ML20098F710

Forwards Reformatted Justification for Continued Operation Re Environ Qualification of safety-related Electrical Equipment,Per 840815 Telcon Request.New Format Includes Equipment Type,Manufacturer & Model Number

ML20098F710
Person / Time
Site:	Pilgrim
Issue date:	09/24/1984
From:	Harrington W BOSTON EDISON CO.
To:	Vassallo D Office of Nuclear Reactor Regulation
References
84-162, NUDOCS 8410030287
Download: ML20098F710 (191)

Text

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BOBTON E'oisON COMPANY 800 BOYLETON STREET BOSTON, M AsEACHUBETTs 02199 wtLLIAM D. HARRINGTON s:ssets wees pasasossev i

,0MTLSA2 Mr. Domenic B. Vassallo, Chief September 24, 1984 Operating Reactors Branch #2 BEco #84-162 Division of Licensing Of'fice Of Nuclear Reactor Regulation U.;S. Nuclear Regulatory Commission Washington, D. C. 20555

Subject:

Environmental Qualification Of Safety-Related Electrical Eauipment at Pilgrim Nuclear Power Station l

References:

1) Telephone conversation between Paul Leech and P. Shemanski of NRC and BEco on 8/14/84

2) BECo Letter No.84-119 dated August 3,1984, W. D.

Harrington to D. B. Vassallo

3) BECo Letter No.84-099 dated July 9,1984, W. D. Harrington to D. B. Vassallo

Dear Sir:

Reference (2) and (3) provided you with BEco resolution of Franklin TER equipment items and those equipment items that have been added to BEco Equipment Qualification program since the issuance of TER, respectively. For those equipment items for which the documentation for environmental qualification was not yet established at the time Reference (2) & (3) were prepared and submitted, BECo provided you with a justification for continued cperation (JCO) as enclosures to the submittals. BECo also provided you with I

matrix of Equipment Identification No's (ID's), Type and Manufacture /Model No.

and how their qualification concerns were resolved.

Based on the preliminary review of BEco Submittals conducted by your staff BECo was requested per telecon on 8/14/84 that all JCO's submitted be reformated to include Equipment Type, Manufacturer and Model No. Your staff also conveyed to us that the JCO's generally comply with the Staff guidelines and requirements.

i Enclosure to this letter provides you with all JCO's reformated as I requested as well as certain new JCO's for equipment which BEco had not included in Reference 2 and 3. These JCO's are identified by an asterix against the equipment identification No. The new JCO's have resulted from our

, continuing evaluation of equipment for environmental qualification.

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! We would be pleased to answer any questions you may have regarding the l enclosed information.

Very t y yours,

/ IMSIGIATED QBIGIX&B.

t feertified % bh h k@

W. D. H rrington y h '

n< (c l l Enclosure (1) Justification For Continued Operation TAV/m 8410030287 840924 b AiU '

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BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No..M0220-2 TER No.1 Sheet 1 of 2 Preparer: d/ Ibm Date: 9MM Independent Review: ~ Date: 8i E'i Approval: lb Date: i[2eh 4 l)

EQUIPMENT TYPE: DC Motor Operator MANUFACTURER: Limitorque MODEL: SMB-000-5 M0220-2 operates the outboard isolation valve for the MSIV drains. The valve is located outside containment in the steam tunnel and is normally closed during plant operation except during steam line warmup or while equalizing the pressure differentials across closed MSIVs in preparation for opening.

. The' valve is automatically closed if low-low reactor vessel level, high steam line radiation, high main steam line space temperature, high steam line flow, low steam line pressure at the turbine inlets or high reactor vessel water level is sensed. The valve could be exposed to a harsh steam and radiation

. environment during a PBOC-7, 8 or 9, (steam line break in steam tunnel), or to a harsh radiation environment during any other PBOC or a PBIC.

Systematic Analysis During a PBIC or PBOC, this valve's design function is to close to provide containment isolation and prevent the release of excessive amounts of radioactive material from the drywell. In most cases, the valve would already be shut and would simply have to remain shut (i.e., not perform an

" active" function). There is no credible cause for a subsequent spurious cpening caused by the harsh environment since all potential sensitive control components are located in panels 903, 904'and 941 in the control and cable spreading rooms. In the rare event of a PBIC or a PBOC other than a PBOC-7, i 8, or 9, during steam line warm up or while bypassing the MSIVs for opening, the valve would have sufficient time to close prior to encountering a harsh environment.

During a PBOC-7, 8, or 9, M0220-2 is required to close to provide containment isolation preventing release of excessive amounts of radioactive material from the drywell, and to terminate the transient if the break is in the drain line. In the event that the break is in an unisolated main steam line then 220-1 and 220-2 would normally be closed and would remain closed as previously discussed. If the break were in the drain line, M0220-1 would not be immediately.affected by the harsh environment and would be capable of i closing.

BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. M0220-2 TER No. 1 Sheet 2 of 2 Preparer: M/IbrM- Date: 7NfM/

Independent Review: Date: thy Approval: e fM1(\ Date: T/Zo/N

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Technical Analysis M0220-2 is equippped with a Peerless DC motor utilizing Class "B" insulation for which limited qualification documentation is available. Limitorque qualification test report B0003 documents the testing of an actuator of similar design (but with a Peerless AC motor with Class "B" insulation rather than a DC motor) in a steam and radiation environment to 250"F, 25 psig and 2 x 107 rads. The test profiles envelope the service profiles for all postulated transients except for temperature during the first minute of a PB0C-8 (main steam line break in the steam tunnel). However, the thermal inertia of the operator in a super heated steam environment, as documented in Limitorque Test

~

Report B0027, will result in temperatures within the vital portions of the actuator and motor which are enveloped by the qualification test. The results of Limitorque Report B0003 therefore justify the capability of Class B insulation to withstand the service environment. Limitorque Qualification Test Report B0009 documents the testing of an actuator of similar design (but with a Peerless DC motor with Class "H" rather than Class "B" insulation) in a steam and radiation environment which envelopes the service environment for all postulated transients af fecting M0220-2. The results of Limitorque Test Report B0009 demonstrate the capability of the commutator and brushes of a Peerless Motor to withstand the service environment. Based on these considerations, the operability of M0220-2 is adequately assured and continued operation is justified.

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COSTON EDISON COMPANY JUSTIFICATION FOR l

CONTINUED OPERATION Equipment Identification No. M04002 Sheet 1 of 1 TER No. 2 Preparer: A fM Date: hYh Date: .

Independent Review:

Date: E/27/84 Approval: NOa w

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EQUIPMENT TYPE: AC Motor Operator MANUFACTURER: Limitorque MODEL: SMB-000-5 M04002 is the operator for the Class C Containment Isolatio This valve, which is located in the torus compartment, is HVAC coolers.

normally open and can be manually closed to prevent the release of excessive amounts of radioactive material from the drywell.

M04002 would be exposed to a harsh radiation environment during a PBIC/LOCA.

However, the LOCA would have to be of sufficient magnitude and in the proper location to result in a missile or jet impingement sufficient to sever theThe RBCCW piping within the containment.be almost imediately indicated in the The operators could be expected to normal alarms for the RBCCW System.

diagnose this condition and remotely M04002close M04002 is qualified for afrom radiation the control room in a relatively short period of time.7 rads as documented in Limitorque Qualification Rc;;crt cxposure of 2 x 1080003 and would therefore remain operable for period in based on projected radiation exposures.

diagnosis and closure to occur.

M04002 would be exposed to a harsh environment during a PBOC-5 (HPCI Bre the Torus Compartment).

Although not required, M04002 would remain in the open position to provide drywell cooling and would not be to function.

mild environment and would not be affected by the PBOC.

Based on this discussion, continued operation is justified.

I Page 4 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION t

Equipment Identification No. 'M01001-63 TER No. 3 Sheet 1 of 1 Preparer:

Date: Sf'h Independent Review: Date: '

24 !fY

(/ U Approval: MD =

( N Date: 8124/24 Y

EQUIPMENT TYPE: AC Motor Operator MANUFACTURER: Limitorque MODEL: SMB-00-5 M01001-63 is the operator for the inboard isolation valve for RHR head spray during shutdown cooling (SDC) operation. This valve can be openeo during SDC to maintain saturated conditions in the reactor vessel head during reactor cooldown in order to permit a more rapid / accelerated flooding of the vessel.

However, the valve is normally shut during SDC and power operations. The The valve can be valve is located in containment zone 1.30 elevation 84'.

operated remotely from the control room and will automatically close in the event that low reactor vessel level, high drywell pressure or high reactor vessel pressure is sensed.

The only safety functica which this valve operator performs that can be challenged by a harsh environment is that of providing containment isolation during a PBIC or a PBOC. However, the valve need not provide an " active function" since it need only remain in the normally closed position. There is no credible means for this valve to subsequently fail open as a result of the harsh environment since all potentially sensitive control circuitry is located in panels 903 and 941 in the control and cable spreading rooms.

In the rare event that a P81C or PBOC did occur with SDC in operation, the valve would be called upon to close. However, the environment to which it was exposed would be considerably less harsh thanIn that associated with a this event, it is similar transient starting from power operation.

believed that this valve would be able to close well before its operability would be challenged. In addition, redundancy is provided by closure of the inboard check valve (1001-64) and the outboard isolation valve (1001-60).

Since capability has been shown for the performance of the required safety function (s) and since the valve would not be required to change states at any subsequent tiwe, continued operation is justified.

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BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. M02301-4 TER No. 4a Sheet 1 of 2 Preparer: d/ e7 Date: N #: / k Independent Review: bb Date: Pf24ff4 Approval: Date: f /h d

() I EQUIPMENT TYPE: AC Motor Operator MANUFACTURER: Limitorque MODEL: SM8-2-60 M02301-4 operates the inboard isolation valve in the steam supply line to the HPCI turbine. The valve is mounted within the drywell and is actuated open in the event that reactor vessel low-low water level or high drywell pressure is sensed. The valve is over-ridden closed in the event that a HPCI steam line break is identified by high HPCI steam line space temperature or high HPCI steam line flow. The valve is normally open during operation.

Potentially sensitive control circuitry for this valve is mounted in panels 903, 939 and 941 in the control room and cable spreading room and would not be subject to a harsh environment.

FSAR section 6.5.1.2.2, Safety Evaluation for the HPCIS, describes the HPCI system as one " designed to provide adequate reactor core cooling for small breaks." On this premise, a detailed analysis concluded that the " core never uncovers and is continuously cooled throughout the transient so that no core damage of any kind occurs for breaks that lie within the range of the HPCI."

During such events, M02301-4 fulfills a safety function of opening / remaining open to supply steam to the HPCI turbine and therefore facilitate HPCI operation. However, since no core damage results f rom those events for which HPCIS operation is essential, those components such as M02301-4 that are considered essential for HPCIS operation will not be exposed to radiation in excess of that experienced during normal operation. In the event that the small break PBIC exposes. M02301-4 to a harsh steam environment there is a small chance that M02301-4 could be rendered inoperable prior to opening.

However, ADS /LPCI and ADS /CS would be available for redundant protection.

M02201-4 therefore need not be demonstrated to be operable for P8IC.

In the event of a PBOC in the HPCI steam lines, 2301-4 and its paired outboard isolation valve (2301-5) are required to close to prevent the excessive loss of reactor coolant and the release of radioactive material.

However, there would be suf ficient time delay before the PBOC caused an environment within containment suf ficient to challenge the operability of M02301-4 thus allowing automatic closure of 2301-4 to occur due to high HPCI space temperature or high HPCI steam line flow.

BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. M02301-4 TER No. 4a Sheet 2 of 2 Preparer: h/[he-w Date: N2d6 Independent Review: N ks4.A4- Date: I 74!ff Approval: Date: f 30b'@

G During any other PBOC, HPCI would be required to operate for core cooling following isolation of the leak. PNPS FSAR analyses indicates that fuel failure would not occur during any PBOC and M02301-4 would not be exposed to a harsh environment. Therefore, the valve would remain in the desired normally open position since potentially sensitive control components would not be affected by the harsh environment.

Based on these considerations, continued operation is justified.

