univeristy. The lead wire insulation' ! sample to 9.9Tx was found to have degraded but ;is quite flexible'.and-should remain strong ' enough to insure the splice interface does not degrade._- e L. L p. u 3 4 -a, .x, ,w-.

9. TER Item 85, 86, 897, 88, 89, 92, 99, 103 Pyrotrol III Cable, Cable Splice, Electrical penetrations, Raychem Splices (Continued) The District believes safe continued operation is justified for the electrical penetrations, Item 99. As discussed earlier, a test sample 6 was irradiated to 9.9 x 10 R (approximate accident dose). The sample functioned properly under the limited testing. No leakage was measured at 60 psig, the insulation did not break down at 500 VDC with the lead wires immersed in salt water, and although there was some loss of structural strength, the insulation still required physical effort to remove from the wire and did not exhibit cracking when bent sharply. The District has also completed a successful aging test in which no leakage was measured after the equivalent of 40 years life. It should also be noted that the penetrations have successfully passed a LOCA test without aging.or radiation. 10. TER Item 91 - Amp Cable Splices at Solenoids These splices are installed on solenoids in the containment and Room 81 which are de-energized by the accident signal and are not required to operate in an accident / post-accident environment. Potential leakage of moisture will not. affect operation. The splices are in conduit, protected from direct spray or steam. -The District considers that the qualification is adequate. It should be noted that it is the District's judgment that coating the splices with RTV 732 clear will quali fy the splices for use in a DBA for both energized and de-energized use. In spite of this analysis the District has installed Raychem qualified splices on all solenoid splices which must be energized in a DBA (which includes a steam and/or spray environment). 11. TER ' Item 95, 96 - Containment Vent Fan Splices at Motor and Electrical Penetrations A. Qualification Analysis: 480V Vent Fan Splices Based on the results' of the attached Wyle Laboratories evaluation of the Fort Calhoun Station cable splices and the District's engineering judgment, the 480 VAC vent fan motor cable splices at the motor leads and on both sides -of the containment electrical penetration are adequately qualified for both LOCA and post-LOCA environments. -The key to full qualification of these splices involves the consideration that the splice -

11. -

TER Item 95, 96 - Containment Vent Fan Spifces at Motor and Electrical I Pen'etrations A. Qualification Analysis: 480V Vent Fan Splices (Continued) n is a system in which the inner layers of tape ensure the electrical integrity of the circuit. The outer layer of RTV sealant (Dow Corning -3144 or 3145 clear). provides the protection and electrical insulation from normal and potential harsh environment parameters. A complete description of the motor lead cable splice system is detailed in - Enclosure 9 to the District's letter dated August 26, 1981 (see E -Attachment 5). _A description of the cable splice system at the-electrical penetrations is provided as Figure 1, page 22 of the enclosed Wyle Laboratories Report, (see Attachment 6). To substantiate the District's engineering

judgment, each of the applicable environmental stress parameters (pressure, humidi ty, steam, temperature, chemical spray, radiation, and aging) was evaluated to determine its impact on the splice systems.

The results of the i L investigation are as follows: 1. Pressure': The splices are a mechanically passive system which 1.- provide electrical insulation and protection for the connection. Insulation has been placed over the connector and wire jacket in such a fashion as to minimize. voids and a layer j - of RTV covers all of. this. With this configuration and the small. surface-_ area of the splice, only a small mechanical force i can be, exerted. The District believes this small compression could not cause mechanical damage that would lead to splice failure. In addition, this force tends to compress the splice, [ ensuring water tightness. Aging information indicates that the material should remain functional' throughout the life of _' the - plant, indicating that a pressure transient ' should not. cause splice failure. This : conclusion is also substantiated by the fact that -the splices have remained functional throughout three-containment l integrated leak rate tests in which the fans j operated at accident pressure. F .2. Humdity: The RTV-and various tapes provide an adequate barrier which is substantiated by almost 10 years :of. successful operation. (NOTE: The RTV was applied to the electrical penetration splices in.1980.)- + ( .,c,'- g - r 4 ~+ s -*k+-yw a y y g-s-- y N,- = y--- -+v.cer ', n -e..---- r. =~~.1% rwe ,+ie-w.,,.

11. TER Item 95, 96 - Containment Vent Fan Splices at Motor and Electrical Penetrations (Continued) A. Qualification Analysis: (Continued) 3. Steam: The District believes the protection provided by the RTTTs an adequate barrier to steam. 4. Temaerature: The District judged the splices to be adequate to wi t1s tand the accident temperature environment. The RTV is expected to remain pliable during the DBA transient and be able to accommodate any expansion of the splice due to current induced heating and environment. Since the major contribution to the expansion is the environment (which will return to near normal within one hour), radiation is not expected to cause embrittlement which would detract from the RTV " response". Wyle Laboratories Report No. 26333-25 concludes that the splices and their material constituents can withstand the effects of exposure to the peak accident temperature of 305'F. Please refer to Section 4.3.3.3 of the subject report. 5. Chemical Spray: The only splices which potentially could be exposed to chemical spray are the containment side electrical _ penetration splices. 1he motor lead splices are protected by a junction box, and the penetration splices in Room 81.are not exposed to chemical spray. Furthermore, RTV is not affected by mild acid and basic solutions and precludes damage by chemical spray. 6. Radiation: For radiation qualification, three categories of splices were evaluated and the results are presented below. The first splice of concern is the electrical penetration cable splice located in Room 81 of the auxiliary building. These splices are outside the containment and are not expected to be affected by radiation. No further evaluation is required for these splices. The second splice category includes the vent fan motor lead wire splices inside containment. These splices are protected by a junction box which eliminates the effect of beta radiation an the spl ice. Calculations indicate that VA-3A and VA-3B could be exposed to a maximun gamma dose of 8.64 x 106 rads, and VA-7C and VA-70 could be exposed to 1.92 x 107 rads gamma. Both of these exposures are less than the 1.0 x 108 rads threshold level for these splices which is summarized in Table 5 of the Wyle report. The third category of splice evaluated was the electrical penetration cable splices locatcd inside containment. The radiation exposures to these splices would be as follows: ig. J C

11. TER Item 95, 96 - Containment Vent Fan Splices at Motor and Electrical . Penetrations (Continued) A. Qualification Analysis: (Coltinued) Maximum Exposure at Maximum Exposure at I.D. of RTY and 0.D. of

0. D. of RTV (Rads)

Splice Insulation (Rads) Gamma Radi-1.475 x 107 (1) 1.475 x 107 ation Beta Radi-2.0 x 108 (2) 2.0 x 105 (3) ation Total Inte-2.1475 x 108-1.495 x 107 grated Dose (TID) Il0TES: (1) Includes a normal exposure of 3.5 x 105 rads (i.e., a conservative 1 R/hr for a 40 year operating life) and an accident exposure of 1.44 x 107 rads. (2) Combined normal and accident exposure as recommended by the DOR Guidelines. (3) RTV of approximately 1/8" thickness (125 mils) reduces the beta radiation of a factor of 1000, therefore reducing the 1 beta exposure to 2.0 x 105 rads at the outer layer of splice tape. As _ indicated in the table above and in the Wyle Laboratories report, the RTV is a nominal 1/8" thick on the splice and attentuates the beta exposure to approximately 2.0 x 105 rads at the splice RTV/ tape interface. This results in a TID to the tape surrounding the splice of 1.5 x 107 rads. In reviewing the ef fect of. this radiation exposure on the splice electrical insulation (i.e., tape), a system review is necessary. The insulation consists of inner layers of Irrathene SPT tape, and Irrasil and Scotch 33 - tape are utilized for protection and to hold the Irrathene SPT tape. Item 3 of Table 3 on page 29 of ' Wyle - Report No. 26333-25 demonstrates that the Scotch _33 and Irrathene SPT tape provide adequate radiation resistance to the maximum expected exposure. The Irrasil tape could be expected to degrade after approximately one hour of accident operation; however, since - its purpose is to hold the quali fled Irrathene SPT tape and is itself supported by the Scotch 33 tape, the District believes. the Irrasil ~ tape would not contribute to failure of the splice system. Additionally, in reviewing.

11. TER Item 95, 96 - Containment Vent Fan Splices at Motor and Electrical Penetrations (Continued) A. Qualification Analysis: (Continued) radiation test information (attached) provided by Dow Corning, both RTV 3144 and 3145 clear are known to embrittle with radiation exposure. However, RTV 3144 did not fail at an exposure of 1.94 x 108 rads and failure only occurred after mechanical stress was applied at 4.55 x 108 rads. Based on this embrittling test information, and the fact that each 30-40 mils of RTV reduces the beta radiation by a factor of ten, the District is confident that at a minimum the inner thickness of RTV will maintain its integrity and ensure operability of the splice. 7. A in : Wyle Laboratories Report No. 26333-26 (see attached) in 1 cates that no aging related failures should be e1 countered. Please refer to Section 3.0 of the subject report for details. B. Operating Experience: As stated

earlier, these splices are required to maintain the electrical integrity of the power circuit.

,The District must insure that the RTV remains pliable to expand during temperature transients to accommodate any expansion of the cables and tapes. Some of the splices have been in service for approximately 9 years. An inspection was conducted in early April 1984. The RTV was found to still be resilient. This included full load on the fan motors during the containment leak rate test. The other material s in the splices are normal for splice applications and many have demonstrated years of satisfactory service. C. Qualification Maintenance: The District plans to inspect the splices each re fueling to insure integrity and pliability of the RTV. D.

== Conclusion:== The District considers the splices qualified based on the preceedinj discussion. One further area should be reviewed, that of potent 1al moisture and current leakage. The analysis c Mnstrates that the splice system will exclude the enviror s from r.he circuit. Therefore, it is reasonable to make the assumption that a major failure of the splice would not be expected. The District judges that any leakage would be minor. The fans are supplied from a floating 480V Del ta 3 Phase System. Two phases shorting.or two phases to ground are required to cause any interruption of the circuit. . E

F 11. TER Item 95, 96 - Containment Vent Fan Splices at Motor and Electrical -Penetrations (Continued) l D. Conclusion (Continued) Since at worst only minimal moisture leakage is expected, leakage currents would be on the order of milliamps to the 1 amp range. Full load current for VA-3A and VA-3B is 238 amps and 143 amps for VA-7C and VA-70. Milliamps to 1 amp leakage currents are not large enough to cause a fault. Additionally, there would not physically be enough room for enough moisture to conduct fault current. It could also be expected that any heating cause by leakage current would not damage the splice material and would be expected to " dry" the circuit, interrupting the leakage path. Minor moisture leakage is not expected to be a problem if it were to occur. 12. TER Item 97 - States Terminal Blocks To insure the integrity of the circuits which are made using the terminal blocks, each terminal block, including wire lugs and incoming lead wires, are coated with qualified RTV3144 (3145 clear). The blocks are enclosed in junction boxes which protect against direct spray. Since the circuit is protected, leakage currents are not expected to cause a problem. 13.~ TER Item 104 - COMSIP H2 Analyzer The District has investigated the aging methodology used in the COMSIP qualification. The vendor used the 10*C rule to establish a qualified life of 5 years. This included addressing of the sample pump failure (weak link) in the system. The District applied the Arrhenius Method to the aging information and obtained a plant specific qualified life of 15 years. In spite of this information, the District intends to refurbish the analyzer on a 5-year interval. There is a GE CR2940 control switch installed which is susceptible to 6(failure radiation damage as -reported in IE - Information Notice 83-45 occurred at 3.7 x 107 rads). The expected exposure is 1.56 x 10 R. This -lower than tested exposure (which passed the qualification test) leads the District to judge the unit to be qualified. A review of EPRI NP2129 indicates that at the expected dose the Delrin material would lose about - 30% of its tensile strength vs greater than 75% for the tested exposure. h

r-1 J ATTACHflENT 3 4 9 ..A._

y 3 Omaha Public Power District Fort Calhoun Station Electrical Equipment Qualification Program and Compliance With 10CFR 50.49 (b)(1), (b)(2), (b)(3) 1. History The District's present program for compliance with the electrical equip-ment in a harsh environment qualification rule 10 CFR 50.49 began in Jan-uary of 1980 with the actions required by IE Bulletin 79-01B Environmen-tal Qualification of Class 1E Equipment. The required action expanded the scope of IE Bulletin 79-01 and its related documents. The District based its investigation on the D0R Guidelines provided with IE Bulletin'79-01B. The exceptions to this are those items which require different qualification criteria as provided in NUREG-0578 and subsequent-ly NUREG-0737. Several submittals to the NRC were made including the "45 day", "90 day", " November 1,1980", " Inclusion of Equipment to Achieve Cold Shutdown", and several to note equipment changes. A large submittal of test reports was also made to the Franklin Research Center, from which the latest TER was written. The District has also responded to one SER with many specific questions. The unit is in a refueling outage and the modifications which were discussed in the response to the TER are to be accomplished. The submittal document used by the District is being transformed into a more streamlined document to be used during the day-to-day operation by District personnel. Necessary Qualified Life Program maintenance is to be performed. Documentation open items are to be closed out and the District has hired an independent contractor experienced in equipment qualification to audit the District's entire Electrical Equipment Qualification Program. Additionally, the District believes it would be beneficial to explain the manner in which IE Infomation Notices are handled. Upon receipt, the Licensing Department makes an assessment of the notice to determine the appropriate department for response preparation. An assignment is made and progress is tracked via the District's Licensing Action Log. The assignment requests a review with respect to applicability, potential impact, and possible corrective action. The results of the review are documented for in-house record-keeping purposes and are retained by the District's Licensing Department. II. District's Electrical Equipment Qualification " Philosophy" (10CFR.50.49 (b)(1) A. Basis for the Evaluation 1.- In order to establish the bases for the assessment and this report, as well as the master lists and environmental work-sheets, several preliminary steps were taken. -The first step in the assessment program was to conduct a review of the fa-cility flow diagrams to establish which systems were required ~to mitigate the consequences of a LOCA. After the bases for the LOCA conditions were established, the District began an 1