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.e roSTON EDISON COMPANY JUSTIFICATION FOR l CONTINUED OPERATION Equipment Identification No. M01301-16

. TER No. 4b Sheet 1 of 1 l i

Preparer: h Y:t F D, ate: bdMF Independent Review: Date: f(fM [(4 Approval: MIA

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EQUIPMENT TYPE: AC Motor Operator MANUFACTURER: Limitorque MODEL: SMB-00-10 M01301-16 operates the inboard isolation valve in the steam supply to the RCIC turbine. The valve is located within containment at elevation 41 and is normally open during plant operation. The valve is opened automatically if a reactor vessel low low level is sensed and will be automatically overridden closed in the event that a RCIC steam line leak is sensed by indications of either high RCIC steam space temperature or high RCIC steam flow. The valve

. serves a dual safety role of supplying steam to the RCIC pump turbine following a Control _ Rod Drop (the only accident for which RCIC operation is credited) or to provide containment isolation and terminate a PBOC-4 (RCIC Steam Line Break in the RCIC Valve Station) or a PBOC-6 (RCIC Steam Line Break in the RCIC Pump Room). The valve operator is equpped with a Reliance electric motor which was rewound with Class "H" insulation material by the GE Apparatus Service Shop in Medford, MA 8/2/80. A comparison of the GE Class "H"' rewind materials with the Reliance Class "HR"'OEM materials showed the rewind materials to be similar or equivilent. M01301-16 is therefore similar to the motor operator whose qualification testing was documented in Limitorque Test Report 600376A.

During a PBOC-4 or a PBOC-6, M01301-16 wYuidbeexposedtoincreased radiation as a result of fuel failure while being required to shut to provide containment isolation and terminate the transient. However, the radiation exposures experienced by M01301-16 for any PBOC are enveloped by the qualification testing documented in Limitorque Report 600376A. In addtion, redundant isolation would be provided in all cases except a PBOC-4 by the outboard isolation valve operated by M01301-17.

Based on these considerations, continued operation is justified.

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l BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. M0220-1 TER No. 4c Sheet 1 of 1 Preparer: MM"t Date: M'/8/

Independent Review: I Date: 7!/ 9[F'/

Approval: MO Date: 9[2.o[f Y'

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EQUIPMENT TYPE: AC Motor Operator MANUFACTURER: Limitorque MODEL: SMB-000-5 M0220-1 operates the inboard isolation valve for the MSIV drains. The valve is located within containment (zone 1.30 at elevation 18') and is normally closed during plant' operation except during steam line warmup or while equalizing the pressure differentials across closed MSIVs in preparation for opening. The valve is automatically closed if low-low reactor vessel level, high steam line radiation, high main steam line space temperature, high steam line flow, low steam line pressure at the turbine inlets or high reactor vessel water level is sensed. The valve could be exposed to a harsh steam and radiation environment during a PBIC or to a harsh radiation environment following a P80C. The design function of M0220-1 is to close to provide containment isolation and prevent the release of excessive amounts of radioactive material f rom the drywell. The actuator is presently equipped with a stock replacement Reliance Electric motor with Class "RH" insulation.

Limitorque Qualification Test Report B0058 and Appendix B document the qualification testing of a similar actuator with a Reliance Electric motor utilizing Class RH insulation. The qualification profile envelopes the service profile for all parameters for any postulated transient affecting M0220-1. M0220-1 is therefore considered to be qualified pending completion of an inspection to verify that appropriate terminal strips were used for power cable termination (required by IE Notice 83-72). Inspection of the terminal blocks in the Limitorque operators is in progress. No deficiencies in the tenninal blocks have been reported and therefore there is a high degree of assurance that the terminal blocks in this motor operator are qualified. Continued operation is therefore justified.

Page 9 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION u

Equipment Identification No. M01001-50 Sheet 1 of 2 TER No. 5 .

Preparer: h brze D' ate: Nifh9 M ST B Independent Review: 3 b[ ~ Date:

Date: R12 7 l%4 Approval: SND > 2 (

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EQUIPMENT TYPE: AC Motor Operator MANUFACTURER:

Limitorque MODEL: SMB-2-40 (w/ brake)

M01001-50 operates the inboard isolation valve in the RHR pump shutdown This valve cooling (SDC) suction supply line for the recirculation system. The valve serves is located within containment at elevation 50' (zone 1.3).The valve also a containment isolation function during a PBIC or PB0C.

serves to allow return flow from the recirculation system to the RHR pumps during SDC operation. The valve has a 30 day mission length.

Communications with the vendor have documented that the operato brake installed on 1001-50 Continued operation can therefore in Limitorque Reports 600198 and 600376A.

be justified on the following basis:

o Qualification Method 600198 and 600376A.

This component is qualified per Limitorque600198 Test Reportsis in accordance with the DDR The qualification method used in report Report 600376A, which is in guidelines with the exception of radiation.accordance with the 00R g e Temperature and Pressure and communications from the Limitorque Per Limitorque test report 600198 Corp. and Wyle Labs, this motor operator has been successfully tested to a temperature and pressure profile which envelops the service profile for all postulated transients, o Qualification Time this component was tested for a period of Per Limitorque Test Report 600198, The 7 days, with a test profile more severe than the service profile.

service profile returns to normal conditions within approximately 6 days.

However, a degradation equivalency analysis of both

fage 40 l l 1

l BOSTON EDISON COMPANY I JUSTIFICATION FOR CONTINUED OPERATION I

Equipment Identification No. M0-1001-50 TER No. 5 Sheet 2 of 2 Preparer:

" -f _ Date: M&t'Mf' Independent Review: Date: M Approval: C9GD% ( N Date: 8/11/ R4 w

day accident where the accident temperature is at or below 100'F for 692 hours0.00801 days <br />0.192 hours <br />0.00114 weeks <br />2.63306e-4 months <br />. Based on this analysis, adequate margin exists to ensure that this component will continue to perform its intended function for the duration of its required mission length, o Radiation Per Limitorque Test Report 600376A, this type of motor operator has been successfully tested to a radiation exposure of 2 x 108 rads. Based on consnunications f rom Limitorque, Test Report 600376A is applicable to this This test was performed in operator for radiation qualification purposes.The total integrated dose for this component accordance with DDR Guidelines.

is less than the qualified dose.

o Aging (160*F)

Component materials of the Limitorque actuators have been identified.

Evaluation of these materials has been performed per DOR Guidelines and using Arrhenius Analysis Techniques. With the exception of the lubricants, the components of the actuators are considered insensitive to aging effects at a 160*F temperature. Lubricants were previously renewed by changeout.

o Drywell High Temperature (240*F)

The age sensitive components of the Limitorque actuators (the lubricants, seals, gaskets, and jumper wires) were previously inspected and replaced as necessary. The limit switches, torque switches, terminal blocks, and terminal strips were previously inspected and verified to be as tested. The Class H motors, per Limitorque requirements, was previously inspected and meggered for operation. The limit switch gear frames were previously inspected and verified to be as tested. The limit switch compartment cover was previously inspected and judged acceptable for operation by Limitorque.

Based on these considerations, continued operation is justified.

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BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. M01201-2 TER No. 5 Sheet 1 of f Preparer: hb Date: V /

Independent Review:

Date: M Approval: Date: %iTi / 84-e N w

EQUIPMENT TYPE: AC Motor Operator MANUFACTURER: Limitorque MODEL: SMB-00-15 M01201-2 operates the 6" inboard isolation valve in the RWCU supply line from the reactor vessel. The valve is located within containment at elevation 48' and is normally open during plant operation. The valve is automatically closed if reactor vessel low level, SLCS initiation, high temperatore in the RWCU space or high RWCU flow is sensed. M01201-2 can be exposed to a harsh

. environment during a PBIC or a PBOC. Since all potentially sensitive control components are located in mild environments spurious actuation of M01201-2 is not deemed credible.

During a PBIC, M01201-2 is exposed to a harsh steam and radiation environment. The valve's safety function during the transient would be to close for containment isolation and prevent the release of excessive amounts of radioactive material from the drywell. M01201-2 would also be exposed to a harsh radiation environment while being required to close during a PBOC for contrinment isolation and in the case of a PBOC-28/2T to also terminate a leak from the RWCU System.

Limitorque has confinned that this valve operator was built to the same specifications as operators tested and reported in Limitorque Qualification Test reports 600198 and 600376A. However, actuator replacement is planned for documentation purposes.

The qualification testing profiles documented in Limitorque reports 600198 and 600376A envelope the service profiles over the required mission length for all postulated transients. In addition, redundant isolation can also be shown in all cases by the series outboard valve 1201-5.

Based on these considerations, continued operation is justified.

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' l BOSTON EDISON COMPANY JUSTIFICATION FOR (

CONTINUED OPERATION Equipment Identification No. M0202-5A, M0202-5B TER No. 6 Sheet 1 of 2 ,

i kl Date: VNYlW Preparer:

/ '

Independent Review: b Date: P!24ff4

'u) Date: [30 f Y _

Approval: -

EQUIPMENT TYPE: AC Motor Operator MANUFACluRER: Limitorque MODEL: SMB-3-100 M0202-5A/58 are the operators of the recirculation pump discharge isolation valves. These valves are normally open during power operation but the valve in the undamaged recirculation loop is automaticallyThe signaled valve operators shut for injection loop selection during a LPCI initiation.

include a motor and magnetic brake for which complete radiation qualification

- data is not available. Failure of these components could result in the valve not closing or only partially closing.

e Systematic Analysis One of these two valves is signaled closed immediately However, following closure detection of of a LOCA/PBIC from the other recirculation system loop.

the valves is only required in the event of a double ended rupture of the pump suction piping. The 10CFR50.46 ECCS Acceptance Criteria is satisfied providing that the recirculation pump discharge valve in the unaffected loop closes and the LPCI injection valve on the same recirculation loop opens.

The pump discharge valve in the affected loop is left open to maximize reactor vessel blowdown and accelerate recirculation system depressurization For to the LPCI threshold and therefore does not need to actively function.

a complete, guillotine rupture of the pump discharge piping, the two redundant low pressure core spray subsystems would provide sufficient emergency core cooling.

The These valves are not expected to fail as a result of radiation damage.

incremental increase in accumulated radiation dose from a large break LOCA should not prevent valve closure, since the valve operates within the first minute of the accident.

Page la i

4 BOSTON EDISON COMPANY JUSTIFICATION FOR ",_-

i CONTINUED OPERATION

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Date: ffflAff4 b- Independent Review: bh v g i u 8 / 3o[T Y r

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- f Technical Analysis E a 600198 and Limitorque Qualification Repor t

{p ll as Limitorque Qualification Report 600376A describe theanseparate testing of a sim The testing involved  !

r a similar motor and magnetic brake assembly. for

's irradiation of 200 megarads and exposure to a harsh steam environment h first

~ "g thirty days at temperatures / pressures as high as 329*F/90 d psig for t eThe-;D hour without deleterious effects. j

[ brakes for Reliance Electric, has verified that the i 11ent brakes were co 3 using Class "H" insulation. ]

analysis which determined that the brake materials are similar t d in or equ v _=

to those used Thein the total motor design integrated i id/orbasis brake PBICassemblies 30 day estimated tested as docum 600198/600376A. 7 Rads) is significantly less than the tested file dosefor a integrated dose (6.6 x 10 g and the test temperature and pressure profile envelop the service proswitch com =

these components.

An inspection of th. those not I perf ormed to verify the condition of components and toage All potentially replace h i 3 meeting the standards for use within containment. j sensitive components of the operators have been evaluated d d to using be Arr en us Analysis Techniques and with the exception of lubricants are consi ereLubrica _

insensitive changeout.

to aging effects at 160*F.Wyle Labs has performed the necessarfl justify continued operation to the end of cycle 7. i d until i Based on these cor sideration, continuation of operation be is justif e i such time as qualified replacements (which have been ordered) can g

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Page 14 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. M0/N-109, M0/N-113 TER No. T, 8 Sheet 1 of 1 Preparer:

% Date: AY!?Y Independent keview: kb e Date: 24!N o

Approval: NdO- Date: B / T7 / M N

V EQUIPMENT TYPE: Damper Actuator MANUFACTURER: Honeywell MODEL: M940A1067-1 These components are the outlet dampers for SGTS filter trains and are required to open upon a Standby Gas Treatment System initiation signal. The motor operators for the dampers were deenergized by removing the fuses and the dampers are positioned such that the required airflow of 4000 scfm is maintained. Therefore, failure of this item will not affect SGTS operation

- and continued plant operation is justified.

Page 15 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. M01001-60 TER No. 9 Sheet 1 of 1 Preparer: hh4- Date: W Independent Review: MS Date: 8b4 !f(4 0 0 Approval: NO-( Date: 7/24 /%

<T EQUIPMENT TYPE: DC Motor Operator MANUFACTURER: Limitorque MODEL: SMB-000-5 M01001-60 operates the outboard block valve for reactor vessel head spray during shutdown cooling. This valve is normally closed but can be opened during shutdown cooling (SDC) to maintain saturated conditions in the reactor vessel head during reactor vessel cooldown and permit a more rapid / accelerated flooding of the vessel. The valve is located outside

- containment in the fuel pool cooling heat exchanger room (zone 1.13) and could be exposed to a harsh radiation environment during a PBIC or PBOC.

During the occurrence of a PBIC or PBOC with SDC not in service, this valve would remain in the normally closed position since potentially sensitive control components will not be affected by a harsh environment. Although the valve might not subsequently be capable of opening to accelerate vessel flooding during SDC initiation, it is not required to be open to achieve SDC.

During the occurrence of a PBIC or PBOC with SDC in service, this valve would be automatically signaled closed upon receipt of a LPCI initiation signal to isolate SDC from the reactor vessel. Based on the full power PBOC/PBIC integrated dose estimates, approximately 10 minutes would elapse prior to this valve being exposed to a harsh radiation environ:nent thus allowing M01001-60 more than sufficient time to close. Although the valve would be inoperable for subsequent reinitiation of SDC, it is not required as discussed above.

Based on these considerations, continued operation is justified.

3 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identi'ication No. M01001-23A/238, M01001-26A/26B TER No.11, 20 Sheet 1 of 1 Preparer: d// he Date: [/zMf1(

Independent Review: h Date: 9 ff V' 0 Approval: / Date: if30f!Y --

(l EQUIPMENT TYPE: AC Motor Operator MANUFACTURER: Limitorque MODEL: SMB-0-40 M01001-23A/23B and M01001-26A/26B operate the containment isolation valves -

for the containment spray portion of the RHR system. M01001-23A and M01001-26A are located outside containment in the RWCU heat exchanger room ..

i (zone 1.llA). M01001-238 and M01001-26B are also located outside containment at the RCIC Valve Station. These valves are all normally closed.

These valves are expected to be remotely opened by an operator in the control room during a small break steam leak within containment to prevent exceeding the drywell design temperature. Although the valves are normally closed, it is our engineering judgement that there would be sufficient time to open these valves and actuate containment drywell spray prior to these valves being exposed to a harsh radiation environment.

During a PBOC, these valves are exposed to either a harsh steam and radiation -

environment or to a harsh radiation environment alone. However, in all cases, these valves are required to remain in their normally closed position and are not required to actively function. Subsequent spurious actuation of the valves is not deemed credible since all potentially sensitive control components are located in mild environments.

Based on these considerations, continued operation is justified.

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Page 17 BOSTON EDISON COP /ANY JUSTIFICATION 'f0R CONTINUED OPERATION Equipment Identification No. H01400-25A, M01400-25B TER No.12,10b Sheet 1 of 2 Preparer: h G Date: kNW Independent Review:

Date: T Approval: TO-m Date: tin!M ~

s N U

EQUIPMEH1 lYPE: AC Motor Operator .

MANUFACTURER: Limitorque MODEL: SMB-3-100 M01400-25A/B are the operators for the downstream / isolation valves for the core spray lines. M31400-25A is located in RWCU Heat Exchanger Compartment (Zone 1.11 A) and M01400-25B is located in an open area of the reactor .-

building at elevation 51' (Zone 1.12). Both valves are normally closed but will automatically open once reactor vessel pressure has decreased to approximately 400 psig (following manual initiation or indication of low reactor vessel water level or high drywell pressure) to allow core spray to provide a core cooling safety function. The valves can be exposed to a harsh environment during a PBIC or a PBOC. The valves are equipped with a motor and electrical brake for which complete qualification data is not available.

Over the full range of analyzed PBIC break sizes, reactor vessel pressure can be shown to decrease, either due to direct blowdown (large break) or A05 (small break) without assistance from HPC1/RCIC to 400 psig or less in 5 minutes or less. A design basis PBIC manifests a hazardous radiation environment in the area where H01400-25A/B are located within approximately 7 minutes. However, since the valves are designed to operate in 10 seconds or less, ccepletion of the open cycle prior to exposure is adequately assured.

In addition, a similar motor and brake demonstrated the capability of withstanding a 200 megarad exposure (which is well in excess of the design PBIC exposure) without deleterious effect as documented in Franklin Report F-C4411. Once the valves had opened, they are expected to remain open and .

available for use in long tenn core cooling since all potentially sensitive control components are not expected to be affected.

Both M01400-25A and M01400-258 would be affected by a harsh steam and radiation environment caused by a PBOC-2T (RWCU line break in the RWCU Heat Exchanger Room). However, the A & B LPCI train would be available to fulfill the core cooling safety function.

~~

Page 18 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. M01400-25A, M01400-25B TER No.12,10b Sheet 2 of 2 Preparer: [ enf Date: I/V[/7 Independent Review: 9W Date: M' 7 4 Approval: u Date: BI'171 Ts4 i N v

Poth M01400-25A and M01400-25B would be exposed solely to harsh radiation environments during all other PB0Cs. However, both valves would be capable of achieving their intended open positions prior to a harsh exposure level being reached. In addition, the capability of a similar motor / operator combination to remain operable for exposures up to 2 x 108 rads was documented in F-C3441 as previously discussed.

Since protection can be demonstrated in the event of all potential harsh environments challenging these valve operators, continued operation is justified.

.m~

BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment identification No. M01400-24A, M01400-24B TER No.13,10a Sheet 1 of 1 Preparer: h] Date: h Independent Review: Date: YbY Approval: @O Date: 3121/ %

I \

U EQUIPMEN1 TYPE: AC Motor Operator MANUFACTURER: Limitorque .

MODEL: SMB-3-80 2 1

W These valves are the " upstream" outboard isolation valves in the core spray (CS) supply lines. These valves are located outside the drywell in zones

~

1.11A (RWCU Heat Exchanger Room) and 1.12 (open area at elevation 51) respectively and could be exposed to a harsh environment during a PBOC or PBIC. The valves are normally open and are controlled by remote manual actuation from the control room or automatic open actuation in the event that low low reactor vessel level or high drywell pressure are sensed concurrent with low reactor pressure.

The core spray system provides protection (core cooling) for large or small breaks in the nuclear system when feedwater, control rod drive water, RCIS and HPCIS are unable to maintain reactor vessel water level and, in the case of small breaks, when the ADS has lowered reactor pressure below CS pump shutoff head. During such transients, the design function of these two '

valves is to open or remain open to permit injection of CS. However, the valves are not required to actively function (i.e., change position) during such transients, either PBIC or PBOC, since they are normally maintained in the open position. There are no credible mechanisms for inducing a spurious closure during a PBIC or PBOC since all potentially sensitive control circuitry is mounted in panels 902, 932 or 933 in the control and cable . . .

spreading rooms. In addition redundant protection is provided for large l break PBIC/PBOC by LPCI and for small breaks by ADS /LPCI. Continued operation is therefore considered to be justified.

F s

e _

Page EU BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUEO OPERATION e

Equipment Identification No. M01201-5, M01201-80 TER No.15,14 Sheet 1 of 1 Preparer: lW $^~~r Date: ?hYN f(4 Independent Review: hb Date: If2 Date: I[3c[9M Approval:

nv EQUIPMENT TYPE: DC/AC Motor Operator MANUFACTURER: Limitorque MODEL: SMB-00-15/SMB-0 M01201-5 operates the outboard isolation valve in the RWCU suction line from the reactor vessel. M01201-80 operates the isolation valve in the RWCU return line. Both valves are located outside containment in the RWCU heat exchanger room (zone 1.ll A) and are normally open during reactor operation.

Both valves are automatically signaled shut to terminate a RWCU linebreak upon detection of a high flow rate to RWCU or a high temperature in the RWCU spaces, or to provide containment isolation if low reactor vessel level is detected. These valves are exposed to a harsh steam and radiation l environment during a PBOC-2T (RWCU line break in the RWCU heat exchanger ' f.,

room) and to a harsh radiation environment during a P81C and all other In all cases, these valves are required to close and remain closed to b)% ~

PBOCs.

either terminate the leak and/or establish primary containment. M01201-5 is cI.ff ,t _.,*

h being replaced with a qualified operator under the valve betterment program.

Limitorque Report B0003 documents the qualification testing of a valve [V." N operator and motor similar to M01201-80 in a harsh steam and radiation 2 - T environment that envelopes the service profile for both valve operators for %D.:

all postulated transients including a PBOC-2T. M01201-80 is therefore S . ji considered to be qualified pending completion of an inspection to verify that g.Q.y appropriate terminal strips were used for power cable termination (required W.Q by IE Notice 83-72). Inspection of the terminal blocks in the Limitorque M^'

operators is in progress. No deficiencies in the terminal blocks have been (,jg reported and therefore there is a high degree of assurance that the terminal #9 "'

blocks in this motor operator are qualified. Continued operation is therefore justified, t.J

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I'dge di BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. M02301-5 _

Sheet 1 of 1 }

TER No.16 .

A 7, Preparer: MIM r Date: M2M/V <

< .';c~,. "

Independent Review: Nhw, u Date: PfMh4

.h.';h)./

Approval: id466o Date:  ?[30/94 hh,;

.. .j -

v;

((

~ .Qj, Y.'l. '-8 -:

EQUIPMENT TYPE: DC Motor Operator N$

MANUFACTURER: Limitorque *[

. 3 ., :

MODEL: SMB-1-60 7..g f gy s M02301 -5 operates the outboard isolation valve in the steam supply line to # M the HPCI turbine. The valve is located outside containment in the RHR/HPCI Valve Station (zone 1.108) and is normally open. During a transient requiring HPCI operation, the valve's function is to open and remain open over a 5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> mission time to supply steam to the HPCI pump turbine.

The FSAR Section 6.5.1.2.2 Safety Evaluation of the HPCI System, describes the system as one " designed to provide adequate reactor core cooling for small breaks." On this premise, a detailed analysis concluded that the " core never uncovers and is continuously cooled throughout the transient so that no core damage of any kind occurs for breaks that lie within the range of the HPCI system." Based on the prevention of core damage for those small break PBIC events requiring HPCI operation, those components that are essential to HPCIS operations, such as M02301-5, will not be exposed to radiation during such transients in excess of levels occurring during normal operation.

The only harsh environment to which M02301-5 is exposed while being required to function is that caused by a PBOC-1 (HPCI Line Break in the HPCI Valve Station). The design function of M02301-5 during this transient is to cicse to isolate the leak. However, the inboard isolation valve (M02301-4) inside containment will be capable of closing prior to exposure to a hrsh environment to provide isolation of the leak. Continued operation is therefore justified.

l l

3 BOSTON EDISON COMPANY JUSTIFICATION FOR 3 CONTINUED OPERATION i -2 Equipment Identification No. M01001-29B y

TER No.17b Sheet 1 of 1 r=_.

Preparer: - Date: W -

Independent Review: -

Date: Y Approval: TO% Date: 8 I?A / M 7

( \ I

=_

e EQUIPMEN1 TYPE: AC Motor Operator [

t MANUFACTURER: Limitorque ^-

L MODEL: SMB-3-100 N01001-29B operates the downstream LPCI injection valve for the A l )

h Recirculation Loop. The valve is located outside containment in the HPCI , T

Valve Station (zone 1.108) and could be exposed to a harsh environment during @

i a PBIC or a PBOC. The valve serves to allow or prohibit LPCI or shutdown 4:

) cooling (SDC) flow to the B Loop and is hormally open. However, M01001-29B $

k will be automatically closed if a low reactor vessel level or high drywell 3-

- pressure is sensed during SDC to isolate a possible leak from the RhR/ SOC s system. The valve can be overridden open using a pushbutton at the operator , p p control switch at panel 903 in the control room following isolation reset. ^

g.

There is no credible cause for spurious operation of M01001-29B as a result = T of a harsh environment since all potentially sensitive control components are b mounted in panels 903, 932 and 933 in the control and cable spreading rooms.