II. . District's Electrical Equipment Qualification " Philosophy" (Continued) A. Basis for the Evaluation (Continued) 1. (Continued) evaluation of the high energy piping systems to determine whare failure of a pipe could cause Engineered Safeguards systems to be challenged. After these lines were identified, a cross-check of areas within the plant was made to determine if a HELB would affect any Class 1E electrical equipment which was required to func-tion under the postulated accident conditions. The components which were identified as a result of the above studies were then further evaluated for their suitability for operation in the postulated environment. The following is a description of the safety systems, high energy lines, and areas taken under consideration by the Dis-trict. a. Identification of Safeguards System: In order to ensure that all of the components requir(d to operate to mitigate design basis events were identi-fied and assessed for their impact on plant safety, a survey of each plant system was made to identify re-quired flow paths for accident mitigation. In addition, all systems were reviewed for isolation requirements af ter receipt of Engineered Safeguards Signals. As a result of this survey, the following systems were identified as either being required to operate or as Iaving components which required isola-tion on receipt of Engineered Safeguards Signals: (1) Reactor Coolant System (2) High Pressure Safety Injection System (3) Low Pressure Safety Injection System (4) Containment Spray System (5) Containment HVAC System (Containment cooling units and isolation valves) (6) Component Cooling System (7) Raw Water System (8) Main Steam System (9) Steam Generator Feedwater and Blowdown System (10) Chemict.1 and Volume Control System (11) Containment Hydrogen Purge System (12) Control Room Ventilation System (13) Instrument Air System-(Isolation valves only) (14) Plant Air System (Isolation valves only) (15)' Sampling. System (Isolation valves only) (16) Demineralized Water System (Isolation valves . only) 2;

LII.. District's Electrical Equipment Qualification " Philosophy" (Continued) A. Basis for the Evaluation (Continued) 1. (Continued) t a.. Identification of Safeguards System: (Continued) (17). Waste D1sposal system (Isolation valves only) (18) Electrical Auxiliary Components (which were common for all of the above systems) (19) Nitrogen System (Isolation valves only) (20) Charging and Concentrate Boric Acid 7 (21) Reactor Protective Systemo (22) ESF Actuation Systeml (23) 120 VAC 10 and 130V DC Instrument and Control Power 2 (24) 480 VAC 30 and 4160 VAC 30 Power 2 (25) Emergency Diesel Generator 2 (26) Ventilation for Areas Containing Safety Related Equipment 3 (27) Post Accident H2 Sampling and Radiation 11onitoring t (28) Long Term Core Cooling 8 After identification of the systems had been completed, i the system list was cross-checked against Appendix A of the Guidelines for Evaluating Environmental Qualifica- - tions of Class 1E Electrical Equipment in Operating Re-actors. -In general, there is a close correlation be-i: tween Appendix A and the system listed for the Fort Cal-houn facility. However, certain specific systems are 3 not required _at Fort Calhoun to achieve a safe shutdown under the postulated accident condition. In addition, some of the systems. listed are unaffected by either LOCA or HELB environments since they are located out-side. of affected areas. It should be noted that hot shutdown condition is defined as safe shutdown condi-tion for Fort Calhoun Station. . These systems arid the basis for. excluding them from the District's response are as follows: 7 i - (1) Engineered Safeguards Actuation - The system'.com-i .ponents which initiate safeguards actuation are contained and evaluated-as : components within the p . systems identified for Fort Calhoun. 4 . (2) i Emergency Power - The emergency: power system for Fort Calhoun consists 'of two diesel generators i . and associated distribution equipment such as + switchgear-and motor control centers.. In addi-i p' tion a-130VDC system consisting of fully redun-dant. batteries, chargers and associated distri-bution equipment is available at Fort Calhoun. - ~ E - None of.the postulated accident ' situations affect ' the environment where this equipment-is located. Since this is the case, no _ evaluation of.individ- _ ual components has been_done. 3 G

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II. District's Electrical Equipment Qualification " Philosophy" (Continued) A. Basis for the Evaluation (Continued) 1. (Continued) a. Identification of Safeguards System: (Continued) (3) Ventilation for Areas Containing Safety Equipment - Where ventilation equipment is required for op-eration of safety equipment, and it is affected by the postulated event, then it has been as-sessed for the resultant environmental condi-tions. (4) Emergency Shutdown - The District has performed an analysis of the systems required to bring the reactor to a cold shutdown condition after an accident involving rapid depressuriztion of the primary system with no breach of the reactor coolant pressure boundary. The safety analysis for Fort Calhoun shows one possible event which could cause this situation to occur. The event is a steam line rupture incident. Plant emer-gency procedure EP-6 " Uncontrolled Heat Extrac-tion" was referenced to determine those systems necessary to limit the consequences of this event. After review of EP-6, it was determined that there are no additional systems required to function than those which have been previously identified. (5) Safety Related Display Instrumentation - The plant emergency procedures for both loss of cool-ant accident and main steam line break uncon-trolled beat extraction have been investigated and the components which are relied upon to func-tion after these events have been assessed for . environmental qualifications. These items are evaluated as components within the systems iden-tified for Fort Calhoun. Also included is the instrumentation installed un-der NUREG-0578 and 0737. (6) Reactor Trips - For the LOCA analysis, Low Pres-surizer Pressure initiates a reactor trip. See the following discussion on Small Break LOCA. Review of the small break LOCA analysis has shown that for all small break LOCAs, low pressure is the parameter which initiates a reactor trip. . The reactor protective system (RPS) uses loop temperatures and reactor power (Delta T or nu-clear whichever is higher) to generate a calcu-lated pressure. (thermal margin low pressure) which is fed into a bistable and compared with 4

I I'. District's Electrical Equipment Qualification " Philosophy" (Continued) A. Basis for the Evaluation (Continued) 1. (Continued) a. Identification of Safeguards System: (Continued) (6) (Cc,atind actual reactor pressure. If reactor pressure falls below the calculated number, the reactor trips. In addition, the bistable is set with an absolute low limit such that no matter what the calculated input, the reactor will trip at a pressure no lower than 1750 psig. It is this 1750 psig trip point which trips the plant in the small break LOCA analysis. Since the failure of unqualified equipment in con-tainment cannot affect the low limit trip value and.the RPS pressurizer input are LOCA qualified, no further analysis is required for small break LOCA reactor trip. The remaining equipment used to mitigate a small break LOCA is discussed in the master list. Discussions with the District's NSSS vendor have indicated that for small steam line breaks, low steam generator levels will be the reactor trip initiating parameter. Therefore, worksheets are included for the low steam generator level LOCA qualified transmitters. For the MSLB, the reactor trip is initiated by Low Steam Generator Pressure which is LOCA qual-i fied. No other reactor trips are required to be quali fied. Clutch deenergization is accomplished in the con-trol room mild environment. (7) .The Fort Calhoun Station Safety Analysis does not take credit for the charging pump or concentrated boric acid system. (8) The long term core cooling system is made up of components from other systems. It should be noted that hot shutdown condition is defined as safe shutdown condition for Fort Calhoun Station. A master list has been prepared for each systen, listing those components which were identified as-Class 1E and which could-be-affected by a LOCA or a high energy line break. This completed the first step of the District's review. 5 t-

1 l IIi: District's Electrical Equipment Qualification " Philosophy" (Continued) LA.: Basis for the Evaluation (Continued) 1. (Continued) b. Identification of High Energy Lines The' basis for evaluation for HELB effects on Class 1E electrical components is Appendix M of the Final Safety Analysis Report. A review of the high energy lines listed in Appendix M was conducted to determine which, if any, would have an effect on plant systems and equip-ment. It was determined from the review that only a main steam or main feedwater line break could cause an accident condition under which plant safety systems might be challenged. HELB for any other systems listed would not require engineered safeguards systems to operate for any reason, these lines were excluded from this ' analysis. After determination that main steam and main feedwater lines could cause actuation of safety systems, these lines were reviewed to determine where Class 1E equip-ment could be affected as a result. Two areas were sub-sequently identified and investigated in greater depth. The first area is within the reactor. containment it-sel f. Since a main steam-line break is of nore conse-quence than a main feedwater line break, the main steam break was_ addressed. The Fort Calhoun facility is equipped with an automatic containment spray system equipped with redundant pumps, lines and spray headers. As such, it is not subject to disabling by single com-ponent failures. Therefore, in accordance with Enclo-sure 4 of IE Bulletin 01B,.it has been determined that the.LOCA environment will_ govern qualification of equipment located within the containment. For a main steam line or main feedwater line break out-side of containment, the only Category 1E electrical equipment which could be affected is located in Room

81. The effects of-a main steam or feedwater line'-

break on the environment of' Room 81 are discussed in - Appendix M of the Final. Safety Analysis Report and 'in of-this document. The break within Room 81,~ results in the " worst case environment". - The anal-ysis conducted on the components within the areas af-. fected was thus governed by the main steam line break, wi,th the exception'of flooding.- Flooding within Room 81~ is more limited for_ a main-feed-water line break and the flood level predicted in the. .FSAR was utilized to analyze the components subject to possible flood damage.. _ This completed the second step of the District's review. 4 1 -6 ~ ~ a-

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II. District's Electrical Equipment Qualification " Philosophy" (Continued) A. Basis for the Evaluation (Continued) 1. (Continued) c. Areas Where Fluids Are Recirculated to Accomplish Long-Term Core Cooling The areas which have been addressed for consideration of fluids from inside containment are Rooms 13, 21, 22, 59, 60, and 69. These areas were chosen since this is the only area where fluids would be recirculated follow-ing the postulated accident. Other systems where fluids from inside the containment are normally circulated are isolated under the postu-lated accident conditions. The isolation valves for those systems have been reviewed for their capability to function under the environment expected. 2. R'adiation Analysis - Reactor Containment The postulated radiation environment for components located in the Fort Calhoun reactor containment are based on a speci-fled gamma level of 1R/HR for 40 years, plus the dose re-ceived during a LOCA (see Enclosure 1). This total dose of 3 x 106 RADS was specified for the equipment used within the containment which is required to function in the accident en-vironment. Since this dose level is less than the 2 x 107 RADS considered acceptable under Enclosure 4 of IE Bulletin 79-018 " Guidelines for Evaluating Environmental Qualifica-tions of Class 1E Electrical Equipment in Operating Reactors", the District has performed a series of calculations to determine the expected doses. For equipment whose geometry or location influenced dosage, spec:al calculations were done using IS0SHLD. For those components located below flood level, the District

• has calculated the expected dosage using ISOSHLD.

The shielding study and subsequent refinements performed for areas outside containment as part of NUREG-0578 were l used _ to provide dose levels in the auxiliary building. 3. Submergence After completion of the master list, a survey was made for 'the components located within the containment building to determine if they were subject to flooding. The flood level used as the basis for this evaluation is 1000.9'..This level was arrived at by investigating all pos-j 7 1 li I

1 II. 61 strict's Electrical Equipment Qualification " Philosophy" (Continued) A. Basis for the Evaluation (Continued) 3. Submergence (Continued) sible sources of water which could be pumped into the contain-ment or released from systems within the containment prior to entering the recirculation mode. For conservatism, the en-tire contents of the Safety Injection Tanks, the Safety Injections Refueling Water Tank, and the Reactor Coolant System were assumed to be dumped into containment prior to any recirculation actuation. The resultant flood level thus represents the entire water inventory available to mitigate the consequences of a LOCA and is considered to be a conservative number. B. Component Qualification Philosophy The District's " Philosophy" on Electrical Equipment Qualification stems from the nanner (method) in which qualification was demon-strated. -Specifically, the District's Qualifica :on Program is organized'to demonstrate the listed equipment's ability to function under environmental stress (harsh environment) and have adequate margin to insure operation, and operating time. As discussesd in Section A, " Basis for Evaluation", the FSAR was used to provide LOCA and HELB information. For evaluation of equipment plant specific environmental profiles were used as provided in the FSAR Section 14 and Appendix M. Please note, for the LOCA' profile this was modified by the first SER which required the use of 305'F temperature. The methods used to demonstrate the compliance of equipment to the above philosophy _can be placed in four categories: 1.- For those items where analysis indicated that qualificaticn could not-be accomplished or where testing of some type was available, but where analysis to demonstrate complete quali-fication could not be accomplished,- a replacement to fully qualified equipment was, or is presently being, accomplished. i

The solenoid and limit switch upgrades are examples 'of equip-ment in which analysis indicated that qualification was not feasible. The Foxboro transmitters are examples of equipment which were' upgraded when analysis and testing could not be combined to demonstrate qualification.

t 8 F y e f - p. 4 ,3 myp, _,....... _ yap 3 p

II.- District's Electrical Equipment Qualification " Philosophy" (Continued) B. Component Qualification Philosophy (Continued) 2. For those items where existing test data and/or analysis could not completely qualify the equipment and there was adequate information to indicate that additional testing (coupled with analysis where applicable) could demonstrate qualification, additional testing was done or is planned to be done. The Conax penetrations and Fisher 304 limit switches are examples of this effort. Also, in the case of the 304s and 546 positioners, the components were reviewed for significant aging of materials. This was based on the D0R guideline,. Table C1. Ilo aging tables were used, as long as applications were within vendor temperature limits. 3. For those items whose existing analysis or test data was not adequate, additional analysis was performed to establish qualification in aging, chemical spray, and radiation. The component cooling water pump motors are an example of this effort. 4. For those items which have some test data but for which spec-ific -analysis is required, a system (i.e., splicing materials which are combined to form a splicing system) analysis is made to demonstrate how the system is qualified to perform the function. To date this has been perfonned only on the containment cooling and filtering unit ventilation fan motor splices. This type of analysis has been limited to systems which are not active in a DBA, i.e., these splices perfonn a protective function. This analysis was provided in the District's TER response. To complete the qualification of any. equipment covered by the EEQ Program, the following items must all be included; margin, aging, operating time, and operator presentation. It is the District's judgement that the margin, aging or qualified: life, and operating times must be reviewed as a single item. Margin is the " parameter" which demonstrates that if the equipment is exposed to a Design Basis Accident, sufficient testing stress or analysis demonstrated stress capabilities are built into the equipment such that failure would not be expected. Aging is a deteriorating characteristic which must be accounted for to insure that . equipment has not deteriorated to the extent that the -stresses presented in a DBA would cause failure and that as-surance of post accident operation (operating time), if required, can be assured. a

II. . District's Electrical Equipment Qualification " Philosophy" (Continued) -B. Component Qualification Philosophy (Continued) _ IE Bulletin 79-01B, Enclosure 3, " System Component Evaluation Worksheet" requires specification of the time period that the component or equipment is required to function and identification c of the document which provides the basis for this time interval. of the bulletin requires that the time duration of the test should be at least as long as the period from the initiation of the' accident until the temperature and pressure service l conditions return to essentially the same levels that existed before the postulated accident. Additionally, Enclosure 4 stated t that a shorter duration may be. acceptable if specific analyses are provided to demonstrate that the materials involved will not experience significant thermal aging during the period not tested. Supplement 2 to IE Bulletin 79-018 requires that equipment designed to perform its safety-related function within a short time into the event be qualified for a period of at least 1 hour in excess of the time assumed in the accident analysis. Also, Supplement 2 references NUREG-0578 in requiring qualification of equipment in close proximity to recirculating fluid systems inside and outside containment as a result of LOCA. This equipment is the equipment j required to function in "long term" as required in Supplement 2. As a result of the above-mentioned requirements, the District defined four levels of required qualification - 1 hour,1000 hours (42 days),100 days and 1 year. The 1 hour specification is applied to equipment whose safety function is completed within a few seconds after receipt of an accident signal. The 1 hour equipment was evaluated for the effects of subsequent failure on the safety systems and the potential for misleading the operator. Where subsequent failure could degrade the plant safety system s. status or the potential for misleading the operator existed, the -level of required qualification was increased. The 1000 hour specification is applied to equipment which is required for LOCA, i HELB, or safe shutdown. The equipment in this category functions during the entire DBE until the plant environments return to essentially the same levels that existed before the postulated accident (see' discussion below)..The 100 days is for the containment hydrogen analyzer. The 100 days are expected to be l adequate to detect.a containment H2 problem and take necessary . action. The long term (1 year) specification.is applied to equipment which must operate for a significant amount of time af ter. LOCA and is not accessible'during the course of the accident. -Long term is defined as the naximum time necessary 'to achieve cold l shutdown. The long term specification is consistent with ' Supplement 2 of IE Bulletin 79-018. i l i. L i 10-r n , _. _ Z_ _... ;

_, a,,.