Limitorque Test Report B0003 documents qualification testing of a similar #

E valve operator and motor for a harsh steam and radiation exposure (250*, 25 f 5 psig and 2 x 10 7 rads maximum). The qualification profile envelopes the 7 L service profile for all postulated transients af f ecting M01001-29B except a 2_

E- PBOC-1. PBOC-1 (HPCI steamline break in the HPCI valve station) exposes n a M01001-29B to a harsh super-heated steam and radiation environment. The e PBOC-1 service profile for temperature (309.4*F maximum) exceeds the B0003 7

{ qualification profile (250*F maximum) for approximately 2 minutes. However, g

the thermal inertia of the valve operator in a super-heated steam . _-

environment, as documented in Limitorque Report B0027, would cause the vital r '

5 portions of the valve operator and motor to lag sufficiently to be enveloped ll1 by the qualification profile. The qualification profiles fse all other ';_

= parameters envelope the corresponding PBOC-1 service profiles and M01001-29B  ;

g will therefore remain operable. '

p g [

g Based on these considerations, continued operation is justified.

b k -_

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5 2

m L I_

Page 23 BOSTON EDISON COMPANY JUSTIFICATION FOR -

CONTINUED OPERATION s

Equipment Identification No. M02301-8 TER No.18 Sheet 1 of 2 ,

Preparer: dddNN Date: fdf[# '

Date: 19 ffY Independent Review:

i[2o[f Date:

Approval: -

(\

EQUIPMENT TYPE:

DC Motor Operator MANUFACTURER: Limitorque MODEL: SMB-1-60 M02301-8 serves two functions. For events requiring isolation of HPCI, M02301-8 (a normally shut valve) serves a containment or pressure vessel isolation function. However, redundant containment and reactor vessel isolation is provided by valve 588 (feedwater line "B" check valve).

"B"

~

For events requiring HPCI operation, M02301-8 opens to admit HPCI to the feedwater line. The HPCIS is relied upon to operate during and following  :

Loss of Feedwater Flow, Total Loss of Offsite Power, Shutdown from Outside Control Room (Special Event), -

Pipe Break Inside Primary Containment, j Control Rod Drop Accident, and Pipe Break Outside Primary Containment to assure continued core cooling, and thus mitigate consequences which could result in potential of fsite exposures comparable to the 10CFR100 guidelines.

None of the first three events listed above is expected to result in i envisonmental conditions any more severe than those experienced during normal operation. The fourth event is addressed in the HPCIS Safety Evaluation, which states that, "The HPCIS is designed to provide adequate core cooling for small breaks... core never uncovers and is continuously cooled throughout the transient so that no core damage of any kind occurs for breaks that lie m within the range of the HPCI." Thus, the size of LOCA presumed to generate "

postulated core damage is beyond the capacity of HPCIS to provide core cooling. A The Control Rod Drop Accident has been evaluated and no HPCIS equipment will be subjected to pressure, temperature, radiation or humidity conditions any more severe than those experienced during normal operation.

2

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Page 24 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION I

Equipment Identification No. M02301-8 TER No.18 Sheet 2 of 3 Preparer: d2/ d6+ Date: I//fk Date: 'I I Independent Review:

s INAAMQ Oate: Tf7efR4 -

Approval: i (g

w Those pipe breaks outside containment which could be expected to result in harsh conditions of oressure, temperature and humidity in the vicinity of Each of these events, however, M02301-8 are the PBOC-3 and the PBOC-5.

incapacitates the HPCIS. System operability is, therefore, not required for either PBOC.

On the other hand, system operability is required for the main steam line breaks, PBOC-7 and PBOC-8. However, FSAR analysis of the PNPS design basis Main Steam Line Break Accident indicates that, with a maximum 10.5 second MSIV closure and continued core coverage (from normal or standby systems, including HPCIS), there would be no fuel damage. Without core damage, a harsh radiation exposure will not occur.

MSIV closure time is verified once per quarter under Technical Specification surveillance requirements. The closure time must be greater than 3 seconds and less than 5 seconds for the valve to be considered operable. For valve closure times shorter than 10.5 seconds, the postulated accident is considered less severe than that analyzed.

Core cooling systems are also verified operable periodically under plant surveillance requirements. Thus, if HPCIS was incapacitated as a consequence of the PBOC, then ADS, LPCI and Core Spray would bc available to redundantly assure safe shutdown of the plant. If all core cooling systems operate as designed and tested, harsh radiation levels will not occur.

Therefore, continued operation is justified.

c -- -----_- _ _ _ - - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - - - - _ _ _ . _ _ _ . _ . _

l EOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. M01301-17 1ER No. 19 Sheet 1 of 1 Preparer:

Aa D' ate : 2/ h l Date: N 8 Independent Review:

Approval: NCkb% i \

Date: R l'17/ 2 4

%)

EQUIPMENT TYPE: DC Motor Operator MANUFACTURER: Limitorque MODEL: SMB-000-5 M01301 -17 operates the outboard isolation valve in the steam supply line to the RCIC pump turbine. The valve is located outside containment in the RCIC piping room (zone 1.10A) and could be exposed to a harsh operating environment during a P81C or a P80C. M01301-17 is automatically signaled open if a low-low reactor vessel level is sensed and is signaled closed if a

- RCIC pipe break is signaled based on high RCIC turbine steam flow or high temperature in the RCIC space.

The valve is normally in the open position.

would be automatically signaled open to admit steam During a PB10, M01001-17However, RCIC operation is not credited in the analysis to the RCIC turbine.

of this transient and therefore M01301-17 need not be qualified to operate during this transient. It should be noted however, that M01001-17 would be capable of opening prior to the development of a harsh radiation environment at the valve.

During a PBOC-4 (RCIC Steam Line Break in the RCIC Valve Station) wouldorbea PBOC-6 (RCIC steam line break in the RCIC Pump Compartment), M01301-17 During a PBOC-4 or exposed to a harsh steam and radiation environment.is intended to automatically close b P80C-6, M01301-17 high steam flow to the RCIC turbine or high temperature in the RCIC space to However, redundant protection would be provided by terminate the accident.

automatic closure of the paired inboard "in containment" valve (1301-16) in response to the same signals.

Neither valve is required to provide a safety function for any other PBOC since RCIC is not credited for any PBOC.

Based on these considerations, continued operation is justified.

iu3e u 5

BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION -

• ?

Equipment Identification No. M01001-47 ,

Sheet 1 of 4 TER Wo. 21 Preparer: b b f D' ate : NTk i Independent Review: b- V Date: 8 24[f4 Approval: N6 x h( t - -*

t~ N Date: RI14/M EQUIPMENT TYPE: DC Motor Operator MANUFACTURER: Limitorque MODEL: SMB-2-40 operates the outboard isolation valve in the line running from the recirculation system to the suctions of the RHR pumps. This line is used to M01001 -47 provide return flow from the reactor vessel during shutdown cooling (SDC) operation. This valve is therefore normally During shut unless SDC is in service.

the initial stages of a The valve provides a dual safety function. _

PBIC or PBOC, the valve is automatically signalled closed to provide -

- containment isolationFollowing based on an indication termination of theof low reactor transient, vessel level or this valve high drywell pressure.

would be opened to facilitate long-term core cooling in the SDC mode of operation of the RHR system. Although the valve was assigned a 30-day mission length, the active function of opening to establish SDC is conservatively estimated to occur within 8-10 hours following the transient.

There is no credible cause for spurious actuation of this valve since all potentially sensitive control components are not expected to be affected by .

the harsh environment. M01001 -47 is equipped with a motor and brake for which only limited qualification documentation is available.

M01001 -47 is located .lside containment at the RHR valve station (zone 1.9A). This area is exposed to a harsh radiation and steam environment during a P80C-7 (main steam line break in the condenser bay), a PBOC-8 (main steam line break Theinarea thewould steam tunnel) also or a PBOC-9 be exposed to solely a (RWCU break at the RHR harsh radiation valve station). However, by procedure SDC would environment during a P81C or any other PBOC.

normally be secured and the valve would merely need to remain in the normally closed position. As a result, the valve would not be required to actively function during the initial most challenging stages of a PBIC or any PBOC In the highly unlikely event that a RWCU line break other than a PBOC-9. would be actuated closed to occurred with SDC in service, (P80C-9) M01001-47However, the latent energy and radiation ,

provide containment isolation.

inventory present in the primary system and core when the break occurred would be significantly less than in the analyzed design P80C-9 event due to the lower temperature / pressure and reacter non-criticality associated with would be SDC operation. As a result, the environment to which M01001-47 exposed during its 30-second closing cycle would be significantly less harsh

=

vage Li BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. M01001-47 TER No. 21 Sheet 2 of 4 Preparer: [1/ @ D' ate : NEf[M Independent Review: SuO Date: Y2 Approval: 1 --n Date: R l'24 / to tv N than in the analyzed case. Based on this, it is our engineering judgement that M01001-47 would be capable of closing without suffering any deleterious effects. In addition, redundant containment isolation would be provided by the inboard isolation valve (1001-50) which has been demonstrated to remain functional for this event.

The only other occasion wherein M01001-47 could be called upon to actively function during exposure to a harsh environment would be during the establishment of SDC approximately 8-10 hours following a PBIC or PBOC. The ability of M01001-47 to remain operable for this function can be demonstrated

. based on the following discussion.

Limitorque Qualification Test Report #B0003 documents the qualification testing of an actuator similar to M01001-47 except that it was equipped with a Peerless AC motor with class "B" insulation rather than a DC motor. The qualification test profile envelops the service profile for all postulated transients af f ecting M01001-47. The results of this report can therefore be used to demonstrate the capability of class "B" insulation to withstand the service exposure estimated for M01001-47.

Limitorque Qualification Report #B0009 documents the qualification testing of an actuator essentially similar to M01001-47 except that it was equipped with a Peerless DC motor with class "H" rather than class "B" insulation. The qualification test profile envelops the service profile for all postulated transients af fecting M01001-47. The results of this report can therefore be used to demonstrate the capability of the Peerless DC commutator and brushes to withstand the estimated service exposure of M01001-47.

M01001-47 is also equipped with a Sterns magnetic brake manufactured with class "A" insulation. Wyle Labs has performed a materials analysis of the brake and has determined that the brake should remain functional if operated under the conditions expected at the RHR valve station during the 8-10 hour post accident time frame wherein establishment of SDC is antif.ipated. This determination is based on the ambient conditions at the time of actuator operation being bounded by the design ratings of the limiting materials and the moisture resistant nature of the brake housing.

BOSTON EDISON COMPANY JUSTIFICATIO!! FOR CONTINUED OPERATION Equipment Identification No. M01001-47 TER No. 21 Sheet 3 of 4 .

Preparer: b - Date: # [

Independent Review: Date: 8!2A!ff Approval: R -m Date: 1Ll'14 / to t X v

Wyle has further determined that all of the brake materials except the Phenolic case on the coil selection switch (which has a threshold of 3.4 x 105 rads) will withstand the estimated exposure of approximately 106 rads, 8-10 hours following a PBIC/PBOC with core damage. However, based on a 25% damage level of 107 rads for this material, and the design of the switch, it is our engineering judgement that this will not impair the operability of the brake. In the unlikely event that the brake did fail and

" lock up", Limitorque has indicated that they believe the valve operator would continue to operate (but at a slower speed) since the brakes are generally designed for the nonnal running torque, which is approximately 20%

of the stall torque of the motor.

There is a potential that M01001-47.could be temporarily submerged during a feedwater line break in the steam tunnel. However, the transient is not deemed credible to occur under conditions wherein SDC would be in operation.

Therefore, M01001-47 will be in its normally closed position during the submergence and will not be called upon to actively function until 8-10 hours In addition, the af ter the temporary submergence has been alleviated.

ability of a somewhat similar operator to actively function while submerged was inadvertently demonstrated when the test' chamber accidentally flooded during qualification testing documented in Limitorque Test Repor'. 600376A.

It is therefore our engineering judgement that this temporary submergence will not impair the ability of M01001-47 to subsequently operate to facilitate establishment of shutdown cooling.

The Wyle Labs has also completed two additional expected life analyses.

first analysis indicated that the most limiting brake materials have an expected life of 120 years based on conditions at the time of expected operation. The second analysis determined that the qualification testing documented in Limitorque Reports 80003/B0009 is more severe than the accident environment to which M01001-47 is exposed.

J

- 4 - - _ . _ . , . _ _._w_,,- - - - _ _ _ . _ . . , . . _ - . _.._,,__,_rm-,_--,,,,,_____,-.,.,_,-.-.,,.----.,_,n - - . _ - - - - -

BOSTON EDISON COMPANY JUSTIFICATION FOR l CONTINUED OPERATION I

Equipment Identification No. M01001-47 Sheet 4 of 4 TER No. 21 h *-; Date: Mar /W PrGparer:

b Date: IfM f Independent Review:

+x, Date: % / 4 /R4

_k Approval: _

i N v

7 Based on these considerations, it is our engineering judgement d that M01001-will remain operable to fulfill its required functions for all postulateIn the highly unli transients resulting in a harsh environment.did not remain operable and prevente that M01001-47 SDC, the RCIC, HPCI or core spray systems could be utilized for coolant makeup while steaming to the torus through the relief valvecould (s) orbepump turbines manually open.

to stabilize plant conditions until such time as M01001-4 justified until a qualified replacement, which has been ordered, can be installed without impacting plant availability.

- - - - ~ _ _ _ _ _ _ _ _ _.

BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment identification No. M01001-28A, M01001-288 TER No. 22a, 17a Sheet 1 of 2 Preparer: [UI M rh Date: k2NY '

Independent Review: Date: M[N Approval: Ih J Date: V[3 /N4-EQUIPMENT TYPE: AC Motor Operator MANUFACTURER: Limitorque MODEL: SMB-5-300 M01001-28A/288 operate the LPCI loop injection throttle globe valves.

M01001-28A is located outside containment in the RHR Valve Room (zone 1.9A) cnd M01001-288 is located outside containment in the RHR/HPCI Piping Room (z:ne 1.108). Both valves are required to be operable (to open if demanded) fcr LPCI during a PBIC/PBOC or to be open for initiation of the RHR System in th2 Shutdown Cooling Mode following termination of several transients.

Op; ration of these valves could be required during exposure to a hazardous Gnvironment as a result of a PBIC or a PBOC. Limitorque report B0003 sunnarizes qualification testing of similar valve operators and motors to a hsrsh steam and radiation environment (250*F, 25 psig and 2 x 107 rad maximum).

During a PBIC, the injection throttle valve for the intact recirculation loop would be required to open and then throttle LPCI for core cooling as well as to be open for shutdown cooling for long term core cooling following tsruination of this transient. The harsh environment exposure would be i li2ited to the integrated radiation exposure over the 30 day mission length which is estimated as being 4.45 x 106 rads and 3.27 x 106 rads for l M01001-28A and M01001-298 respectively. However, component operation will n:t be affected since both operators are qualified to a 2.0 x 107 rad sxposure per Limitorque Report 80003.

During a PBOC-1 (HPCI Steam Line Break in the HPCI Valve Station) M01001-288 would be exposed to a harsh super-heated steam and radiation environment.

However, the service profile for temperature (309'F maximum) only exceeds the The qualification profile (250*F) f rom B0003 for approximately 2 minutes.

thermal inertia of the operator in a superheated steam environment as documented in Limitorque Report 80027, would cause the temperature in the vital portions of the operator and motor to lag sufficiently to be enveloped by the qualification profilc. In addition, both trains of core spray would be available as redundant satisfaction of the core cooling safety function during the transient. SDC could be initiated following termination of the transient using M01001-28A (which would only be subject to a radiation cxposure for which it is qualified) to facilitate SDC Discharge to the A Loop.

l

f BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. M01001-28A, M01001-28B TER No. 22a,17a Sheet 2 of 2 Preparer: N/]he ; Dats: h2 h Independent Review: b Date: [ [4 Approval: M Date: f[3tr/I4 0

During a PBOC-7, 8, or 9 M01001-28A could be exposed to a harsh superheated steam and radiation environment. However, the service profiles for PBOC-7 cnd PBOC-9 are enveloped by the qualification test profiles in B0003 and M01001-28A is therefore qualified for these transients. During a PBOC-8 (main steamline break in the steam tunnel) the service profile for temperature (251.8'F maximum) only exceeds the qualification profile (250*F maximum) for a few seconds. The thermal inertia of the operator in a super-heated steam environment as documented in Limitorque Report B0027, would cause the temperature of the vital portions of the valve operator and

- motor to lag sufficiently to be enveloped by the qualification profile. The qualification profiles for all other variables envelope the associated s:;rvice profiles and M01001-28A will remain operable. In addition, LPCI and SDC could be initiated through M01001-288 in all 3 cases since its harsh cxposure would be limited to a radiation environment for which it is qualified in B0003.

It should also be noted that M01001-28A might be subject to submergence following closure in response to a feedwater line break. However, it is our cngineering judgment that this will not inhibit the ability of the operator to function based on the inadvertent submergence during testing of a similar cperator as documented in Limitorque Qualification Testing Report 600376A.

Based on these considerations, continued operation is justified.

' ~ n.

COSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION

_Eq3ipment Identification No. M01001-29ASheet 1 of 2 _

TER No. 22b Date: _

N Preparer: _

bh _

D _

- Date:

Ind: pendent Review: _ Bl1~7/M Date: _

Approval: QCTkbum Q AC Motor Operator EQUIPMENT TYPE:

MANUFACTURER: Limitorque MODEL: SMB-3-100 for the A Loop. The l tation (zone 1.9A) and M01001-29A operates the downstream LPCI inject ling (SDC) cculd drop.

be exposed to a harsh environment during SDC during a PBlC flow to the A Loop and is normally open. The valve can cutomatically closed if a low reactor vessel llevel switchis at sensed panel cperation to isolate a possible leak from the RHR/SDC system.

be overridden open using a pushbuttor at the operator i lly controThe 903 in the control room.as a result of a harsh environment since all potent a cf M)1001-29A sinsitive control components are mounted in panels 903, control and cable spreading rooms. class HR ii M01001-29A includes a Reliance Electric AC motor (util z ngThe Ding "H" materials as insulation) equipped with a Dings magnetic lbrake.

verified that the brake was built with insulation c assA t r was comparison performed by of the specified by their customer, Reliance Electric. imilar materials used in the brake with those used in the mo oW operators Wyle Labs.cr equivalent to those used in the motor.

judgment that the results of qualification testing "H" motors, a s documented applicable of in Limitorque to equipped with Reliance Class "HR"600198 and Class and 600376A are Limitorque Qualification Test Reports The temperature, pressure and itorque Report N01001-29A including the motor and brake. ll postulated

! humidity qualification testing profiles documented in Lim

/

l 600198 envelop the service profiles fortheM01001-29A 30 day mission for aIn l

transients.

more severe than the service profiles anticipated overThe test dose of 2.0 00376A, more than l length of this component by degradation analysis.

rads gamma as documented in Limitorque Test Report 6f 5.34E6 rad adequately envelops the expected service exposure oThe brak this component.

constructed of the same or equivalent materials as the mo o l

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A .

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BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION l

i Equipment Identification No. M01001-29A TER No. 22b Sheet 2 of 2 Preparer: h Date: Y I Independent Review: Date: N Y Approval: M Date: 8127 / e4

1. \

v continued operation of the brake is justified by similarity. The brake discs, which are constructed of asbestos with a phenolic binder, have a radiation threshold of 1.8E7 rads which envelops the requirement. Beta will be reduced by the shielding effect of the equipment enclosure so that cnalysis concerns are only with the gama dose.

Based on these considerations, ccntinued operation is justified.

_,,s.,..-__.-_c.- ,___,ew,.7 - . . . -

@OSTON EDISON COMPANY l JUSTIFICATION FOR CONTINUED OPERATION  :

Equipment Identification No. M01001-21, M01001-32 TER No. 24, 23 Sheet 1 of 1 l Preparer: b hat 4+ L Date: 7/3r/6 Independent Review: b Date: I 2AfGr'4 Approval: Date: 8/ 30[fM  !

O EQUIPMENT TYPE: DC/AC Motor Operator MANUFACTURER: Limitorque MODEL: SMB-000-5 M01001-21 and M01001-32 operate the series isolation /stop valves in the line for discharging from the RHR System to Radwaste. The valves are normally shut except while the RHR is in torus recirculation mode and draining is in progress. If the valves failed to shut during a LPCI initiation, a portion of the LPCI flow would be diverted to the Radwaste System. The valves could be exposed to a harsh environment during a PBIC or a PBOC. The valves are

- located outside containment in the CRD Pump Room Mezzanine (Zone 1.8).

Limitorque Qualification Test Report #B0003 documents the qualification testing of a valve operator and motor similar in design to M01001-32. The documented test profile envelops the M01001-32 service profile for all transients that are postulated to af fect M01001-32. M01001 -32 is therefore considered to be qualified pending completion of an inspection to verify that i appropriate terminal blocks were utilized for power cable terminations (required by IE Notice 83-72). Inspection of the terminal blocks in the Limitorque operators is in progress. No deficiencies in the terminal blocks have been reported and therefore there is a high degree of assurance that the terminal blocks in this motor operator are qualified. Since isolation is the only safety function provided by M01001-21 and M01001-32, redundant protection for any postulated failure of M01001-21 would be provided by M01001 -32. Continued operation is therefore justified.

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Yage 00 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. M01301-25, M01301-26 TER No. 26, 25 Sheet 1 of 1 Preparer: kb Date: /W Independent Review: _- Date: 3/ W Approval: Date: 9!7 p -

i .

\J EQUIPMENT TYPE: DC Motor Operator MANUFACTURER: Limitorque MODEL: SMB-000-2 M01301-25 and M01301-26 operate the block / isolation valves in the torus suction supply line to the RCIC turbine. These valves are located in the RCIC pump room mezzanine (zone 1.5) and are normally closed. The valves are to be remotely opened from the control room if low condensate storage level or high torus suppression pool level it sensed.

M01301-25 and M01301-26 can serve a containment isolation function during a PBOC or a PBIC. However, in both cases the valves are not required to actively function since they will be maintained in their normally closed position. Subsequent spurious opening of either valve is not deemed credible since all potentially sensitive control components are located in mild environments.

The only transient for which RCIC is credited and M01301-25/26 are required l

to open is a Control Rod Drop. RCIC is used following a Control Rod Drop to l

supply core cooling while depressurizing. The Control Rod Drop transient has l

been evaluated and it has been determined that no RCIC components are exposed l

to conditions different from those during normal RCIC operation. Continued operation is therefore justified.

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BOSTON EDISON COMPANY

, JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification Nu. M02301-10 TER No. 27 Sheet 1 of a Preparer: bbw Date: f/1k Independent Review:

Date: li Approval: -

Date: Tf10 (3

EQUIPMENT TYPE: DC Motor Operator ,

MANUFACTURER: Limitorque MODEL: SMB-2-80 This valve provides flow from the discharge of HPCIS pump P205 to the condensate storage tanks for full flow testing of the HPCIS. Because the valve is required to open for testing only, it normally remains closed during plant operation. The opening function is not safety-related. However, if the valve is opened for testing, it must close on HPCI initiation to assure adequate cooling flow to the core. Since this is its only safety-related function, operation of M02301-10 is required solely to assure satisfactory HPCIS operation.

The HPCIS is relied upon to operate during and following Loss of Feedwater Flow, t Total Loss of Offsite Power, Shutdown from Outside Control Room (Special Event),

Pipe Break Inside Primary Containment, Centrol Rod Drop Accident, and Pioe Break Outside Primary Containment to assure continued core cooling, and thus mitigate consequences which could result in potential of fsite exposures comparable to the 10CFR100 guidelines.

None of the first three events listed above is expected to result in environmental conditions any more severe than those experienced during normal operation. The fourth event is addressed in the HPCIS Safety Evaluation, which states that, "The HPCIS is designed to provide adequate core cooling for small breaks... core never uncovers and is continuously cooled throughout the transient so that no core damage of any kind occurs for breaks that lie within the range of the HPCI." Thus, the size of LOCA presumed to generate postulated core damage is beyond the capacity of HPCIS to provide core cooling.

The Control Rod Drop Accident has been evaluated and no HPCIS equipment will be subjected to pressure, temperature, radiation or humidity conditions any more severe than those experienced during normal operation.

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BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. M02301-10 TER No. 27 Sheet 2 of a Preparer: Date: h/k Date: li Independent Review: ~

Approval: h Date: i[ f'/

A v

Those pipe breaks outside containment which could be expected to result in harsh conditions of pressure, temperature and humidity in the vicinity of M02301-10 are the P80C-3 and the PB0C-5. Each of these events, however, incapacitates the HPCIS. System operability is, therefore, not required for oither PBOC.