II. District's Electrical Equipment Qualification " Philosophy" (Continued) B. Component Qualification Philosophy (Continued) In some instances the District did not believe a rigorous aging solution was required, as in the case of Fisher 304 limit switches which are not subjected to high temperatures or pressure, and which use materials which do not show significant aging. The only environmental stress is that of radiation for which the switch is tested; the temperature exposure is within the range the vendor feels is correct for the limit switch application. Since the material shows no significant aging and no radiation induced failures were encountered, the switches are considered qualified for forty years. The last area of the EEQ program is that of presentation of infonna-tion to the operator. This is divided into two areas, accuracy of analog information and a method to insure instrumentation which may fail does not mislead the operator into taking an improper action. With regard to instrument accuracy, the District has performed anal-yses to show that although the accident stress causes inaccuracies, these should not mislead the operator, or cause actions which are detrimental to plant safety. Also, for any accident, not all trans-mitters are required to function, or could these be expected to give a large amount of useful information. This is defined in the analysi s. For those transmitters which must initiate an autoinatic action in an accident, the environmental stress induced inaccura-cies are accounted for. The other area of operator interface is the quick and easy identifi-cation of valid information. The District believes that this must be presented in a way which is quickly identified and does not cause confusion. To accomplish this, orange dots have been placed on the control board name plates to identify qualified equipment. This allows the operators to conduct post-accident operation with-out referring to special additional instructions. III. - Qualified Life Program The District's Qualified Life Program (QLP) is the means by which the Dis-trict has implemented a system which accomplishes several aspects of an ongoing Electrical Equipment Qualification Program. These items may be characterized as,1) qualified equipment tracing program, 2) qualifica-tion documents, 3) maintenance-or refurbishment schedule to maintain qual-ification, 4) breakdown maintenance, and 5) future modification control. As implemented, administrative and technical direction for the QLP re-sides in three documents,1) Fort Calhoun Station Standing Orders, 2) Gen-erating~ Station Engineering Manual, and 3) the Electrical Equipment Quali-fication Manual. e 11 Z ~T

III. Qualified Life Program (Continued) The QLP's operation is summarized in the following discussion. First is the actual maintenance of qualification (refurbishment to ac-count for aging). This is accomplished by the previously discussed Items 1, 2 and 3. The District has elected to maintain a central file where, in the Dis-trict's judgement, are all the test and analysis documents necessary to establish equipment qualification. These documents (tests, analyses, etc.) must be tied to field equipment to both demonstrate qualification and establish any needed refurbishment interval. This is done in the form of an Equipment Qualification Documentation Form (EQDF) in which one of these, per device, is issued. Once necessary maintenance (or cycling) has been identified, the refur-bishment, including procedures, must be placed in the plant maintenance system. The effort is controlled by plant Standing Order. Maintenance Procedures were written as required to refurbish. However, maximum use was made of existing plant procedures including surveillance tests, calibration procedures, and existing' preventive maintenance proce-dures. When refurbishment is completed, an FC-198 form is conpleted which up-dates the central file to document continued qualification. It should be noted that although such things as cycling are noted and accomplished, the central file is not updated. In many of these cases existing proce-dures are used. Breakdown maintenance and equipment failure is controlled under plant Standing Orders. These controls insure compliance with 10 CFR 50.49 - spare or replacement parts - and documentation of continued qualifica-tion. If the repair requires replacement and an upgrade to NilREG-0588 is to be done, the station modification controls (to be discussed later) are used. If a subcomponent is replaced or a one for one replacement is justified (sound reasons to the contrary) the FC-198 is used to establish continued qualification. In order to insure future qualification of yet-to-be-installed (and un-known) modifications, it is necessary that all modifications to the station be included in the QLP if their function warrants inclusion. To accomplish this, Standing Orders have been updated to insure that equipment is included in the ongoing program. Other administrative ^ control documents related to station modification control (GSE Manual and the EEQ Manual) serve to insure all modifications meeting the QLP criteria are treated in the same manner as the equipment originally in the QLP scope. e 12 e-

"III Qualified Life Program (Continued) Update of all document files, procedures, and programs will be handled in the same manner as other document and program updates, as required by Lplant standing orders governing modifications. It should be noted that the QLP documents provide guidance as to how to . establish qualification, fill out necessary forms, and evaluate vendor information. - To summarize, the District's QLP accomplishes three major test tasks,1) -documents. qualification, 2) actually maintains equipment in a qualified condition, and 3) accounts for future unknown nodifications. The Dis-trict believes this is accomplished within the guidance of 10 CFR 5,0.49. ^ 0 113 L-._

1 IV.- District Position on 10CFR50.49(b)(2) 10CFR50.49(b)(2), "Nonsafety-related electric equipment whose failure under postulated environmental conditions could prevent satisfactory accomplishment of safety functions specified in subparagraphs (1) through (iii) of this section by the safety-related equipment." It is the District's engineering judgement that the Fort Calhoun Station is in compliance with the requirement of 10CFR50.49(b)(2). To insure this, the District has used a four step apprcach. These steps are: 1. A review of the station's 480 and 4160 volt power distribution system to insure adequate circuit protection. 2. A review of the District's response to IE Bulletin 79-22 on potential unreviewed safety questions caused by the interaction of non-safety grade and safety grade systems and IE Bulletin 79-27 on the adequacy of station instrument and control power distribution systems. 3. A review of station modifications installed since the bulletins were issued to insure no modification had been made which could cause an unreviewed safety question. 4. A review and update of the safety analysis procedure (Standing Order G-46) to insure that all modifications (including those designed prior to the -issuance of 10CFR50.49) are reviewed for the effect of non-safety related failures on safety related equipment. Based on these reviews it is the District's engineering judgement that the following statements are applicable: 1. The Fort Calhoun Station instrument and control power and three phase AC (4160V and 480V) systems are designed with proper isolation and fault clearing coordination. A fault on a non-safety related device should not affect the operation of a safety-related device. 2. There is no known failure of a non-safety related device (i.e. solenoid failure causing a valve to open) which would create an accident outside the bounds of any analyzed event. 3. .No modifications have been installed which would alter the conclusions made in 1 and 2. This is based on an independent study by Stone and Webster Engineering Corporation. 4.- The station modification control is adequate, the requirement for an unreviewed safety question analysis per 10CFR50.59 is required. Addi-tional information was added regarding electrical equipment in a harsh environment. Based on this review it is the District's judgement that no further action is required with regards to 10CFR50.49(b)(2). 8 14

V. - (b)(3)- Certain Post Accident li:nitoring Equipment It is the District's judgement that post accident monitoring equipment has been adequately considered. Those itens required in the Station Emergency Procedures have been identified and qualified for the required function and environment. Final implementation of all post accident monitoring equipment will be completed in accordance with the schedule for Reg. Guide 1.97, Rev. 2, as negotiated in NUREG-0737, Supplement 1. Any changes or upgrades to accident monitoring equipment will be implemented on a negotiated schedule. Also included in the EEQ Program are certain components of the accident monitoring equipment installed as part of NUREG-0737. 1 w 9 15 l W~

ATTACHMENT 4 9 6 4

ELECTRICAL EQUIPMENT PRESENTLY UNDERG0ING QUALIFICATION TESTING As discussed in Note 9, the District presently has underway a qualification program for the containment electrical penetrations, splices, and electrical cable. The testing is tentatively scheduled to be done in accordance with the following: Agin9 April 9,1984 Short Time Overload and Short Circuit April 18,1984 Seismic April 23-24,1984 Irradiation

• April 27-30,1984 LOCA*

May 3-21, 1984 Short Circuit

• May 24-28,1984 Report Complete
• June 29, 1984 Based on schedule estimate made prior to testing.

Schedule has slipped with irradiation in progress the week of May 14, 1984. 1

r. - t 3 } l-i e ATTACHMENT 5 3 3 9 k'I i s' t. 't 3i. ~ -...

ENCLOSURE 9 Containment Vent Fan flotor Splices i The containment vent fan motor lead splices (VA-3A, 3B, 7C and 7D motor lead splices) are, in OPPD's engineering judgment, environmentally qualified for the adverse conditions of a LOCA. Reasons for this judgment stem from the following:

1. 70 tape are applied to the

~1) First, eight half-laps of Scotch Brand U3 high bare joint / splice. Second, eight half-laps of Bishop Brand voltage tape are ' applied over the splice surface. Third, the joint / plice area is then covered with eight hal f-laps of Scotch Branl 88 tape. Fourth, an additional two hal f-laps of Scotch Brand

1. 70 tape is then applied over the general splice / joint area.

gastly, the entire splice / join $ area is covered with Dow Corning RTY 3144 compound at least 1/88 thick and at least 1" beyond all applied tape. The RTV is smoothed to completely seal the splice / joint and then the RTV is allowed to cure in accordance with instructid1s. ecent conversations with the manufacturer of Scotch Brand I70 and 2) g88 -tapes have revealed satisfactory test results were obtained for samples of the two aforementioned tapes when subjected to radiation fields in the neighborhood of 50-100 x 106 rads. Due to the RTV sealant, this tape will not be subjected to the pressure, moisture (100% R.H.), boric acid conditions present in a LOCA. In addition, both tapes mentioned above are cap 3 ia of operating in temperatures in excess of 350*F with no subsequent damage. 3) The entire splice / joint is covered with a layer of RTV #3144 adhesive / sealant. Conversat'ons with the manufacturer of the RTY, Dow Corning, revealed that several laboratory tests were run on the aforenentioned RTV. Results of ' these tests revealed that the Dow Corning RTV #3144 was capable of operating in environments greater 6 rads - ( total inte dose) with no appreciable In addition, the # grated 3144 RTV reacts with water vapor in than - 102 x 10 deficiencies. the air to cure. Upon curi ng, the adhesive / sealant becomes resistant to humidity and-temperatures up to 482*F over long periods of time. The RTV N3144 sealant will effectively seal off fil environments from the under#ying Scotch Brand tapes and the splice l except for radiation.. The 3144 RTV is also not adversely affected by boric acid solutions in excess of 5%. e a 9 t =.,- w

ENCLOSURE 9 Containment Vent Fan Motor Splices (Continued) 4 -3) (Continued) Further evidence of Dow Corning #3144 RTV sealant / adhesive's ability to stand up to the adverse conditions of a LOCA is documented by the Fisher Controls Company valve actuator tests. In these tests, Dow Corning

1. 3144 adhesive / sealant was used to cover all bare terminations.

Resul ts of the tests provided evidence that throughout the simulated LOCA environment no termination covered with #3144 RTV was found to be shorted or damaged. Test parameters included temperatures in excess of 288'F, pressure in excess of 60 .psig, and a 100% saturated steam environment. No credit is taken for the Bishop 33 high voltage tape. G h g -r.,

? f 3y s e ATTACHMENT 6 e O h i f 8

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'I. I WYLE LAECRATCEE ENGINEERING SCIENTIFIC SERVICES & $YSTEMS GROUP wyi Repo,, No. ,c,,, i E. CORT 2e333-26 WE$ TERN CPERATIONS, NORCO FACILITY - 1841 HILLSIDE AVENUE, NORCO, CALIFORNIA 917M Wyle Job No. AREA CCCE 71&7274871 50843 Twx 9to-332.i:o4 rEtECCPY (714) 7374371 Customer P.O. No. Total Pcges this Report 25 June, 1982 Date: r ENVIRONMENTAL QUALIFICATION EVALUATION OF CABLE SPLICES f INSIDE CONTAINMENT FOR OMAHA PUBLIC POWER DISTRICT FOR USE IN FORT CALHOUN NUCLEAR GENERATING STATION, UNIT 1 i J 1h ( M. ?m PREPARED BY: / ,]., t VERIFIED BY:,<y S < e u o ->

1. e APPROVED BY:

Ekulu-CUAllTY ASSURANCE 40 M' 6 -n ~

26333-26 REPCRT NO. umanavenus sosec samncts a sysTrus onour 7 WESftRN oPERAT1oNS.NOACO FACluTY pace so - l . TABLE OF CONTENTS Page No. ~ 1.0 SCOPE................................................................ 3 1.1-Objective......................................................... 3 1.2 Applicable Qualification Standards,................................... 3 Specifications, and Documents l.3 Equi pm en t D escription.............................................. 4 1.4 Saf ety-Related Functions........................................... 4' 2.0 DEFINITION OF SERVICE CONDITIONS................................... 5 2.1 Normal Operating Conditions........................................ 5 2.2 FS A R DB E Conditio ns.............~................................. 5 3.0 AGING EV ALU ATION C RITERI A......................................... 6 3.1 Evaluation of Susceptibility to....................................... 6 Radiation Degradation 3.2-Evaluation of Susceptibility to....................................... 6 Time / Temperature Related Mechansims 4.0 EVALUATION S 4.1 Aging............................................................ S 4.2 Relative Humidit y Ef f ects......................................... 10 4.3 Desi gn Basis Even t................................................. 10 4.4 In-Containment Inspection.......................................... 15 4.5 Tes t S p e ci m e ns.................................................... 16 4.6 Evaluation S um mary................................................ I S 5.0 CO N C L U SION S........................................................ 19 REFERENCES..............................................................20 1 Figure ! Insulation of "E" Cable Connections................................. 22 Figure 2 Containment Temperatures Fo!!owing LOCA.......................... 23 Figure 3 Containment Pressure............................................. 24 Figure 4 SER Section 3.3, MSLB Temperature Curve........................... 25 Table 1 Ca ble D escri p tion................................................. 2 6 . g. Table 2 Cable Splice Identification......................................... 27 ( Table 3 A gi n g M a t ri x..................................................... 2 3 Table 4 Evaluation Sum mary o f............................................ 31 Cable Splices at Transmitters Table 5 Evaluation Sum m ar y of............................................ 32 Cable Splices at the 430 V Containment Vent Fan Motor Lead Wires Table 6 Evaluation Sum mary of............................................ 3 3 The 430 V Containment Vent Fan Motor ~ Splices at the Electrical Penetrations Table 7-Evaluation Sum mar y o f............................................ 3 4 Original Plant Cable Splices at Electrical Penetrations Table 8 Evaluation Sum mary o f............................................ 35 TMI Modification at Containment Penetrations Lead Wire Splices (Raychem WCSF-N) ~ - Table 9 Evaluation Sum m ary o f............................................ 3 6 Cable. Splices at Solenoid Valves [ mm. I-r Y

i-1 REPORT NO. i_ us scamesuvcisasysnuso ou, weSMN oPERAnoNS, NotCo FACluW i _f. -1.0 SCOPE l, This document was prepared by Wyle Laboratories for Omaha Public Power District (The District) for safety-related cable splices installed inside containment at Fort Calhoun Nuclear Generating Station, Unit 1. l.1 Objective . The purpose of this report is to present an environmental qualification evaluation in accordance with the requirements of IE Bulletin 79-01B, including an aging analysis of six types of cable splices for safety-related electrica) equipments inside containment. u 1.2 Applicable Qualification Standards, Specifications, and Documents O Wyle Laboratories Western Test and Engineering Quality Assurance Manual 380, dated June 1,1981 I O IE Bulletin No. 79-OlB, Enclosure 4, " Guidelines for Environmental Qualification of Class IE Electrical Equipment in Operating Reactors," January 14, 1930. O IE Supplement No. 2 to Bulletin 79-01B, " Environmental Qualification of Class IE Equipment," September 30,1980. i L I t. I I t i i L

't REPORT NO umanavomas scentwc saavcts a systtus cAwr g ' '{ WESTERN optaAftoNS.NoRCO FACluTY PAGE NO cI 1.0 SCOPE (CONTINUED) - i 1.3 Equipment Description I The subject equipment consists of the six types of cable splices listed below for six electrical cable size and multiple conductor combinations (Table 1). For details see Tables 2 and 3 and Figure 1. e.. \\ l 1) . Cable Splices at Transmitters /bi-r 2)- Cable Splices at the 430 V Containment Vent Fan Motor Lead Wires - k' 3) The 480 V Containment Vent Fan Motor Splices at the Electrical Penetrations 4) Original Plant Cable Splices at Electrical Penetrations 2 Ui-I 5) TM1 Modification at Containment Penetration Lead Wire Splices (Raychem WCSF-N) 6) Cable Splices at Solenoid Valves 1.4 Safety-Related Functions I . The specific safety-related functions of the cable splice components are described in the following paragraphs: O Cable Splice: provides the electrical paths for safety-related electrical circuits. O Insulation: provides the necessary electrical isolation to eliminate unwanted electrical paths. i l 0 Heat Shrink Tubing: provides a vapor and liquid (chemical) seal covering the L insulation of the cable and connectors. For certain splices, heat shrink tubing is also insulation. -f 0 RTV Silicone Rubber: provides a vapor and liquid (chemical) barrier over the heat shrink tubing of the able splice. 1 s. I _ ?, r

r -I^'t 26333-26 REPORT NO. l u.onmimes setec smess a sysnus oaou' 5 ')' wesream openAfloNSw NoRCO FACluTY pace so t-2.0 DEFINITION OF SERVICE CONDITIONS -{ The following environmental service conditions have been specified by the District 20,29, 30 Normal FSAR Design Basis Event (DBE*) r 1 0 Temperature 34F(29C) 305F(152C) Maximum " O 0 Relative Humidity 9015% 100 % 0 Pressure Atmospheric 60 Psig Maximum j Chemical Spray ' N/A Beric Acid Solution (2500 ppm 0 -I Boron) ~ O Radiation - 3.42 x 105 g 1.12 x 106 to 3.0 x 107 Rads,

gamma, depending on the location (see Table 3)+ + +

h i O Time: a) Transmitters Continuous Continuous .f. b) Solenoid Intermittent Note I c) Containment Intermittent Continuous Vent Fan d) Cable Continuous Continuous Temperature and pressure profiles are given in Figures 2 and 3 I i The DBE is a loss of coolant accident (LOCA). This is Main Steam Line Break (MSLB) temcerature, used in lieu of lower ++ 233F LOCA temperature per SER Section 3.3 Response 30, This is the total calculated integrated dose for 40 years plus accident 23, NOTEI After the first few seconds into a DBE situation, all the solenoids in l, containment move to their fail positions with the exception of the following:_ ^ The Long Term Core Cooling Solenoids (233,239, 240) are required to operate in a DBE situation. The Reactor Coolant Solenoid (HCV-433 A & C) moves to its fail position which is the open position, and is driven closed in a DBE. I t. The Auxiliary Feedwater (HCV-Il07A, !!OSA) move to their fait position which is their open position, and are driven closed in a DBE. Charcoal Spray may operate intermittently in a DBE, HCV-864, S65. Purge system, HCV-331 and 332. move to their f ait position which is their'open 1' position and are driven closed in a DBE. 3 i

(. REPORT NO. u.anarona ser,a,c ss=cas a sysnus caou, wasmN OPERATloNS,NoRCO FACluTY ,,q, go 3.0 AGING EVALUATION CRITERIA The following sequence of steps were used to evaluate the non-metallic materials in each ( splice with respect to thei; safety-related functions under normal and Design Basis Event (DBE) conditons. ) 3.1 Evaluation of Susceptibility to Radiation Degradation The approach for evaluating the components for_ their radiation resistance is a "aur step process: 1. Review the individual materials of construction as provided on the contract specific materials list. I-2. Research Wyle Laboratories Aging Library for information on threshold levels, severe damage levels, degradation characteristics, and failure criteria. t i 3. List threshold level for radiation damage in the aging matrix. 4. Evaluate the item based on potential degradation and ability to perform its design f function af ter exposure to the specified radiation dose. it is generally recognized that metallic and inorganic materials are immune to radiation g degradation at the specified dose, hence, the evaluation is focusca on the non-metallic f. (organic) materials. 3.2 Evaluation of Susceptibility to Time / Temperature Related Mechanisms l' Deterioration due to thermal aging is insignificant for metallic and inorganic materials under the specified environmental conditions. Therefore, component aging is based on the non-metallic (organic) materials. For many organic materidis, it is known that the degradation process can be defined by a single temperature-dependent reaction that follows the Arrhenius equation: I A exp (-(Ea/kb T)) (1) k =

where, i

k = reaction rate frequency factor A = exponent to base e exp = activation energy (eV) Ea = Boltzmann's Constant (3.617 x 10-5 eV/0K) kb = absolute temperature (OK) T = t s 6 .4 .L

4 T REPOR? NO. LAmona,osuas scitsstwc stRwitts & SYSTthas Gnoup w:sunw ortaAnows.nonco rActun 7 { 3.0 AGING EVALUATION CRITERIA (CONTINUED) 3.2 Evaluation of Susceptibility to Time / Temperature Related Mechanisms (Cont'd) r' It is further noted that, for many reactions, the activation energy can be considered to be constant over the applicable temperature range. Equation (1) can be transformed into a slope-intercept form of a linear equation which yields the expected life: (Ea/k ) (1/T) + Constant (2) In (life) = B r Since the materials follow an Arrhenius relationship, the requirement at one time and (* temperature can be transferred to another set of time / temperature coordinates using the relationship f t1 = t2 exp ((Ea/kg)(1/T - 1/T )) (3) 1 2

where, t[ = Calculated life at temperature Tt t2 = Expected life at T (Equation 2)-120 2

T1 = Accident temperature (max) / T2 = Normal service temperature When the expected life obtaineo from equation (2) at the normal service temperature (34F) } exceeds the specified service life (40 years) by a conservative factor of three, equation (3) is used to calculate the equivalent life at the accident temperature from the expected life t minus 120 years. The factor of three is used for conservatism to account for uncertainties such as variations in the postulated temperatures and durations. This will demonstrate life in excess of the normal service condition (conservatively estimated to be 120 years) and provide a mechanism for comparing the remaining life of a material at the accident temperature with the postulated accident duration. y For example for Polyolefin, with a degradation parameter of 36% loss of electrical i strength (Table 3, item No.1): Normal calculated life = exp ((Ea/k )(1/T) + (Intercept)) B { where, Ea = 0.36 eV Intercept = -15.04707 s i For a baseline temperature of 84F (29C)(normal service condition) I ' T = 29C + 273 = 302K f life = exp ((9980.2716)(1/302)- 15.04707) 7 life = 6.56 x 10 hours (7,496 y, ears) 1 ~ ) I

t-li M REPORT NO. LAeoftAf0futS $CIENTIFIC $4fMCES & $Y$7tMS GAQup 3 7 westenN oPeRADoNs,NORCO FAClurr { 3.0 AGING EVALUATION CRITERIA (CONTINUED) ( 3.2 Evaluation of Susceptibility to Time / Temperature Related Mechanisms (Cont'd) 't Then 7,496 years - 120 years = 7,376 years \\q For an accident temperature of 30$F (152C)(accident service condition) t2 exP ((slope)(1/T - 1/T )) r-t1 t 2 = t equivalent calculated accident life at 305F t1 = 7,376 years t2 = T1 152C + 273 = 425K = i { T2 = 29C + 273 = 302K then ,i ' tt (7,376 years x 365 days / year) exp ((9980.2716)(1/425 - 1/362)) = i 139 days tt = Based on the above calculation, it is demonstrateo: a) Calculated normallife of 120 years at 34F (29C) i b) Calculated accident life of 139 days at 30$F (152C)in addition to 120 years normal t life. j If the calculated life at the normal operating temperature does not exceed the service life t (40 years) by a multiple of 3, then a case by case analysis will be carried out. q. c I ~l 9 1 -i

e~ 26333-26 M @@S REPORT NO. SCIENTIFIC SERVICES & SYSTEMS group g [ WESTERN OPERATIONS, NoRCo FACIUTY PAGI NO I [ 4.0 EVALUATION 4.1 Aging An aging analysis was done to determine the susceptibility to time / temperature and I radiation related mechanisms. ( Damage levels and calculated lives for normal operation and DBE conditions were determined solely on the individual effects of radiation and time / temperature related mechanisms. r { Contract specific materials lists were provided by The District for the purpose of evaluation. j 4.1.1 TIME / TEMPERATURE EFFECTS The Aging Matrix (Table 3) contains a list of the non-metallic materials used in each splice, the data used in this evaluation, and the calculated lives (normal and accident) for each of the splices. A review' of calculated lives, normal and accident, (Table 3) indicates insignificant thermal aging at the specified normai and accident environmental temperatures. ,. Certainly, calculated expected life is only a theoretical life, but it cemonstrates that each material will have a qualified life, for a normal service, of greater than 40 years, y plus accident and post accident life. 4.1.2 RADIATION EFFECTS ~ 4.1.2.1 Gamma Radiation Effects The threshold levels for radiation induced damage were determined per section 3.1. The radiation threshold level of each material was compared to the required dose specified in ( Table 3. Where the radiation threshold level of a material is greater than the required dose by a margin of +25%, or test data exists where test conditions envelop the required dose, the effects of radiation exposure were judged to be insignificant. A review of Table 3 indicates insignificant radiation aging. 4.1.2.2 Beta Radiation Effects The following analysis is based on the methodology presented in the DOR Guidelines. I s f i ) h

1 MO REPORT NO. ~ sc ENTIFIC SERVICES & SYSTEMS CRcuP 10 -) WESTERN OPERATIONS, NoRCo FACIUTY PAGE NO k. 4.0 EVALUATION (CONTINilFN [ 4.1 Aging (Cont'd) (' 4.1.2.2 Beta Radiation Effects (Cont'd) k The beta dose is reduced by a factor of ten within 30 mits of the surface of ciectrical cable insulation. An additional 40 mils (for a total of 70 mils) results in another factor of ten reduction in dose. Any structures or other equipment in the vicinity of the equipment { of interest would act as shielding to further reduce beta doses. If the plant specific beta radiation dose is not available, the generic dose of 2 x 108 rads could be used. t It can be shown, by assuming a conservative unshielded surf ace beta dose of 2.0 x 108 rads and considering the shielding factors discussed above, that the beta dose to radiation i sensitive equipment internals would be less than or equal to 10% of the total gamma dose to which an item of equipment has been qualified. Then that equipment may be considered qualified for the total radiation environment (gamma plus beta), if this criterion is not satisfied the radiation service condition should be determined by the sum ~ of the gamma and beta doses. 4.1.2.2.1 Cable Splices at Transmitters ? These cables splices are located inside conduits which shield them from beta radiation. Therefore, the effects of beta radiation would be insignificant. 4.1.2.2.2 Cable Splices at the 480 V Containment Vent Fan Motor Lead Wires. These cable $plices are located inside terminal boxes 20 and covered with RTV 3145 which f i shield them from beta radiation. Therefore, the effects of beta radiation would be insignificant. 4.1.2.2.3 The 430V Containment Vent Fan Motor Lead Splices _ at the Electrical Penetration These cable splices are exempted from the effect of beta radiation because of the R.T.V. covering. Since the R.T.V is about 1/8 inch thick 2 (125 mils), the beta dose is reduced by a f actor of 1000. The beta dose is then 2 x 105 rads. This beta dose is less than ten percent of the gamma dose and the effects of beta radiation are considered insignificant. 4.1.2.2.4 Original Plant Cable Splices at Electrical Penetrations The effects of beta radiation are considered insignificant due to the RTV coating as in l 4.1.2.2.3. 6 t f 1 h

e J REPORT NO. -x=. scwe smens a sysnus ow ii f WESTERN oPERAT1oNS, NoRCO FACluTY Pact No ] []- 4.0 EVALUATION (CONTINUED) 4.1.2.2.5 TMI Atodification at Containment Penetration Lead Wire Splices (Raychem c f WCSF-N) The effects of beta radiation are considered insignificant because this cable splice was 3 tested to gamma radiation of 2.0 x 10 (Ref. 3), which is greater than the total integrated k. gamma plus beta dose. 4.1.2.2.6 Cable Splices at Solenoid Valves These cable splices are located inside condulets20 which shield them from beta radiation. Therefore, the effects of beta radiation would be insignificant. 7 s 4.2 Relative Humidity Effects Relative humidity is not considered a significant aging mechanism for the subject splices. For insulation systems, humidity is usually not the primary failure mechanism. As noted in Reference 25, with respect to motor insulations, "In most cases, moisture plays only a ( secondary role in the failure. It does not produce the damage in the insulation. The insulation wears away or cracks for other reasons. Moisture merely provides a direct electrical pathway between these matured devices and ground." Therefore, effect of humidity was considered insignificant for this application. In addition to the above it is judged that the combinat:en of high temperature / pressure steam and chemical spray is a more severe environment than 100% relative humidity. { Original Plant Cable Splices at the Electrical Penetrations and TMI Modification at o' Containment Penetration Lead Wire Splices (Raychem WCSF-N) were subjected, without failure, to a LOCA test (high temperature / pressure steam) with chemical spray ( environments..Therefore, immunity to relative humidity 'was demonstrated by more

f..