On the other hand, system operability is required for the main steam line breaks, PBOC-7 and PBOC-8. However, FSAR analysis of the PNPS design basis Main Steam Line Break Accident indicates that, with a maximum 10.5 second MSIV closure and continued core coverage (from normal or standby systems,

. including HPCIS), there would be no fuel damage. Without core damage, exposures will not exceed 104 rads.

MSiv closure time is verified once per quarter under Technical Specification surveillance requirements. The closure time must be greater than 3 seconds and less than 5 seconds for the valve to be considered operable. For valve closure times shorter than 10.5 seconds, the postulated accident is considered less severe than that analyzed.

Core cooling systems are also verified operable periodically under plant surveillance requirements. Thus, if HPCIS was incapacitated as a consequence

! of the P80C, then ADS, LPCI and Core Spray would be available to redundantly assure safe shutdown of the plant. If all core cooling systems operate as designed and tested, harsh radiation levels will not occur.

l Therefore, continued operation is justified.

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BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment identification No. M02301-3 TER No. 28a Sheet 1 of 1 Preparer: h/Ib Date: 9/th Independent Review: [- Date: 2A!74 Approval: 'l Date: ff3o[f 4 r\

v EQUIPMENT TYPE: DC Motor Operator MANUFACTURER: Limitorque MODEL: SMB-1-60 M02301-3 operates the block valve in the steam supply line to the HPCI turbine. The valve is located in the HPCI pump room (zone 1.3) and is normally closed unless HPCI is in operation. During a transient requiring HPCI operation, the valves function is to open and remain open over a 5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> tission time to supply steam to the HPCI pump turbine.

~

The FSAR Section 6.5.1.2.2 Safety Evaluation of the HPCI System, describes the system as one " designed to provide adequate reactor core cooling for small breaks." On this premise, a detailed analysis concluded that the " core never uncovers and is continuously cooled throughout the transient so that no core damage of any kind occurs for breaks that lie within the range of the HPCI system." Based on the prevention of core damage for those small break P81C events requiring HPCI operation, those components that are essential to HPCIS operations, such as M02301-3, will not be exposed to radiation during such transients in excess of levels occurring during normal operation and therefore need not be qualified for such small break PBIC transients, i

During a P80C-3 (HPCI Steam Line Break in the HPCI Pump Station) M02301-3 would be exposed to a harsh steam and radiation environment. However, HPCI operation is not required for this transient. Instead, isolation of the leak would be accomplished by automatic closure of valve 2301-4.

During any other PBOC, HPCI would be required to operate for core cooling following isolation of the leak. However, the valve would be capable of s

opening prior to the exposure reaching narsh levels. The valve would remain in the desired open position since potentially sensitive control components would not be affected by the harsh environment.

Based on these considerations, continued operation is justified.

i

Pdge 49 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. M02301-9 TER No. 28b Sheet 1 of 2 Preparer: - Date: 9///8f' Independent Review:

Date: 7fi Approval: -

Mg ,

Date: T.[Eo!N, v

EQUIPMENT TYPE: DC Motor Operator MANUFACTURER: Limitorque MODEL: SMB-1-60 This valve provides the first isolation on the discharge of HPCIS pump P205.

The valve is normally maintained open and closure is only accomplished through a remote manual switch in the Main Control Room (C-903). Because containment and reactor vessel isolation is provided by valves 588 (feedwater line '8") and M02301-8, the closing function of M02301-9 is not safety-related. However, if the valve is closed, it must open on HPCI initiation to assure adequate cooling flow to the core. Since this is its only safety- related function, operation of M02301-9 is required solely to assure satisfactory HPCIS operation.

The HPCIS is relied upon to operate during and following Loss of Feedwater Flow, Total Loss of Offsite Power, Shutdcwn from Outside Control Room (Special Event),

Pipe Break Inside Primary Containment, Control Rod Drop Accident, and Pipe Break Outside Primary Containment to assure continued core cooling, and thus mitigate consequences which could result in potential of fsite exposures comparable to the 10CFR100 guidelines.

None of the first three events listed above is expected to result in environmental conditions any more severe than those experienced during normal operation. The fourth event is addressed in the HPCIS Safety Evaluation, which states that, "The HPCIS is designed to provide adequate core cooling for small breaks... core never uncovers and is continuously cooled throughout the transient so that no core damage of any kind occurs for breaks that lie within the range of the HPCI." Thus, the size of LOCA presumed to generate postulated core damage is beyond the capacity of HPCIS to provide core cooling.

BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. M02301-9 TER No. 28b Sheet 2 of 2 Preparer: br Date: YNM Independent Review:

Date: li Approval: M Date: Tfu . .

n The Control Rod Drop Accident has been evaluated and no HPCIS equipment will be subjected to pressure, temperature, radiation or humidity conditions any more severe than those experienced during normal operation.

Those pipe breaks outside containment which could be expected to result in harsh conditions of pressure, temperature and humidity in the vicinity of M02301-9 are the PBOC-3 and the P80C-5. Each of these events, however, incapacitates the HPCIS, System operability is, therefore, not required for either PBOC.

On the other hand, system operability is required for the main steam line breaks, PBOC-7 and PBOC-8. However, FSAR analysis of the PNPS design basis Main Steam Line 8reak Accident indicates that, with a maximum 10.5 second MSIV closure and continued core coverage (from normal or standby systems, including HPCIS), there would be no fuel damage. Without core damage, exposures will not exceed 10 4 rads.

MSIV closure time is verified once per quarter under Technical Specification surveillance requirements. The closure ti.ne must be greater than 3 seconds and less than 5 seconds for the valve to te considered operable, foi valve i closure times shorter than 10.5 seconds, the postulated accident is considered less severe than that analyzed.

Core cooling systems are also verified operable periodically under plant surveillance requirements. Thus, if HPCIS was incapacitated as a consequence of the P80C, then ADS, LPCI and Core Spray would be available to redundantly assure safe shutdown of the plant. If all core cooling systems operate as designed and tested, harsh radiation levels will not occur.

Therefore, continued operation is justified.

t i

. _ , - - . _ . . - . _ _ _ . _..r_. , _ _ , . _ _ . _ , , ,_ _ _ , . - _ _ , . . _ _ . . , __,_-.__._____,_m. _ _ - ..-.. , _ -. _ _._ _.,_-. _ .

BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPFRATION Equipment Identification No, M02301-14 TER No. 29 Sheet 1 of a Preparer: k6= - Date: h/d/

Independent Review: Date: 77 Approval: M Date: #I !20 ffV -

n v

EQUIPMENT TYPE: DC Motor Operator MANUFACTURER: Limitorque MODEL: SMB-0-25 On HPCIS startup, pump P205 discharge is inadequate to defeat the effect of 4

reactor backpressure on the injection check valves. To assure safety of the pump, a flow path is provided from the discharge line to the suppression pool. This line is then automatically isolated when flow to the core is verified by an in-line sensing device. M02301-14 provides both the initiation and isolation of minimum flow b, pass. The valve must open on a HPCIS initiation coincident with a low flow signal and must close on either a turbine trip or a high flow signal. Based on the functions of this valve, cperation of M02301-14 is required solely to assure satisfactory HPCIS cperation.

The HPCIS is relied upon to operate during and following Loss of Feedwater Flow,

' Total Loss of Offsite Power, Shutdown from Outside Control Room (Special Event),

Pipe Break Inside Primary Containment, i

! Control Rod Drop Accident, and Pipe Break Outside Primary Containment to assure continued core cooling, and thus mitigate consequences which could l result in potential of fsite exposures comparable to the 10CFR100 guidelines.

I None of the first three events listed above is expected to result in environmental conditions any more severe than these experienced during normal cperation. The fourth event is addressed in the HPCIS Safety Evaluation, which states that, "The HPCIS is designed to' provide adequate core cooling for small breaks... core never uncovers and is continuously cooled throughout N transient so that no core damage of any kind occurs for breaks that lie

_ _:.in the range of the HPCI. Thus, the size of LOCA presumed to generate postulated core damage is beyond the capacity of HPCIS to provide core cooling.

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d Page 42 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION ,

Equipmer.t Identification No. M02301-14 TER No. 29 Sheet 2 of 2 Preparer: ib[/~ -

Date: f/#M Independent Review: Date: 7 li Approval: MU Date: N2e/gy The Contr'olLRod Drop Accident has been evaluated and no HPCIS equipment will

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be. subjected to pressure, temperature, radiation or humidity conditions any more severe than those experienced during normal operation.

Those pipe breaks outside containment which could be expected to result in harsh conditions of pressure, temperature and humidity in the vicinity of M02301-14 are the PBOC-3 and the PBOC-5. Each of these events, however, incapacitates the HPCIS. System operability is, therefore, not required for either PBOC.

On the other ha'id, system operability is required for the main steam line breaks, PBOC-7 and PBOC-8. However, FSAR analysis of the PNPS design basis Main Steam Line Breal Accident indicates that, with a maximum 10.5 second MSIV closure and centinued core coverage (from normal or standby systems, including HPCIS), there would be no fuel damage. Without core damage,

, exposures will not exceed 10 4 rads.

J MSIY closure time is verified once per quarter under Technical Specification surveillance requirements. The closure time must be greater than 3 seconds and less than 5 seconds for the valve to be considered operable. For valve closure ttines shorter than 10.5 seconds, the postulated accident is considered:less severe than that analyzed.

Core cooling systems are also verified operable periodically under plant surveillance requirements. Thus, if HPCIS was incapacitated as a consequence of the F'80C, then ADS, LPCI and Core Spray would be available to redundantly assure safe shutdown of the plant. If all core cooling systems operate as designed and tested,' harsh radiation levels will not occur.

-Therefore, conti nued operation is justified.

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l BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. M02301-35, M02301-36 TER No. 31, 30 Sheet 1 of 2 .

Preparer: ;M Date: P'/W /W Independent Review:

Date: D Approval: G C i b --- Date: 3/27/24

.\

v EQUIPMENT TYPE: DC Motor Operator MANUFACTURER: Limitorque MODEL: SMB-0-25/SMB-00-7. 5 M02301-35 and M02301-36 operate the block / isolation valves in the line from the Suppression Pool to the HPCI Pump Suction. These valves are located outside containment in the HPCI Pump Room (zone 1.3) and are normally closed. These valves will automatically or a to supply torus water to the HPCI pumps if low condenser storage tank level or high torus water level is sensed. The valves are overridden closed in the event a HPCI Steam Line Break is sensed. All potentially sensitive control components are located in mild environments.

FSAR Section 6.5.1.2.2, Safety Evaluation for the HPCI, describes the HPCI System as one " designed to provide adequate reactor core cooling for small breaks.' On this premise, a detailed analysis concluded that the " core never uncovers and is continuously cooled throughout the transient so that no core damage of any kind occurs for breaks that lie within the range of the HPCI."

Based on the fact that no core damage results from those events for which HPCI operation is essential, components such as M02301-35 and M02301-36, which are considered essential to HPCI operation will not be exposed to radiation in excess of the levels experienced during normal operation. As a result, capability of these components to facilitate HPCI operation while exposed to a harsh environment need not be demonstrated.

However, M02301-35 and M02301-36 provide a second safety function of closing to provide containment isolation during a PBOC-3 (HPCI Steam Line Break in the rtPCI Pump Compartment) while exposed to a harsh environment as a result of blowt m from the break. If the break occurs with both valves in their normal closed position, both valves will remain closed and this design function will be accomplished.If the break occurs while both valves are open, then M02301-35 which is equipped with a rewound motor is assumed to fail as is (open). However, an operator and motor combination similar to M02301-36 was qualified to a maximum of 250*F, 25 psig and 2 x 107 rads as documented in Limitorque Report B0003. Although the service profile (30l*F and 16.2 psia maximum) is not enveloped by the qualification profile over the first five minutes, the thermal inertia of the operator in the superheated steam

Page 44 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION a

Equipment identification No. M02301-35, M02301-36 Sheet 2 of 2 TER No. 31, 30 Date: MSV/49 '

Preparer:

Date: M Independent Review:

Date: E/2.~7/E4 Approval: @l \j cnvironment, as documented in Limitorque Report B0027, will result in temperature in the vital portions of the actuator The radiationand exposure motor, thatnot would would be gnveloped by the qualification profile.

impact the ability of the component to operate until well af ter it hadwould.close t closed. It can therefore be assumed that M02301-36 ccntainment isolation.

Based on these considerations, continued operation is justified.

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Page 45 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. M04010A/B, M04060A/B TER No. 33, 38 Sheet 1 of f Preparer: h '% Date: jbb independent Review: Date:

Approval: C3LCA Date:  % /27/%

i N v

EQUIPMENT TYPE: AC Motor Operator MANUFACTURER: Limitorque MODEL: SMB-00 i

l M04010A/B and M04060A/B operate block valves in parallel paths supplying RBCCW to the "B" and "A" RHR heat exchangers respectively.

These valves are located outside containment in their respective RHR/ Core Spray Pump Quadrants (zones 1.1 and 1.2) and are normally closed. The control room operator is expected to open at least one of the valves associated with each RHR heat

~

exchanger approximately 10 minutes into a design basis transient. RBCCW is supplied via these valves to the RHR System in either the LPCI, torus recirculation or shutdown cooling modes and, as a result, the valves operators have a 30 day mission time. Similar valve operator and motors were qualified for extended exposure to a steam environment (250*F and 25 psig maximum) and to radiation (2 x 107 rads) and documented in Limitorque Report 80003. M04010A/B and M04060A/B are therefore considered to be qualified to the profiles used in the B0003 tests pending completion of an inspection to verify that appropriate terminal blocks were utilized for terminating power leaks (required by IE notice 83-72).

During a PBIC, the only potential cause for a harsh environment exposure to these valves would be increased radiation. However, analysis has shown that the valves would not be exposed to radiation in excess of the qualified level i

until af ter their 30 day mission time had elapsed and therefore, these valves would be operable when required and are considered qualified for P81C.

During a PBOC-5 (HPCI Steam Line Break in the Torus Compartment) M04010A/B and M04060A/B would be exposed to a harsh steam and radiation environment.

However, the qualification test profile per B0003 envelopes the service profile and the component is considered to be qualified for PBOC.

Since M04010A/B and M04060A/B will remain operable over their design mission length for all possible harsh environment exposures, continued operation is justified.

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Page 46 l BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION i

)

Equipment Identification No. M01400-4A, M01400-4B TER No. 39, 36 Sheet 1 of 1 1 l

Preparer: (1) W Vate: WTVh/

Independent Review: Date: 19ff4 Approval: Date: T/3 fd

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v EQUIPMENT TYPE: AC Motor Operator MANUFACTURER: Limitorque MODEL: SMB-00-15 M01400-4A and M01400-4B operate isolation valves in the core spray test lines that run from the discharge of the core spray pumps to the torus. The valves are located outside containment within their respective RHR and core spray quadrants (zones 1.1 and 1.2). The valves are required to close when containment spray is initiated. The valves are exposed to a harsh steam and

- radiation environment during a PB0C~-5 (HPCI Steam Line Break in the Torus Compartment) and/or to a harsh radiation environment during a PBIC and all other PBOCs. Limitorque Report B0003 uocuments the qualification testing of a similar valve operator and motor in a harsh steam and radiation environment which envelopes the service environment to which these valves are exposed for all postulated transients including a PBOC-5. M01400-4A/4B are therefore considered to be qualified pending completion of an inspection to verify that appropriate terminal blocks were used for power cable termination (required by IE Notice 83-72). Inspection of the termir.al blocks in the Limitorque operators is in progress. No deficiencies in the terminal blocks have been reported and therefore there is a high degree of assurance that the terminal blocks in this motor operator are qualified. Continued operation is therefore justified.

Page 47 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment identification No. M01001-36A, M01001-36B, M01001-37A, M01001-37B TER No. 40a, 32, 40j, 37f Sheet 1 of 1 Preparer: Mb Date: N K. b l Independent Review: b MA Date: 2'kN Approval: Date: '

/30/fd

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l EQUIPMENT TYPE: AC Motor Operator MANUFACTURER: Limitorque MODEL: SMB-2/SMB-00 M01001-36A and M01001-36B control the block valves in the RHR injection line to the suppression pool cooling spray header. M01001-37A and M01001-378 ,

control the block valves in the RHR injection line for suppression pool cooling. All valves are located outside containment in their respective RHR train quadrants (zones 1.1 and 1.2). All four valves are normally shut but would be required to open to initiate torus spray or torus recirculation cooling, as required, during a PBOC or PBIC. The valves have a 30 day mission time. All four valves could be exposed to a harsh steam and radiation environment during a PBOC-5 (HPCI Steam Line Break in the Torus Compartment) or to a harsh radiation environment during a PBIC or all other PBOCs. Limitorque Report B0003 documents the qualification testing of a similar valve operator and motor in a harsh steam and radiation environment that envelopes the service profile for all four valves for all postulated transients including PB0C-5. M01001-36A/36B and M01001-37A/378 are therefore considered to be qualified, pending completion of an inspection to verify i that appropriate terminal blocks were used for power lead termination (required by IE Notice 83-72). Inspection of the terminal blocks in the

! J Limitorque operators is in progress. No deficiencies in the terminal blocks l

have been reported and therefore there is a high degree of assurance that the teminal blocks in this motor operator are qualified. Continued operation is therefore justified.

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Page 48 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment identification No. M01400-3A, M01400-3B TER No. 40b, 37g Sheet 1 of 1 Preparer: /2/ M D' ate :

I. b b, Independent Review: kl.b, Date: 8 T!f4 Approval: ,

2 Date: f/30/8M n

EQUIPMENT TYPE: AC Motor Operator MANUFACTURER: Limitorque MODEL: SMB-0-15 M01400-3A and M01400-3B operate the isolation valves in the core spray suction lines from the suppression pool. The valves are located outside containment within their respective RHR and core spray quadrants (zones 1.1 and 1.2). The valves are required to remain functional over a 30 day mission time to facilitate core spray system operation during a PBIC or a PBOC. The valves are exposed to a harsh steam and radiation environment during a PBOC-5 (HPCI Steam Line Break in the Torus Compartment) and/or to a harsh radiation environment during a PBIC and all other PBOCs. Limitorque Report B0003 documents the qualification testing of a similar valve operator and motor in a harsh steam and radiation environment which envelopes the service environment to which these valves are exposed for all postulated transients including a PBOC-5. M01400-3A/3B are therefore considered to be qualified pending completion of an inspection to verify that appropriate terminal blocks were used for power cable termination (required by IE Notice B3-72).

Inspection of the terminal blocks in the Limitorque operators is in progress. No deficiencies in the terminal blocks have been reported and therefore there is a Hgh degree of assurance that the terminal blocks in this motor operator are qualified. Continued operation is therefore justified.

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Page 49 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. M01001-7A, M01001-78, M01001-7C, M01001-70 TER No. 40c, 37a, 40d, 37b Sheet 1 of 2 .

Preparer: Sl/lb /

Date': k2MY Independent Review: Date: ff24h4 Approval; / U Date: /3D[N '

/\

- v EQUIPMENT TYPE: AC Motor Opcrator MANUFACTURER: Limitorque MODEL: SMB-0-15 Th2se motor operators are installed on the RHR Pump Suction Block Valves for RHR suction from the torus. These valves are nornelly key-locked open except during Shutdown Cooling (SDC) Operation. The valves are located outside centainment in the RHR Pump Quadrants (zones 1.1 and 1.2), and could be

- cxposed to a harsh environment during a large break PBIC or PBOC. Spurious operation of the valve is not deemed credible since all potentially sensitive control components are not affected. These valves could be exposed to a h:rsh steam and radiation environment during a PB0C-5 (HPCI Steam Line Break in the Torus) or to a harsh radiation environment following a large break PBIC or any PBOC. Limitorque Report B0003 documents qualification testing of a valve operator and motor similar to M01001-7(B-D) which envelops the scryice exposure to these valve operators for any postulated transient.

M01001-7(B-D) are therefore considered to be qualified pending completion of an inspection to verify that appropriate terminal blocks were utilized for power lead termination (required by IE Notice 83-72). Inspection of the tcrainal blocks in the Limitorque operators is in progress. No deficiencies in the terminal blocks have been reported and therefore there is a high d: gree of assurance that the terminal blocks in this motor operator are qualified. M01001-7A is equipped with a Reliance Electric motor that was

. rewound by GE at their Apparatus Service Shop in Medford MA. GE provided a l Cortificate of Confornance that the motor was rewound in the same manner as was found upon receipt inspection at their facility. The motor is therefore Gquipped with the equivalent of the Class B insulation used during original manufacture and is essentially similar to the other motors and the qualification testing documented in Limitorque Report B0003 therefore cpplies. Although the test profile was only for 16 days, a degradation cnalysis has established that the test was more severe than the 30 day

~oission life exposure. In addition to this technical analysis, the following systematic analysis justifies continued operation with M01001-7A as is.

l During a large break PBIC from nornal operating temperature and pressure,

! with shutdown cooling not in service, M01001-7( A-D) would be expected to remain open to supply torus suction to the RHR pumps in LPCI mode. Since the f - __

Page 50 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION  :

a Equipment Identification No. M01001-7A, M01001-78, M01001-7C, M01001-7D TER No. 40c, 37a, 40d, 37b Sheet 2 of 2 Preparer: /A/ [A f+ Date: kFf IndIpendent Review: h Date: N24 [f"4 Approval: .

Date: 30/fi t v In valves would already be open, no active function would be required.

cddition, since there is no credible means for spurious closure, and since ccre spray cculd provide redundant protection, exposure to a harshThe valves would cnvironment during this transient would be inconsequential.

remain in the open position to facilitate long term core cooling by LPCI and drainage from the pipe break to the torus.

During an intermediate or small break PBIC from normal operating temperature

' cr pressure, ADS, HPCI or RCIC would actuate to depressurize the reactor v2ssel without core damage. M01001-7(A-D) would either remain in the open p:sition to provide LPCI following ADS operation or to support torus racirculation cooling. However, since core damage would not occur these valves would not be exposed to a harsh environment and would remain operable.

During a P81C of any size during SDC operation (with the lower temperatures and pressures and reactor sub-criticality necessary to support SDC operation),

tha environment to which M01001-7(A-D) would be exposed would be significantly less harsh and would allow sufficient time for the valves to be cpened to provide LPCI. In addition, core spray would be used to provide

redundant assurance of core cooling.

During a P80C-5 (HPCI Steam Line Break in the Torus), M01001-7(A-D) could be

, If the plant was at normal temperature and '

L Gxposed to a harsh environment.

pressure, the valves would be expected to remain open to support LPCI from the torus. IF SDC was in service, the HPCI SteamInLine the would be isolated due event that M01001-7A to low pressure thus prohibiting the transient.

cculd not be closed following termination of LPCI, long term core cooling ceuld be provided following termination of the transient using train 8 of the RHR System.

Based on these considerations, continued operation is justified.

t

--<--e m . .m e e.----------4,,,-,,wm.y.,--.-,-w-,-,e,%.,-,,v,we-,,-,-ce,- ,_~ ~.,,w- .---m,'

Page 51 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. M01001-43(A-D)

TER No. 40f, 37c, 40e, 37d Sheet 1 of 1 Preparer: M r -I Date: 2V h Independent Review: Date: D Approval: OC Date: 31"/M

, N v

EQUIPMENT TYPE: AC Motor Operator MANUFACTURER: Limitorque MODEL: SMB-0-15 M01001-43(A-D) operate the RHR Pump Shutdown Cooling (SDC) Block Valves.

These valves are normally closed unless SDC is in operation. The valves are located in their respective Core Spray /RHR pump rooms (zones 1.1 and 1.2).

Limitorque Report B0003 documents qualification testing of a valve operator and motor similar to M01001-43(B-D) for a steam and radiation environment that envelops the exposure of M01001-43(B-0) for all postulated transients.

M01001-43(B-D) are therefore considered to be qualified pending an inspection to verify that appropriate terminal blocks were used for termination of the power leads (required by IE Notice 83-72). M01001-43A is equipped with a Reliance Electric motor that was rewound by GE at their Apparatus Service Shop in Medford, MA. GE provided a certificate of conformance that the motor was rewound in the same manner as was found upon receipt inspection at their facility. The motor is therefore equipped with the equivilent of the class "B" insulation used during original manufacture and is essentially similar to the other motors and the qualification testing documented in Limitorque hvurt ::0003 therefore applies. Although the test profile was only for 16 days, a degradation analysis established that the test was more severe than the 30 day mission life exposure.