severe test conditions. g For the Cable Splices at the Transmitters, Cable Splices at the 480 V Containment Vent i Fan Motor Lead Wires and the 480 V Containment Vent Fan Motor Splices at th9 Electrical Penetrations, the RTV coating provides an excellent seat over the splice thus causing the effects of humidity to be insignificant. 3 The splices at Solenoid Valves are doub'c Pentube heat shrink tubing and are located inside a condulet system 20 There! te, the effects of humidity are considered insignificant. } i = 6

- fI I g ggS REPORT NO. 2b333~2b SCIENTiflC $ERVICES & $Y$TEMS GROUP WESTERN OPERATIONS, NoRCO FACluTY PAGE NO {. 4.0 EVALUATION (CONTINUED) 4.3_ Design Basis Event (DBE) The DBE is a Loss of Coolant Accident (LOCA). Each splice was evaluated for the following LOCA environments: t-1. Thermal Aging i -f. 2. Radiation Aging 3. Temperature j ^1 4. Pressure 5. Chemical Spray t \\ a~ 6. Relative Humidity j 7. _ Submergence A summary of these evaluations is given in Tables 4 through 9. ) 4.3.i THERMAL AGING Based on the evaluation presented in Section 4.1, the effects of thermal aging during a LOCA are insignificant. i 0.3.2 RADIATION AGING r t. Each cable splice was evaluated for the total integrat.ed dose plus accident (LOCA), Section 4.1.2. l i Based on the evaluation presented in section 4.1.2, the effects of radiation aging during a LOCA are insignificant. l TMI modification at Containment Penetration Lead Wire Splices (Raychem_ WCSF-N), and Original Plant Cable Splices at Electrical Penetrations interface with teflon insulated cables. The effects of 1.12 x 106 -(Table 3) and 1.36 x 107 (Table 7) rads gamma respective because the Raychem test 3 and Franklin . Institute (l)ly on teflon must be addressed by test ~ tests were conducted without teflon insulated cables. Because of the high radiation level, a test, in lieu of analysis, must be used to demonstrate qualification of the interface. t I

2b3N-2b M LAECRATCfDE REPORT NO. SCIENTIFIC SERVICES & SYSTEMS G2ouP g3 WESTERN CPERAftoNs, NoRCo FACluTY PAGE NO N [ 4.0 EVALUATION (CONTINUED) ~ t 4.3 Design Basis Event (DBE) (Cont'd) f 4.3.3 TEMPERATURE Figure 4 shows the SER Section 3.3 response 305F temperature profile. The shaded area f is the MSLB 305F temperature profile, in excess of peak LOCA temperature. The f estimated duration of this hypothetical condition will not be greater than 5 minutes. A review of calculated lives for the materials used in each type of cable splice showed 7 ) that each Individual material is capable of withstanding 305F far longer than 5 minutes as shown in Table 3. } 4.3.3.1 Cable Solices at Transmitters i As indicated in Section 4.3.5.1, these splices are covered with a LOCA qualified Dow Corning 3145 RTV adhesive / sealant". This RTV has good dielectric procerties over a wide } temperature range and will withstand long term exposure at 432F (250C)27, The sealant will also withstand steam (to 200C) a.id has withstood a 100,000 hour aging ) test at 200C". Dow Corning has reported " Steam at 245F could, in time, sof ten Dow Corning 3145, but 20 minutes would be considered a minor exposure"4 Because the exposure to high temperature is for only a short time, there should be no adverse effects t on the Dow Corning 3145 RTV. ~ 4.3.3.2 Cable Splices at the 480V Containment Vent Fan \\1otor Lead Wires h Dow Corning 3144 RTV adhesive / sealant's ability to stand up to the adverse conditions of 7 a LOCA is documented by the Fisher Controls Company valve actuator tests. Test parameters included temperatures in excess of 233F, pressure in excess of 60 psig, and a 100% saturated steam environment. I Furthermore,3144 RTV will withstand long term exposure at 250C (432F)27, ~ it is concluded that the short time exposure at high temperature will not have an adverse, effect on this splice. 4.3.3.3 The 480V Containment Vent Fan. Motor Lead Solices at the Electrical [ Penetrations This cable splice will withstand the short time exposure of 30$F per analysis presented in l section 4.3.3.1 above. l_ P ts s

ur !~ 26333-26 M LABCRATCfBE nercar no. SCIENTIFIC SERVICES & systems group WESTERN OPERATIONS, NoRCo FACIUTY PAGE NO I 4.0 EVALUATION (CONTINUED) i 4.3 Design Basis Event (DBE) (Cont'd) 4.3.3.4 Oricinal Plant Cable Solices at Electrical Penetrations Figure 4 includes the Franklin Test estimated average temperature of 297F. The 17F-7 l ' increase (305F-233F) over the calculated LOCA temperature curve is plotted as the SER Section 3.3 MSLB Temperature Curve. By inspection, it can be seen that the amount of heat added during testing was significantly greater than that required by the hypothetical - [ SER Section 3.3, MSLB Temperature Curve (LOCA curve plus 17F). Note the logrithmatic scale and that Area B is a major increase over Area A. Therefore, the Franklin Tests are judged to be conservative compared to the DBE temperature profile with its 30$F imposed paak temperature. Some test temperatures reached 302F while others were as low as 295F. This represents a range of undershoot from 3 to 3 degrees. Since the SER Section 3.3, use of 30$F was j established for the upper regions of the containment, and the electrical penetation splices are in the.ower-middle elevations, the 3 to 3 degree dif ference for about 52 seconds can be taken into account by establishing the materials capability to withstand higher temperatures. The material evaluation in Section 4.3.1 and 4.3.3.1 shows the capability to withstand 305F temperatures so materials in the splice should withstand a shcrt exposure at 30$F. 1 t. 4.3.3.5 TMI Modification at Containment Penetration Lead Wire Solices (Raychem WCSF-N) These splices have been tested to temperatures up to 390F which exceeds the required 3 ^ temperature by 35F. } 4.3.3.6 Cable Solices at Solenoid Valves t.. The material evaluation in Section 4.3.1 and 4.3.3.1 shows the capability to withstand 305F temperatures so materials in the splice should withstand a short exposure at 30$F. t ~ 4.3.4 PRESSURE ? J No accident pressure test data exists for the cables splices listed below: a) Cable Splices at Transmitters b) Cables Splices at the 430V Containment Vent Fan Motor Lead Tires c) The 430V Containment Vent Fan Motor Splices at the Electrical Penetrations d) -. Cables Splices at Solenoid Valves \\ 1 ib r

I M REPOR7 NO. sCIENilHC sERVICfS & SYSTEMS GRoVP gy WESTERN CPERATioNs, NoRCo FACluTY PAGE NO .f f 4.0 EVALUATION (CONTINUED) 4.3 Design Basis Event (DBE) (Cont'd) ? 1 4.3.4 PRESSURE (Cont'd) The effects of pressure are significant when chemical spray is present to cause shorting of j the conductors due to voids or poor adhesive properties of the splice. The splice t construction technique should minimize the possibility of voids. RTV alone exhibits excellent adhesive properties,7, 4 ? ) Original plant Cable Splices at E!cctrical Penetrations and TMI Modification at Containment Penetration Lead Wire Splices have been tested for a LOCA condition with a pressure equal or greater than 60 psig 3 l } 4.3.5 CHEMICAL SPRAY 4.3.5.1 Cable Solices at Transmitters 4 These splices are potted with Dow Corning RTV 3145 adhesive / sealant. The sealant will withstand steam up to 392F (200C), and chemical spray for the DBE conditions specified ) in section 2.2. 1 Each cable splice is sealed in a condulet which prevents chemical spray from getting to the splices 20, A chemical spray environment during a LOCA should be insignificant. 4.3.5.2 Cable Splices at the 4SOV Containment Vent Fan Motor Lead Wires i These splices are covered with Dow Corning RTV 3144 adhesive / sealant. Due to the RTV sealant, the splice system will not be subjected to chemical spray during a LOCA (Ref. 7). The RTV 3144 sealant will effectively seal off all environments from the underlying Scotch brand tapes and the splice, except for radiation. The RTV 3144 also is not adversely affected by boric acid solutions in excess of 5%. 7 These splices are contained within a sealed NEMA conduit and terminal box system 20, i The physical layout of the conduit is such that chemical spray would have to travel ?_ against the direction of gravity inside the conduit to reach the splices during the 2 to 3 hours operating time requirement 20, The effects of a chemical spray environment during a 2 to 3 hour LOCA should be insignificant. e

==- " ee i

l .I 26333-26 REPORT WO. setstwc sanvers a sysitus caour gg I WESTERN oPERATloN5.NotCo FACluTY paca no i s - 4.0 EVALUATION (CONTINUED) 4.3.3.3 The 480V Containment Vent Fan Motor Solices at the Electrical Penetrations These splices use G.E. RTV silicone to seal the final end tabs of the Irrasil tape. A layer of Scotch P33 tape is installed over the entire splice. An investigation of this splice .} indicates that its composition would allow it to withstand the effects of chemical spray 5 during a LOCA, s The SPT has an outstanding resistance to steam and hot water 5 It also has excellent f resistance to acids. The silicone tape and RTV both exhibit good, high-temperature characteristics and chemical resistance. [ To insure operability of the splice, the splices are coated with Dow Corning RTV 3145 4 i adhesive / sealant. This mitigates the chemical spray from attacking the splice. Therefore, the effects of chemical spray environment during a 2 to 3 hour LOCA should be insignificant. 4.3.5.4 Oricinal Plant Cable Solices at Electrical Penetrations The effects of chemical spray environment during the LOCA should be insignificant per i Section 4.3.5.1 above. ( 4.3.5.5 TMI Modification at Containment Penetration Lead Wire Solices (Ravchem WCSF-N) 3 These splices are LOCA qualified per Tyle Report No. 53442-1. The tested chemical spray consisted of 6200 ppm of boron, 50 ppm of hydrazine buffered to a pH of 10.5 with trisodium phosphate. .i The test conditions far exceed the required plant conditions specified in Section 2.2. 4.3.5.6 Cable Solices at Solenoid Valves ? These cable splices are covered with double heatshrink tubing and are contained within a sealed NEMA condulet and conduit system 20 The physical layout of the conduit is such i that chemical spray would have to travel against the direction of gravity inside a conduit L to reach the splices during the LOCA which prevents chemical spray from getting to the splice. 4.3.6 RELATIVE HUMIDITY Based on the evaluation presented in Section 4.2, the effects of relative humidity during a j-LOCA are insignificant. l s 1

J-2b f M MMS REPCRT NO. l sCIENilFIC SERVICES & SYSTEMS GROUP g7 ' WESTERN oPERAnoNS, NoRCo FACluTY PAGE NO { f-4.0 EVALUATION (CONTINUED) 4.3.7 SUBMERGENCE - )" As reported by The District, the cable splices are above flood level (SCEW Sheets p. 5-49 through 5-52), therefore no effects of submergence are considered in this report. ]. 4.4 In-Containment Inspection On November 5 and 6, !?31, an inspection of splices was performed for the purpose of the g ( "as constructed" splices at Fort Calhoun3 The District's Licensing Action Log, Item 00266, commitment to perform the inspection during the 1931 refueling outage was completed.' The significant results of the District's and Wyle's in-containment inspection ) are as follows: Original Plant Cable Solices at Electrical Penetration i ( The inspection of a splice after disassembly verified that the pertinent design data of the "as constructed" equipment conforms to document FSK-E-329, Sheet 3, the Fort Calhoun Construction Inspection Data Report (CIDR) of 1973 and the test specimen description of Test Report F-C3343. The pertinent design data which was selected to verify the 3 f-assumptions of Wyle Preliminary Report9 include, but are not limited to the following: 1. Double heat shrink tubing over butt splice 2. Drain wire has boot and associated splice in double heat shrink 3. Relative spacing betwe. 9 butt splices 4. Materials i a. RTV b. GE Irrathene c. Scotch 33 tL in addition, subsequent discussions with the District's Field Maintenance Electricians on November 5,1931, pointed out that the materials of items 4a, b, c, were recognizabic and f identifiable as the proper materials. These District personnel participated in construction , [ and start up of Fort Calhoun. The first purpose of the cable splice disassembly was to ensure continued plant operation ) by demonstrating that assumptions 2,3,4, and 5 of Reference 9 regarding the penetration lead wires were met. Specifically, the "as constructec" penetration ! cad wire splices were 4 similar to those used in the April,1972 Franklin Institute Test, Report F-C3343, by having two layers of heat shrink over each butt splice in lieu of one layer (including the drain b wire), and the drain wire had a boot of heat shrink over it. The second purpose was to gather sufficient data to assist in the evaluation / verification of the cable splice similarity analysis (tested specimens versus installed splices) of assumption 1 of Reference 9. 8 s \\, =

} bN REPORT NO. SCIENTIFIC SERVICES & SYSTEMS GROUP 3 .j - WESTERN OPERATIONS, NoRCo FAClu1Y PAGE No s ( ; I 4.0 EVALUATION (CONTINUED) ') 4.5 Test Specimens Similarity Evaluation ? ) Industry experience regarding cable splice qualification, suggests that the multiconductor cable splice is the limiting case. The sealing or pressure boundary function of keeping liquid / chemical spray out of the conductor area is more difficult to obtain for a multiconductor splice than for a single conductor,or lesser number of conductors splice. 4.6 Evaluation Summary e { See Tables 4 through 9 for details. Effects of LOCA environment are considered negligible for Cable Splices at the Solenoid Valves for a one minute LOCA operating time requirement. However, the District must take exception to the one hour margin criterion of the DOR Guideline. Otherwise a test or replacement must be considered. Material analysis shows no adverse effects. Also, the solenoids fail in a safe position. According!/, continued plant operation is justified, and if I the one hour criterion with the requirement for accident test data is envoked, then a test or replacement program must be considered. j For the Cable Splice at the Transmitter taking into account the single heat shrink tube potted with RTV inside an enclosed condulet, the LOCA operational time requirement of 1000 hours and the material analysis shows no adverse effects. Continued plant operation is justified. As no accident test data is available, a test or replacement program must be / considered. TMI Modification at Containment Penetration Lead Wire Splices, Raychem WCSF-N, meet { IEEE-323-1974. The Original Plant Cable Splices at Electrical Penetrations meet the DOR Guidelines by a combination test and analysis. However, because neither was tested with Teflon insulated cable, a test program is needed to demonstrate qualification for the Teflon interface at the levels indicated in Tables 7 and 3. k Cable Splices at the 430V Containment Vent Fan Motor Lead Wires and the 430V Containment Vent Fan Motor Splices at the Electrical Penetrations evaluation shows good f. use of RTV to seal the splices. The material analysis shows that the individual splice components have no adverse effects from normal and accident conditions and continued plant operation is justified. As no accident test data exists, a test plan or replacement is v needed. e V er k

REPORT NO. u aamans senwcsams:asyswscaour wasrumsopenAnows.nonco rAciury ga ,,,, so e (

5.0 CONCLUSION

S 1. Based upon the inspection at Fort Calhoun and the engineering evaluation done to [ date, it has-been determined that insufficient accident test data is available to D-support full qualification in strict accordance with DOR Guidelines of IE Bulletin 79-01B for the cable splices listed below. The specific deficiency is lack of accident test data on the splice. a) Cable Splices at the 480V Containment Vent Fan Motor Lead Wires (LER 30-007) / b) The 430V Containment Vent Fan Motor Splices at the Electrical Penetrations (LER 30-007) c) Cable Splices at Solenoid Valves except for HCV-238,239, and 240) d) Cable Splices at Transmitters (LER 30-006) As presented in Section 4.0 above, from an engineering and analysis point of view, the above splices are capable of safe operation before, during, and af ter a LOCA for the time period required to operate. Therefore continued operation is justified. 2. Original Plant Cable Splices at containment penetration using original plant doubl heat shrink splices tested per April,1972 Franklin Institute Test Report F-C3343y are qualified except for interface with teflon insulated cable which must be tested. 3. Containment penetration lead wire splices using Raychem splices are qualified per \\ May,1980, Wyle Test Report No. 53442-1, except for the interface with Teflon 3 b insulated cable which must be tested. i 9 ) a 9 6

~ NE Mb REPORT NO. SCitNTIFIC MtViCEs & sY3TENL5 CROUP 20 PAGE NO . W(STERN oPEEAftoN1, NoiiCO FANTY REFERENCES 1. Qua'i'ication Tests of Cable Splices Under Simulated Reactor Containment Service Condit!cns, Franklin Institute Final Report F-C3343, dated April 1972. t. ~ 2. Fort Calhoun File No. FC-643-80, dated 6 June,1930. b 3. 1:.avironmental Qualification Test Repert of Raychem WCSF-N nuclear in-line cable ' splice assemblies for Raychem Corporation, Alento Park, California, Wyle Report No. 33447-1, dated 15 Atay,1980. 4. Dow Corning Wer dated Alarch 24, 1930;.

Subject:

Dow Corning 3145 RTV and I adhesive / sealant integrity. ) 5. LER 30-007, Fort Calhoun Station, Unit 1, Docket No. 05000235, attachment No.1. 6. Standard Handbook for Electrical Engineers, Tenth Edition. t

7., Containment Fan Cooler A1oter Splices. Omaha Public Power District,

~ Fort Calhoun Station, Unit 1, Electrical Equipments Evaluation Report. I 3. Wyle Quality inspection Record by E.3. Gerlof f; subject: Penetration Splice, dated November 11,1931. i 9. Wyle Report, 26333-02; subject: ' Preliminary Assessment Report on Cable Splices l i Inside Containment for Fort Calhoun Station, Unit 1, dated January 29,1931. ' ' 10., Ataterial Analysis of Containment Penetration Cable Splices for . Radiation Effects. for Fort Calhoun Station, Unit 1, Electrical Equipments i Evaluation Report. [ 11. Fort Calhoun Station, Unit 1, File No. ! ! 405-E-150, 151, Cable and Conduit Schedule, Fort Calhoun. e 12. "Raychem Flamtrol-Qualification to IEEE Standard 333," Library Code 231-30A I 13. " Report on the Effect of Radiation on Electrical Insulating Alaterials," C. L. Hanks and D. 3. Hamman, REIC Report No. 46, June,1969, Battelle Atemorial Institute, Library Code 299-80 14 " Thermal Aging Program for U.L. Recognition," T. C. Hampton, Dow Corning, Library Code 465-31 j.. "The Effect of Nuclear Radiation on Elastomeric and Plastic Staterials," R. W. ~ 15. King, et. al., Battelle Radiation Effects Center, REIC Report No. 21, September 1, j 1961, Library Code 286-30 16. Thermal Life Data for CC 2115, 2116 Silicone Rubber Wire Insulation, Continental e Wire and Cable Company, June 30,1973, Lbirary Code 387-SOA I-

~ \\ l k M.a r sc..a csweisasnm caou, REPORT NO. u {- 6 oPERAN M FAduIv PAGt NO L I REFERENCES (CONTINUED) 17. Varflex Corporation U.L. File No. E63450 (Varflo Sleeving), January 17, 1979, Library Code 446-31. 13. " Wires and Cords for Original Equipment Manufacturers," General Electric Company, No. WCC-;, Library Code 135-79A ti. 19. "Raychem Corporation WCSF Thermal Aging Data," EDR-2001, Library Code 360-30 20. Omaha Public Power District, letter dated March 2,1982.

Subject:

Operational f' - time requirement of Safety Related Equipment inside Containment; NEMA rating of Condulets at Pressure Transmitter and Solenoids and Terminal Box at Containment Vent Fan Motor, and Composition of Chemical Spray. L 21. Radiation Resistance of Bishop Materials, Physical and Electrical Properties for Bishop P3 tape provided by George Foote, Manager, inside Sales. Bishop Electric, Cedar Grove, NJ. 22. " Wires and Cords for Electrical Appliance and Equipment Manuf acturers", General' Electric Company, Library Code 135-79A. e 23. " Insulations and Jackets for Control and Power Cables in Thermal Reactor Nuclear Generating Stations," Robert B. Blodgett and Robert G. Fisher, IEEE Transactions j en Power Aoparatus and Systems, Vol. PAS-33, No. 5, May,1969, Library Cod ? 22t-79A 24. Fort Calhoun File No. FC-765-2617, dated May 13,1972, " Insulation of "E" Cabl+ { Connection", Drawing No. XA-545-E462. 25. Industrial Motor Users Handbook of Insulation for Rewinds, L.J. Rejda and Kris Neville, Elsevier,1977, Wyle Library Code 253-30. 26. Telecon of S. Charakhanian, Wyle Laboratories, Norco, Ca., and George Congdon (Inside Sales), Dow Corning Corporation, Midland, Michigan, January 14, 1932. (

Subject:

RTV 3144, 27. Information about Silicone Elastomers, 3145 RTV, Dow Corning Corporation, Form [ No. 61-34913-30. ~

23. 1, Expected Radiation Dose Levels In-Containment Omaha Public Power District, Fort Calhoun Station, Unit 1, Electrical Equipments Evaluation Report.

~ 29. Telecon of Jim Thompson, Wyle Laboratories, Norco, Ca., and Mike Capella, Omaha Public Power District, Omaha, Nebraska, April 21, 1932.

Subject:

Containment Temperatures for Fort Calhoun Nuclear Generating Station, Unit 1. 30. Omaha Public Power Districts Fort Calhoun Station, Unit 1, Electrical Equipment } Qualification Report, SER Section 3.4, Enclosure 1, Enclosure 6 (pages 6-49 through ( 6-52) and Enclosure 12. i u

M M ESS REPCRT NO. $CitNilFICittvlCt1 & SYSTEM 3 GROUP 22 PAGR No { WisitRN CPERAflCN$, NCRCO FACluTY k' h L EllCTRICAl. PLl!CTPATICH CAHISTt'R WADS Or IRRAfttleil $PT TATE e STEEL. JAC*ET h POLTSUt t'OHE Il4506 ATION t 'a

• I D P A SII. SII ICD'8E Pl8tl#IR T AIE f

e.a 't TftAH04.0 CotN41CTOM i L b .} d s \\ {l /, 77; ~ (.,/ 'jdyf):th.hih'l['E ~ - "'" M jf ~ (JIf)f r. -~ I . i... ,. i... 3 titz inst -COHlat't; Toft he Ol'lis'isE J AO6 r ovt n *II t; ll4SHf A t f ul ( Aus t l'k Ht:1ttAf ts et 4:teden.1His R.T.V. 134$ tB"trd INSUI ATIOtt Of "E' CAttl E C0tatst:CTlf fl1 e '[ rem b COtiTAltatti147 VI ti? FAH ? i FIGUltF. l' INSULATION OF "E" C ABLE CONNECTIONS f

• Reference 24 e

d ) m

a f. ~ Rt90R1 NO. [; scentinc saavices a systtuscaovP 23 l WelftRN opt #AriCNS. N0aCO FAcititY PAGt Peo r i , l i

• I I s

t 1 l i }" l l' l 3 4 I, 5 I I 3 I I I4) IIg I I i5 I I IIl F 4 4 5 8 4 I I ) p, f~~ CONTAINMENT PRESSURE 50-l r

30C, i.*

/ l / i F i 's I CONTAINMENT ATMOSPilERE G f l ,I 2 s T EMi'E AAEURE gi 40 l S / s\\ v .i 1 s n g it / SUHP WATER TEMPERATURE i t j;8 - : j 's iTI ,h / s b / \\ }[ 30- / \\ i \\ f \\ 200 '* / \\ f \\ l

/

\\ ,o.; s\\ N i { \\ l 32'000lM.E ENDEO OREAN,MlHIMUM SAFETY lilJECTlott g N l 3 SPAAY PUMPS,1 SFAAY llEADER. g* s 10 - N l s . i i ss '., j ./ isinal i i i n il i i s i n al { 100 - ' i i i i i e e i 10 10 0 1000 l TIME (SEE0005) ~ 1 FIGURP. 2 1 CONTAINMENT TEMPERATURES FOLLOWING LOCA l I l 3, / I w l t t

I 4i

• • M M LAECRATCIUS nEroni No.

SCIENilHC $ERVICES & $Y$TEMS GROUP 3 WESTERN OPERATIONS. NCRCO FACILITY PAGE NO i v. ,f i ... iiig ....ig ,o l ff ~ [ m 1 { t I. i -12 40 r. v I E 1 a = i " 30 N Q @ 32"StlGt.E Ef10E0 CREAK,140 SAFETY ' lilJECT10tl, 3 SPilAY PUMPS,1 SPRAY ltE ADER - 'y @ 24" SelGLE EtiOED PHEAX, f40 SAFETY .l N g8 edJECTIOti, 3 ' SPA AY PtJMPS. l SPAAt lie ADER g { @ la" SelGLE Et40E0 BREAK, #40 SAFETY tilJECTlott, 3 SPHAY PUMPS, i SPH AY llEADER - ~ @t2"SitlGLE Ett0ED of EAH, tMi SAFETY tilJECTiota 3 SPhAy PuuPS, i SPli AY llEADER - ~~ 7 . s ~ { s I I I I III ~l I I I III I l I l I IiI F 0. b .0 gix) gJOO TruE(SEcot:Os) - L FIGURE 3 ~. CONTAINMENT PRESSURE i ~ l .M e.

n k.'

". W L '_.2.

l. MO REPORT NO. ~' $CitNilFIC SERVICt1 & $YSTE.%$ GROUP y g WESTERN CPERATIONS. NCRCO FACiUTY PAGI M3 ) f i-FranklinInstituteTe,st SER Section 3.3 Averaoe Test Tercerature ftSLB Temnerature Curve Dwell 207F For 100 Minutes or 6.000 Seconds g,@;9:-M M~~._'JLAliJMEtJT PRESSURE 30C' BM?^ ' =w-...8c. 59 / ^% N ,l / / s s. 5. f 9 5 ).l COtJhti4MEllT ATMOSPHERE 1 -} g ' % p /. s g 40q. TEMPERATQRE s / g / s s.. s .v / N N i. I.$. : / l 's \\. l: \\ \\ m n / \\ \\. l,jj 3 : / ARE A A C g \\ er 1 6.- / \\-g A f, / AREA B Q \\ \\ 200 - / - / l \\ N. / \\ i -r N ~ \\ N s \\ ) } 32' DOUBLE EtJDED BREAK,MitJUAUM SAFETY !!1 JECT! Oil g N 3 SPRAY PUMPS,1 SPRAY HEADER. N l ~ s 10 - i s \\ g 52 Seconds-- s t 's \\ s ~- [ 100 ' ' iieil e , i ,,,,l f,_ TIME (SEC0tJDS) l ,,f000 10 10 0 I- \\. FIGURE 4 SER SECTION 3.3 MSLB TEMPERATURE CURVE I 1 1 D - ens L_.

I NM-N ~ ' M LABCRA M E neecar no. SCIENTIFIC SERVICES a SYSTEMS group 26 WESTERN OPERATIONS, NCRCo FACILITY PAGE NO - f, I L .?. E TABLE 1 CABLE DESCRIPTION (' t' ~ 1.D. Cable No. No. -Type Function i e 319 W-10 1/C 300 MCM Containment Vent Fan Motors i i, 325 W-21 3/C #10 480 V, 3 @ Power for Motor Operated Valves (MOV) [. 323 - W-33 3/C #12 120 V,1 0 Control for MOV and 120 VDC on PC1849 i 330 W-40 4/C #12 120 VDC Control to Solenoids and [ Limit Switches 331 W-41 7/C #12 120 V,1 0 Control for MOV and I. HCV 1107A and HCV 1103A 323 W-57 2/C #14 TS Pair Drain Wire Using all Instruments i~ .~. ? ? I. a _4 '? p w.~-.

L REPORT NO. u on.mi scamesamis a masenove p WEETERN OPERAflONS. NOSCO FACluTY pac, so TABLE 2 CABLE SPLICE IDENTIFICATION i + - .}

• e '

5 Espnsure to l tem 1.D. (Cable 5 places) Cable (Cable Splaces) (Cable Splaces) Contamment Scr ew s

• H eterence No.

No. Materials No. Type ' Description vanuf acturer Atmosphere r' Page No. No. I })0 ' Polyoletin W.40 4/C f t2 5plices at Trans. Amp & American No* 6 30 -(Enc #8. I LER.30 09) 32) Dow Corning w.37 2/C fit mitter Pamcor 10,4 314) RTV Clear T5 Pair (Single heat shrmk splice). g 7 Sl?A 1.5cotch Tape 770 W-101/C 300 Cable Sphcas at 3M Company & No *

• 6 51 (Enc.r?)

7

2. Bishop Tape f)

MCM the 430V Contamment Ibshop 3.5coten Tape #38 ~ Vent Fan Motor Lead f-3.Dow Corning Tires fv A.3A 31), 3144 RTV 7C,70) ') ll?B 1.ltrathane $PT Tape W.101/C 300 The 430V Contam. General Electrec Yes 6.32 (LER 30-007) ) 2.treasil Tape . MCM ment Fan Motor Lead 3.5cotch Tapa f)) ' 5 places at the . r 1 4.Dow Corning Electrical Pene-Jit) RTV tration { 4 32) Polyolefin . Original Plant Amp & Penntube Yes 6 a? (Enc.r3 X A.34 5E 462) 123 - . Neoprene. w.21 3/C fl0 Caole Splices at 10 g 330 Dow Corning W.38 2/C r62 Electrical Pene. i 331 314)RTV w.40 4/C f t2 trations. 72) Cle:* T Al 7/C ft? (double

• -37 2/C fle heat shrmk)

T5 Pair i. 3 Cross-linked Poly. ~ TMI Modification at WC5F N Yes N/A ) oletin 5 1II? Conta.nment Pene. Raychem Adhesive (Hotmelt tration Lead Wire - Polyethylene Copoly- $plices h. .m.r) e ~ W 40 4/C fl2 Splices at Amp & American No* 6 44 '6 Polyotefan W.37 2/C fit solenoid Valves. Pamcor T5 Pain - (double heat shrink _ splice) .l

• Inside Condulets '

rReference Il.

• *lnside Termmat not 5ystem Component Evaluation Sork Sheet I

w.. ?

e .yk

,,.y -

jf .,. ~ ~' . m, _ m ~. y g~ g. , ~, TAlli 11 3 ltelert No. 26333-26 AGitJG AtAlulX Page No. 28 bM Wmt.TAIJ.Ic Mimun CEl(Vit 10 thtal)1Tisill:i ITi tt IMI. M ITt tl f1 Ant 8t M." ruta it pggyg,g gg_g g,gg ttt MAf(KS ltADI ATIOla lat *f TAI.. Acce ss:ttr ACTIVAtsura unw:trsfuv) t>Anux f u,re;) tioamAs. accgregar m. 1 Cable ' splices at Transmitter Tei perature (I)polyoteiin (1)5.0 x 103 120 189 (2) AMP 4 American Parncor 84F (29C) 305F (152C) 0.36 Utet.12) (Ref.13) (days) Relati e ilumidity (2)l14 512 TV (2)2.5 x 107 120 > 120 9015% 100%- 1.67 (Ref.14) (Ref. 4) P essure Atmospheric Max. (0 psig R diation 3.42 x 10 rads 3.0 x 107 rads 5 2 Cable Splices at the 450V Contairune it Ten ;wrature (1) Scotch Tape r70 (111.0 x 106 120 > 120 (3) Vent Fans Motor Lead Wires 34F (2T) 305F (152C) (uticone rubber) (Ref.15) 3M Cornpany & ltishop Electric Relati e lluinictity. 1.64 Otet.16) 90151 1001-(2)lbhop Tape r3 (2)2.0 x 103 120 52 (polyethylene base) (Ref. 23) (days) l' essure Atmmbperic Max. 60 psig assumeil p>lyet hylene R. tia tion 1.11 (Rel. 21) 3.42 x 105 raos 1.92 107 O) scott h Tape r33 (3)l.9 x 107 120 73 (3) Van >l plastic (poly. (Ref.15) (days) vmyl cl.loride as>ume. ) 1.19 (l ef. I?) bill 4414 TV (4)l.02 x 103 120 >l20 (4) (.assaned (lear (Ref. 7) !! TV 314 5) 1.67 (Ref. I 4) 4 - - = -. -

Po . a.

)

3. -.

~. .,m ,s g, , ~. -.,. ~ f~. g. .3-TAllt.!! 3 Report No. 263)3 26 AGING M AIltlX Page No. 29 [ ' (I ha 1 st:s< vier Ctenistisses ams nmini uwi<s at HATEHI A14 AtH) lit: mal *S y. g ta tl<MAI. M V8te:Irr ACTIVATlate 6 tu:sta;It:s taV) liAMME IPAns) load 4AI. AccIttt47 3 The 480 Containinent Vent Fan Momr Te. iperatine (1)lrrathene (1)5.0 x 107 120 34 Splices at the Electrical Penetration 34F (29C) 305F (152C) SPT Tape (Ref. 23) (days) General Electric Relat <e fluinidity (Ethylene Propylene 9015% 100% Robber) 1.34 (!tel. 22 I t essure (2)lrrasil (2)l.0 x 106 120 >120 (5,3) Atmospheric Max. 60 psig Silicone Rubber Tape (Ref.15) la diation (irradiated silicone 3.42 x 10 rads 1.12 x 106 rubber) 1.64 (Ref.16) 5 rai (3)5 cot (h Tape f 33 1.6 x 107 120 73 Vinyl plastic (Poly-(Ref.15) (days) vinyl chloride assuine ) 1.19 (Ref.17) t43145RTV 2.5 x 107 120 >l20 1.67 (Ref.14) (Ref. 4) 4 Original 1%ot Cable splice . Tei perature (1)l'olyotelin (1)$.0 x 108 120 189 at Electrical Penetrations 84F (29C) 305F (152C) 0.86 (itet.12) (Ref.13) (days) Relati e lionsidity (2) Neoprene (2)l.0 x 106 120 4 (days) (6) Arup. & Penntube 9015% 100% I.01 (Ref.18) (Ref.15) l' essure (3)314 5 It TV (3)2.5 x 107 120 >l20 AtmosgAcric Max. (0 psig 14 7 (Ref.14) (Ref. 4) R .ha t son 3.42 x 105 rads 2.5 x 107 5' . TMI Mods ication at Containinent All the conditio,, are tlw sari.e (1)Polyotefin (1)).O x 108 120 55 (7) Crosslinked (Ref.13) (Jays) Penetration Lead Wire Splices as stem No. 3 at.ve l.P8 (Ref.19) Rayctwin WCSF-N (2) Adhesive (2)3.7 x 107 120 52 (llotinett Polyethylen. (Ref.15) (days) Cupolyiner) 1.11 (Ref. 21) 6 Cable Splices at Solenoid All the conditio. are t!.e same Polyoicfin 5.0 x 108 120 189 0.86 (Ref.12) (Ref.13) (days) Valves as itern No. 4 al ve AmL-American Pancor

i 2b333-2b MO REPORT NO. $Cl!NTIFIC $ERVICES & SYSTEMS GROUP PAGE NO WESTERN OPERATIONS, NoRCo FACluTY i . TABLE 4 EVALUATION

SUMMARY

l' '{' EQUIPMENT: Cable Splices at Transmitters P EVALUATION RESULTS PARAMETER PLANT TEST ANALYSIS REMARKS Thermal Aging 40 years 120 years at Section 4.1.1 (Normal and DBE) 34F plus DBE i at 305F i Radiation Aging 3.0 x 107 3.0 x 107 Section 4.1.2 l (Rads) Temperature (F) 305 305 Section 4.3.3 I Pressure (psig) 60 60 Section u.3.4 l . Chemical Spray 2500 ppm Protected by Section 4.3.5 Boron RTV 3145 Relative 100 100 Section 4.2 k' Humidity % Submergence Flood level Above Flood SCEW Sheet Elev.1000.9' Level

p. 6-30 1.

m i 9 09 7.- r

} -

26333-26 M LABCRA M E REPORT NO. SCIENTIFIC $1RVICEs & SYSTEM 5 GRoVP 30 WESTERN OPERATIONS, NoRCo FACluTY PAGE @ k-TABLE 3 REMARKS (1) Unless otherwise noted, Calculated Accident Life listed is in addition to 120 years Calculated Normal Life. (2) Has shown to exhibit excellent radiation resistance when irradiated to levels of 5.0 x 107 rads, gamma (Ref.10). (3) Satisfactory test results were obtained when subjected to radiation fields in the neighborhood of 30-100 x 106 (Ref. 7). (4) Dow Corning no longer manufactures RTV 3144; the replacement product is RTV 3145 clear, which is basically the same product (Ref. 26, 27). (5) An investigation of this splice indicates that its composition would allow it to .{ withstand the LOCA conditions (Ref. 5). (6) Has been irradiated to levels of 5,10, and 25 x 106 rads by the Penntube Plastics Co., with no evidence of degradation as a result of these exposures (Ref.10). !~ (7) This splice system has been tested to a radiation de:e up to 200-290 x 106 with satisf actory results (Ref. 3). \\. i O he esp / an ~

2b -2b MMM REPORT NO. SCIENTIFIC SERVICES & $YSTEMS GROUP '{ ~ WESTERN oPERATloNS, NoRCo FACluTY PAGE NO -l-. TABLES EVALUATION

SUMMARY

l EQUIPMENT: Cable Splices at the 430V Containment Vent Fan Motor Lead Wires il. EVALUATION RESULTS ~ PARAMETER PLANT TEST ANALYSIS REMARKS Thermal Aging 40 years 120 years at Section 4.1.1 (Normal and DBE) 34F plus DBE at 305F Radiation Aging 1.92 x 107 1.0 x 103 Section 4.1.2 l (Rads) 1 Temperature (F) 305 305 Section 4.3.3 f Pressure (psig) 60 60 Section 4.3.4 Boric acid Section 4.3.5 Chemical Spray 2500 ppm-i Boron in excess of 5 6 h Relative i Humidity % 100 100 Section 4.2

f. _

Submergence Flood level Above flood Scew Sheet Elev.1000.9' level

p. 6-51 t

} t L E f 1 O 'I } Li

h 2bN-2b M MMS REPORT NO. J SCIENTINC $ERVICES & $YSTEM$ oRouP WESTERN oPERATtoNS, NoRCo FACIUTY PAGE NO TABLE 6 EVALUATION

SUMMARY

l EQUIPMENT: TheMOV Containment Vent Fan Motor Splices at the Electrical Penetrations EVALUATION RESULTS i PARAMETER PLANT TEST ANALYSIS REMARKS 'l Thermal Aging 40 years 120 years at Section 4.1.1 (Normal and DBE) 34F plus DBE at 305F 'f Radiation Aging 1.12 x 106 1.6 x 106 LER S0-007 (Rads) Section 4.1.2 I Temperature (F) 305 305 Section 4.3.3 { Pressure (psig) 60 60 Section 4.3.4 )- Chemical Spray 2500 ppm Protected by Section 4.3.5 Boron RTV 3145 f Relative 100 100 Section 4.2 Humidity % Submergence Flood level Above flood SCEW Sheet Elev.1000.9' level

p. 6-52 f_-

p h I t

i 2b333-2b M MMS REPORT NO. SCIENTIFIC SERVICES & SYSTEMS GROUP WESTERN OPERATIONS, NCRCo FACluTY PAGE NO TABLE 7 EVALUATION

SUMMARY

EQUIPMENT: Original Plant Cable Splices at Electrical Penetrations L EVALUATION RESULTS PARAM'ETER PLANT TEST ANALYSIS REMARKS I Thermal Aging 40 years 120 years at Section 4.1.1 l (Normal and DBE) 34F plus DBE at 305F f Radiation Aging

• 1.36 x 10
• 2.5 x 107 Section 4.1.2 7

Temperature (F) 305 235-295 305 Section 4.3.3 i f Pressure (psig) 60 60 Section 4.3.4 Chemical Spray 2500 ppm 1% pH 9.5 Protected by Section 4.3.5 i Boron RTV 3145 Relative 100 100 Section 4.2 Humidity % Submergence Flood level Above flood SCEW Sheet Elev.1000.9' level

p. 6-49 1

. _f -{

• Application has teflon insulated lead wires as interface. Need test to confirm splice will perform safety function under radiation.

1 enemme e. .m. ~

e l M LABCRA M E neeoar no. 26_233-26 7-SCIENTIFIC $ERVICES & $YSTEMS group 3y I WESTERN OPERATIONS, NoRCo FACluTY PAGE NO c TABLE 3 EVALUATION

SUMMARY

EQUIPMENT: Containment Penetration Lead Wire Splices (Raychem WCSF-N) EVALUATION RESULTS PARAMETER PLANT TEST

• ANALYSIS REMARKS I

Themal Aging 40 years 1500 hours 120 years at Section 4.1.1 l at ISOC 34F plus DBE at 305F 6 Radiation Aging ** 1.12 x 10 *

• 2.0 - 2.9 5.0 x 108 Section 4.1.2 x 103

- } Temperature (F) 305 390 305 Section 4.3.3 i Pressure (psig) 60 t6 Section 4.3.4 Chemical Spray 2500 ppm 6200 ppm Section 4.3.5 Boron Boron Relative 100 100 100 Section 4.2 Humidity % Submergence Flood level Above flood SCEW Sheet a i Elev.1000.9' level

p. 6-52 i

.I

• Wyle Test Report No. 58442-1 (Ref. 3)
  • Application has teflon insulated lead wires as interface. Need test to confirm splice will perform safety function under radiation.

1 4 F ep i ~

1 REPORT NO. {-- usamunas senme samness a sysnus onow M wasms omATions, Noaco FActury - ,,,, yo 1 TABLE 9 EVALUATION

SUMMARY

d .1 EQUIPMENT: Cable Splices at Solenoid Valves EVALUATION RESULTS I PARAMETER PLANT TEST ANALYSIS REMARKS I Themal Aging 40 years 1500 hours 120 years at Section 4.1.1 at 150C 34F plus DBE l at 305F Radiation Aging 1.36 x 107 5 x 103 Section 4.1.2 i, Temperature (F) 305 305 Section 4.3.3 L Pressure (psig) 60 60 Section 4.3.4 Chemical Spray 2500 ppm Protected by Section 4.3.5 } Baron NEMA condulet and conduit system a j Relative Humidity % 100 100 Sectin 4.2 t Submergence Flood Level Above flood level Scew Sheet i Elev.1000.9'

p. 6-49

) I i; 4 m. 8 1

ATTACHMENT 7 P

4/4/84 - Int, GPD, MOG, IG1, RLI, WGG, TJM, JCD, JKG, DW, IES, FAT, FFF, DJM, JJF, TRR ECFile * ~ ;. - :., l.yp..,.. ; ' , H ' x.r. 7.*; $ V af C M y,}

..'.?g'; y N,,% y

-. k._ - Omaha Public Power District 1623 Harney Omaha, Nebraska 68102 402/536 4000 April 3, 1984 LIC-84-093 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulabion U. S. Nuclear Regulatory Commission Washington, D.C. 20555

Reference:

Docket No. 50-285

Dear Mr. Denton:

Environmental Qualification of Safety-Related Electrical Equipment Pursuant to the requirements of 10 CFR 50.49, paragraph (g), the Omaha Public Power District has been working toward the final on-vironmental qualification of the referenced electrical equipment by the end of the second refueling outage af ter March 31, 1982. The Port Calhoun Station is presently shut down for the second refueling outage after March 31, 1982, with a scheduled startup date of May 2, 1984. Recently, the District has identified that additional time will be required to complete documentation review, verify accuracy, and complete similarity studies on a set of Foxboro transmitters in-stalled at the Port Calhoun Station. provides more specific details on these efforts. discusses the work required in order to complete the environmental qualification of electrical penetration assemblies manufactured by Conax Corporation. This attachment also provides a summary of_the history for testing the penetration assemblies 1 over the past two years. Significant progress has been made to-ward demonstrating environmental qualification of these pene-tration assemblies; however, the completion of the remaining test-ing and documentation will extend beyond the end of the current refueling outage. j 455f24 EmplotJment wim Equal Opportunity Male /fernale

Mr. Harold R. Denton LIC-84-093 Page Two For the reasons stated above, as further discussed in Attachments 1 and 2, and pursuant to the provisions of 10 CPR 50.12, the Dis-trict hereby requests an exemption from the scheduled requirements of 10 CFR 50.49, paragraph (g), for the electrical components identified in the referenced attachments. Specifically, the Dis-trict requests an approximate five-month extension beyond the scheduled May 2, 1984 date to September 30, 1984. Sincerely, ' i. ( lh!b,7:'!9 W. C. Jones DivisiEn Manager Production Operations WCJ/KJM:jmm Attachments cc: LeBoeuf, Lamb, Leiby & MacRae 1333 New ilampshire Avenue, N.W. Washington, D.C. 20036 Mr. E. G. Tourigny, Project Manager Mr. L. A. Yandell, Senior Resident Inspector

ATTACNMENT 1 Foxboro Transmitters History and Justification for Continued Operation for Franklin TER Items 1, 2, 3 and 4 The Fort Calhoun Station is equipped with 62 Foxboro transmitters (See Table

1) which f all within the scope of 10 CFR 50.49. Some of these transmitters were reviewed by FRC as noted in Table 1.

Transmitters without FRC iten num-bers were added to the scope of 10 CFR 50.49 mostly because of TMI require-ments, and have not been reviewed by the FRC. These transmitters were pro-cured from 1979 to 1982 to meet IE Bulletin 79-01B or TMI requirements. At the time of procurement, these were required to be qualifled to IEEE 323-1971 with IEEE 323-1974 qualification pendir}g. Testing on these transmitters to IEEE 32341974 was completed on August 10, 1983. The District received the test reports from the vendor on March 16, 1984. P.*esently, the District is in the process of reviewing these test reports and have concluded that be-cause of the complexity of testing, it will take significant ef fort on the District's part to ccmplete this review to resolve any anamolies, prove quali-fication by similarity and to verify accuracy. JUSTIFICATION FOR CONTINUED OPERATION For the purpose of this justification, transmitters listed in Table 1 are divided in the following categories: Category 1: 4-20 mA output Foxboro Model N-E130M and N-E11GM Trans-nitters. Category 2: 10-50 mA output Foxboro Model N-E11GM, N-E130H, and N-E130M Transmitters shipped af ter Dec.1981. Category 3: 10-50 mA output Foxboro liodel N-E13DM, N-E11GH, N-E130H Transmitters shipped prior to Jan.1982.

o Category.1 Transmitters: There are a total of 20 transmitters which fall within this category. At the tine of procurement, these transmitters were qualified to IEEE 323-1971 per Foxboro Test Report #1 TI-1059, Q9-6005, T3-1068, and T3-1097. Subsequently, a group of utilities and Foxboro Co. have qualified these trans-mitters to IEEE 323-1974 Speci fication. The District has received a copy of this test report prepared by Wyle Labs. It has been confirmed by the vendor that Fort Calhoun transmitters falling within this category are similar to the transmitters tested (same model number). The District needs to review the test report and evaluate the test results including post accident accur-actes, llowever, we believe that the transmitters as installed can be con-sidered as fully quali fied. This conclusion is justified because of the following: These transmitters were tested by a reputable test conpany and the testing was intended to envelop requirements for several nuclear power plants. The testing was done under 10 CFR 50 Appendix B QA Program and has been accepted by several utilities. The vendor, Foxboro Co., per their letter dated January 6,1984, has confirmed that no hardware modifications are required to achieve full quali fications. These transmitters were purchased as qualified to IEEE 323-1971. Based on the above, it can he concluded that there is adequate evidence of these transmitters being quali fied. Continued operation is, therefore, justified. e, r -~

l Category 2 and 3 Transmitters: There are a total of 42 transmitters which fall in Category 2 and 3. Like Category 1 transmitters, these transmitters were also procured as qualified to IEEE 323-1971. Subsequently, these transmitters have also been tested to IEEE 323-1974. The District has decided to upgrade these transmitters and has received a copy of the Test Report prepared by Wyle Labs. It has been confirmed that Fort Calhoun transmitters falling within Category 2 are identical to the transmitters tested. The vendor has also confimed that these transmitters can be upgraded without any hardware changes. For transmitters which fall within Category 3, the vendor has infomed us - that these transmitters will require some hardsare changes to fully qualify to IEEE 323-1974. These hardware changes are currently in progress and are expec.ted to be completed before plant,startup from the current refueling outage. 'Upon completion of these hardware changes these transmitters will be identical to the one tested by Foxboro. In the process of qualifying these transmitters by similarity and in review-ing the test report, it has been discovered that the test data needs to be supplemented by an analysis to justify full qualification for these trans-mitters. This is because the transmitters were tested with 65-93VDC power suppifes. The existing power supplies for 36 of these transmitters is 52.5 Volts DC. A preliminary analysis has been completed and it has been con-cluded that these transmitters will be able to perfom their intended func-tion during normal and DBE environment with a 52.5 Volt power supply. The vendor has already confimed that a 52.5 Volt power supply is acceptable for nomal operation. In discussions with the vendor it has been concluded l that with the exception of very high radiation ( 10 R), the transmitters' hardware is insensitive to anticipated post accident environmental condi-tions. For the Fort Calhoun Station the integrated dose for the duration for which these transmitters are required to be functional is expected to be less than 10 R. Therefore, considering that the hardware is not expected to degrade due to post accident environment and use of a 52.5 Volt power supply is acceptable for nomal operation, the District is justified in concluding that these transmitters will be able to perfom their intended function during nomal and DBE accident environment. Based on the above, it can be concluded that there is adequate evidence of these transmitters being qualified. Continued operation is, therefore, justified in accordance with 10 CFR 50.49. rh/4

O' TABLE 1 FOXBOR0 TRANSHITTERS Transmitter FRC# Category FT-313 1 2 FT-316 1 2 FT-319 1 2 FT-322 1 2 A/B/C/D PT-102 2 2 PT-103X 2 2 PT-103Y 2 2 A/B/C/D PT-902 2 2 A/B/C/D PT-905 2 2 LT-101X 3 3 LT-101Y 3 3 A/B/C/D LT-901 4 3 l A/B/C/D LT-904 4 3 2 FT-416 FT-417 2 FT-418 2 2 FT-419 FT-328 2 FT-330 2 2 FT-332 FT-334 2 FT-1109 3 FT-1110 3 LT-1183 3 LT-1188 3 PT-105 3 PT-115 3 PT-783 1 PT-734 1 PT-785 1 PT-786 1 A/B/C/D LT-911 1 A/B/C/D LT-912 1 A/B/C/D PT-913 1 A/B/C/D PT-914 1-I 9 L ,. ~ - ~,

O' ATTACHMENT 2 4 4 Electrical Penetration Testing History and Justification for Continued Operation for Franklin TER Items 85, 86, 87, 88, 89, 92, 99, 103 History: The Fort Calhoun Station is equipped with approximately 400 electrical pene-tration subassemblies which are used to provide electrical paths for instru-mentation, control, and power for nonnal plant operation, and certain acci-i dent and post-accident functions. These electrical penetration subassem-blies were manufactured by the Conax Corporation using TFE teflon for the seal, and FEP teflon for the lead wire insulation. As part of the prepara-tion of..the response to IE Bulletin 79-01B, testing infonnation as des-cribed in Section 5.9 of the USAR was reviewed. Upon completion of a.re-review of the available vendor-supplied documenta-tion in February 1981, the District concluded that additional testing was necessary to meet a strict interpretation of the D0R Guidelines. A separ-ate radiation tmt was done on the assemblies, and was not done in sequence as part of a LOCA test. This was not in full compliance the 00R Guidelines which require sequential testing if a material is known to degrade severely i . under a stress parameter (in this _ case radiation). Therefore, a purchase order for testing was issued to Wyle Laboratories on August 31, 1981. i The time between purchase order issuance and the beginning of actual test-ing was used to determine what fixes (RTV or Raychem sleeving) could poten-tially be tested and for preparing the test fixture and test samples. In preparation for final testing by_ Wyle, in 11 arch of 1982,6a test sample con-sisting of seal and lead wire was irradiated to 9.9 x 10 R gamma at Iowa State University. Although some material degradation was noted, the sample showed no leakage, the lead, tire insulation remained flexible, and the insu-lation withstood a 500 VDC insulation resistance test while immersed in sal t wa ter. NOTE: After experimentation with the fixes (RTV or Raychem sleeving) it was detennined that the fixes could not be acceptably imple-mented and were subsequently dropped. i' The initial testing at Wyle Laboratories began in the fall of 1982, and con-i sisted of the 40-year accelerated aging test. At the end of this testing, excessive leakage was found. This was reported to the Commission in ~a let-ter dated December 30, 1982. This seemed to be contrary to infonnation con-tained in the District's surveillance test program which indicated no leak-age. l -The District then began a research effort to identify the failure mechan-ism. A test sample was aged using the original criteria with leakage test-ing conducted at more_ frequent intervals. Failure was found to occur be-tween 20 and 30 years of qualified life. This was reported to the Commis-sfon in'a letter dated March 8,1983. - Contact was then made with Conax and DuPont. The problem was identified as i _a cold flow problem due to high accelerated aging temperatures in which the seal material " flowed".in the subassembly tubing. Conax then. developed a new aging criteria to more accurately model this " cold flow". This was con-pleted in August of 1983. A second test sample was then aged, and no Icak-age was measured.

The District restarted the test program with a modification such that the penetrations would be aged at the new temperature and then spliced on the already aged penetration lead wires, splice, and cable systen. Iloweve r, due to a communications problem, the aged cable splices were destroyed in mid-Februa ry, 1984. Subsequent to mid-February, the District attempted to locate parts, con-struct new assemblies, and evaluate the impact on the schedule to determine if the overall commitment date could be met. It then became necessary to age the lead wire, splice, and cable assently. The aging began on March 20, 1984. Testing, issuance and review of the final report, will be con-pleted by September 30, 1984. This is after the District's commitment date of the end of the present refueling outage (early May 1984). Thus, an ex-emption from this deadline is requested. Continued safe operation is just-ified. as discussed below. Justification for Continued Operation: (Franklin TER Items 85, 86, 87, 88, 89, 92, 99, 103) The District elected to resolve specific qualification deficiencies in the above noted Franklin TER items by testing. Specifically, Items 85 through 89, Rockbestos Pyrotrol III cable, were cited for deficiencies related to aging, qualified life, and radiation. Item 92, cable splices at electrical penetrations, were cited for deficien-cies related to aging, qualified life, radiation, and test sequence. Item 99, Conax electrical penetrations in containment, were cited for deficien-cies related to radiation, test sequence, aging, and qualified life. Item 103, Raychem cable splices, lacked adequate similarity. To summarize, the Conax penetrations (Item 99) are being re-tested to in-sure the proper test sequence (an elimination of separate effects) is con-pleted. Itens 92 and 103 are being tested to insure the penetration / splice system under proper test sequence is accounted for. The cables, Items 85 through 89, are being tested to account for radiation and aging in proper test sequence. It is the District's engineering judgement that safe operation is justified until the test is completed and evaluated. Based on the information supplied by the vendor, the District believes the Pyrotrol III cable is similar to the qualified Firewall III which has a 40-year qualified life at 90*C. Since the cable is similar and operates at significantly lower than 90*C (qualification level of the Firewall III), the District expects little aging degradation. It should be noted that the Pyrotrol III has successfully completed several 8 LOCA tests. including radiation up to 1,79 x 10 R. Based on similarity to Firewall III and the several tests, the District believes that continued operation with Pyrotrol III is justified. l The District-also believes operation with the splice.and penetration teflon interface is justified for Items 92 (original plant splices) and 103 (Ray-chem). The teflon provides a smooth surface to shrink on and seal. Both splices have completed a LOCA test. The original plant splicos have been qualified by analysis for aging and radiation. The Raychem has been quali-fled by test. t

It should also be noted that the District has irradiated a penetration sam-6 ple to 9.9 x 10 R at Iowa State University. The lead wire insulation was found to have degraded but should remain strong enough to insure the splice interface does not degrade. The District believes safe continued operation is justified for the electri-cal penetrations $ Item 99. As discussed earlier, a test sample was irradi-ated to 9.9 x 10 R (approximate accident dose). The sample functioned prop-erly under the limited testing. No leakage was measured at 60 psig, the insulation did not break down at 500 VDC with the lead wires immersed in salt water, and although there was some loss of structural strength, the insulation still required physical ef fort to remove from the wire and did not exhibit cracking when bent sharply. The District has also completed a successful aging test in which no leakage was measured after the equivalent of 40 years life. It should also be noted that the penetrations have suc-cessfully passed a LOCA test without aging or radiation. 0 .-.--, ~}}