Based on these considerations, continued operation is justified.

l

Page 52 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment identification No. M01001-16A, M01001-16B TER No. 409, 37e Sheet 1 of 1 Preparer: he m__ Date: kE/ /7 f

Independent Review: Mh Date: Pf2.9fN Approval: / Date: N

(\~

EQUIPMENT TYPE: AC Motor Operator MANUFAClVRER: Limitorque MODEL: SMB-2 M01001-16A and M01001-16B operate the RHR heat exchanger bypass valves.

These valves are located in their respective RHR pump quadrants (zones 1.1 and 1.2). The valves are normaily closed except while operating RHR in the shutdown cooling (SDC) mode. During SDC operation, these valves are in a throttled-open position to control reactor vessel temperature. During a LPCI

- initiation, both valves will be signaled open following a 60 second delay in order to maximize injection flow and control vessel cooldown. These valves are exposed to a harsh steam and radiation environment during a PBOC-5 (HPCI Steam Line Break in the Torus Compartment) or to solely a harsh radiation environment during a PBIC and all other PBOCs. The valves are required to remain functional for a 30 day mission length to facilitate LPCI flow and SDC temperature control. Limitorque Report B0003 documents the qualification of a similar operator and motor in a harsh steam and radiation environment that envelopes the service profile for both valve operators for PBIC and all PBOCs including PBOC-5. M01001-16A and M01001-168 are therefore considered to be qualified pending completion of an inspection to verify .1at appropriate terminal blocks were used for power lea, termination as required by IE Notice 83-72. Inspection of the terminal blocks in the Limitorque operators is in progress. No deficiencies in the terminal blocks hive been reported and therefore there is a high degree of assurance that tie terminal blocks in this motor operator are qualified. Continued operat on is therefore justified.

Page 53 BOSTON EDISON COMPANY JUSTIFICATION'FOR CONTINUED OPERATION Equipment identification No. M01001-18A, M01001-188 TER No. 40h, 35 Sheet 1 of 1 Preparer: ///2 Date: bdW Independent Review: 04fAa- Date: frf24[#4 Approval:  ! Date: '

/offY

(\

EQUIPMENT TYPE: AC Motor Operator MANUFACTURER: Limitorque MODEL: SM8-0/SMB-000 M01001-18A and M01001-18B operate the block valves in the minimum flow recirculation lines from the combined RHR pump discharge to the torus. The valves are designed to open upon sensing low flow from the pumps to prevt.nt pump overheating and to close as RHR flow approaches 20% of rated LPCI flow in either injection line to ensure adequate delivery of LPCI during a

- P81C/P80C. The valves must remain operable for at least a 30 day mission length to provide overheating protection for the RHR pumps. The valves are located in their respective RHR quadrants (zones 1.1,1.2) and could be exposed to a harsh steam and radiation environment during a PBOC-5 (HPCI Steam Line 8reak in the Torus Compartment) and/or to solely a harsh radiation environment during a P81C and all other PB0C's. Limitorque Report 80003 documents the qualification of a similar motor and operator in a harsh steam and radiation environment that envelopes the service profile for all postulated transients affecting either valve including PBOC-5.

M01001-18A/188 are therefore considered to be qualified pending completion of an inspection to verify that appropriate terminal blocks were used for power lead termination as required by IE Notice 83-72. Inspection of the terminal blocks in the Limitorque operators is in progress. No deficiencies in the terminal blocks have been reported and therefore there is a high degree of assurance that the terminal blocis in this motor operator are qualified.

Continued operation is therefore justified.

Page 54 BOSTON EDISON COMPANY

-JUSTIFICATION FOR CONTINUED OPERATION Equipment identification No. M01001-34A, M01001-34B TER No. 401, 34 Sheet 1 of 2 .

Preparer: bea Date: MM Independent Review:

Date:

Ydh- r m Date: 8(27 / RG Approval: __

i\

w EQUIPMEN1 TYPE: AC Motor Operator MANUFACTURER: Limitorque MODEL: SMB-00/SMB-00-25 M01001-34A and 348 operate the torus cooling / torus spray line block valves.

These valves are normally closed unless RHR is in operation in the torus cooling mode. The valves are located outside containment in their respective RHR and core spray pump rooms (zones 1.1 and 1.2). Limitorque Test Report 80003 documents qualification testing of a valve operator and motor similar to M01001-34A for exposure to a harsh steam and radiation environment which cnvelops the expected service profiles for all postulated transients affecting M01001-34A. M01001-34A is therefore considered qualified pending completion of an inspection to verify that appropriate terminal blocks were utilized for terminating the power leads (required by IE Notice 83-72). The A train of RHR could therefore provide adequate assurance of the operability cf torus cooling spray regardless of the operability of M01001-348 and the B train of torus cooling spray. However, the performance of M01001-348 can be further justified using the following systematic analysis. M01001-348 is equipped with a Peerless AC motor with class B insulation for which limited qualification data is available.

During a large break PBIC or a small break followed by ADS operation, M01001-34A/34B would be initially required to close to prevent diversion of LPCI to the torus. This would normally be accor .shed by assured

, can be the valvessince all remaining in their normally closed position. T potentially sensitive control components would not be affected by a harsh environment. If the valves were in the open position at the start of the trans hnt, they would be automatically closed in response to low reactor vesses level and high drywell pressure signals prior to a harsh radiation environment developing at their locations. The valves would then remain closed to support initiation of normal shutdown cooling (SDC) following termination of the transient or to facilitate SDC by LPCI or core spray and drainage through the break location. If torus cooling / core spray was required, M01001-34A which is qualified as documented in Limitorque Report 80003 to 2 x 107 rads, would remain operable for a period in excess of 150 days and could be used for torus recirculation / spray via the A RHR Loop.

Page 55 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION f

Equipment Identification No. M01001-34A, M01001-34B TER No. 401, 34 Sheet 2 of 2 Preparer: h kh- Date: 4 Independent Review:

Date: N

[h Date: t /T7 [86 Approval:

( \

v During a small break LOCA for which HPCI or ADS is used to depressurize the reactor, M01001-34A/34B would initially be required to be closed for the LPCI mode operation of RHR and then to subsequently open for torus cooling / spray.

However, such breaks do not result in core damage and as a result, M01001-34A/34B would not be exposed to a harsh environment.

During a PBOC-5 (HPCI Steam Line Break in the torus compartment)However, M01001-34A/34B would be exposed to a harsh environment.

qualification testing profiles for M01001-34A as documented in B0003 envelops

- the service profiles for all parameters and M01001-34A is therefore qualified as discussed previously and will function as required. If M01001-348 failed in the open position, redundant isolation of the 8 Loop torus spray and circulation lines could be provided by M01001-368 and M01001-378 which are qualified for the PBOC-5 service profile since their qualification testing per B0003 is bounding. If M01001-34B f ailed closed, torus cooling / spray could be provided as required using the A RHR train. .

Based on these considerations, continued operation is justified.

Page 55 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. M01301-60 TER No. 41 Sheet 1 of 1 Preparer: Date: M Independent Review:

U Date: 8ZT/N i i Approval: , , M m /a

~

Date: I!38ffY, 3-v EQUIPMENT TYPE: DC Motor Operator MANUFACTURER: Limitorque MODEL: SMB-00-15 M01301-60 operates the block valve in the minimum flow bypass line frcm the RCIC pump to the torus. This valve is normally closed except momentarily during RCIC pump startup and during periods of RCIC pump operation at low flow rates. The valve is located in the RCIC pump mezzanine (zone 1.5) and must remain operable to ensure proper operation of the RCIC System.

M01301-60 serves a containment isolation function by manually closing from the control room during a PBlc or PBOC. During a PBIC, M01301-60 would be capable of closing prior to a harsh environment exposure occurring. In the event that M01301-60 was not closed prior to a harsh environment exposure during a PBIC or during a PBOC, redundant isolation would be provided by valve 1301-47.

Based on the above information, continued plant operation is justified;

+ ,- , - -

-9rs, 3 BOSTON EDISON COMPANY j JUSTIFICATION FOR l l

CONTINUED OPERATION 1

Equipment Identification ^No. SV2300-9 TER No. 42 Sheet 1 of 2 WM//

~

Preparer: he Date:

Independent Review:

Date: /7 Approval: lSemh Date: 3/E0 b

~

n v

EQUIPMENT TYPE: Solenoid Valve MANUFACTURER: Skinner MODEL: L2DB5150 The HPCIS turbine is automatically shutdown by tripping the turbine stop valve closed on any of several signals. This closure is accomplished by energizing SV2300-9 and thus relieving hydraulic pressure from the stop valve actuator. Failure of the solenoid valve to operate on demand could lead to damage of the turbine or pump while inadvertent operation could threaten the ability of HPCIS to provide adequate core cooling. Based on the functions of this valve, operation of SV2300-9 is required to assure either HPCIS cquipment protection or continued satisfactory system operation.

The HPCIS is relied upon to operate during and following Loss of Feedwater Flow, Total Loss of Offsite Puer, Shutdown f rom Outsic'a Control Room (Special Event),

Pipe Break Inside Primary Containment, Control Rod Drop Accident, and Pipe Break Outside Primary Containment to assure continued core cooling, and thus neitigate consequences which could result in potential offsite exposures comparable to the 10CFR100 guidelines.

None of the first three events listed above is expected to result in environmental conditions any more severe than those experienced during normal cperation. The fourth event is addressed in the HPCIS Safety Evaluation, which states that, "The HPCIS is designed to provide adequate core cooling for small breaks... core never uncovers and is continuously cooled throughout the transient so that no core damage of any kind occurs for breaks that lie within the range of the HPCI." Thus, the size of LOCA presumed to generate postulated core damage is beyond the capacity of HPCIS to provide core cooling.

The Control Rod Drop Accident has been evaluated and no HPCIS equipment will be subjected to pressure, temperature, radiation or humidity conditions any more severe than those experienced during normal operation.

Page 58 i

BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION i

Equipment Identification No. SV2300-9 TER No. 42 Sheet 2 of ;l j Preparer: Nkmf - Date: [hM/

Independent Review:

~

Date: IT Approval: M Date: 9/40ffY

' ~ (\

v Those pipe breaks outside containment which could be expected to result in harsh conditions of pressure, temperature and humidity in the vicinity of SV2300-9 are the PB00-3 and the PB0C-5. Each of these events, however, incapacitates the HPCIS. System operability is, therefore, not required for either PBOC.

On the other hand, system operability is required for the main steam line breaks, PBOC-7 and PBOC-8. However, FSAR analysis of the PNPS design basis Main Steam Line Break Accident indicates that, with a maximum 10.5 second

- MSIV closure and continued core coverage (from normal or standby systems, including HPCIS), there would be no fuel damage. Without core damage, exposures will not exceed 104 rads.

MSIV closure time is verified once per quarter under Technical Specification surveillance requirements. The closure time must be greater than 3 seconds and less than 5 seconds for the valve to be considered operable. For valve closure times shorter than 10.5 seconds, the postulated accident is considered less severe than that analyzed.

Core cooling systems are also verified operable periodically under plant surveillance requirements. Thus, if HPCIS was incapacitated as a consequence of the PBOC, then ADS, LPCI and Core Spray would be available to redundantly assure safe shutdown of the plant. If all core cooling systems operate as designed and tested, harsh radiation levels will not occur.

Therefore, continued operation is justified, i

Vage 59 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. CV9068A, CV90688 TER No. 43 Sheet 1 of 2 Preparer: M Date: kM Independent Review:

^

~ Date: MD .

Approval: TO- Date: U 27/94 t 'N y

EQUIPMENT TYPE: Solenoid Valve MANUFACTURER: Att)matic MODEL: 15840 A condensate drain pot is provided on the HPCIS turbine exhaust line near where that line penetrates the Torus (X-223). Since the drain pot collects condensate from the exhaust line downstream of the containment isolation valves (on the Torus side), separate isolation valves have been provided on the line from the drain pot to the gland seal condenser. These valves (CV9068A & B) must be energized to open. This condition will exist only in the absence of a HPCIS isolation signal if either the manual control switches are positioned to "0 PEN" or LS9068 senses high level in the drain pot.

These valves serve a dual safety role. During a HPCI isolation, these valves will be deenergized closed to provide containment isolation. The most likely failure mode to be induced by harsh environment exposure at this time would be solenoid deenergization with the valves subsequently failing closed. This would result in the establishment of the required containment isolation. In the unlikely event that both valves failed by sticking open, two possible scenarios could be postulated. If the valves had failed open prior to a DBA this failure would have been indicated by anomalies in the level control of the drain pot. Therefore, the operating staff would have been expected to respond by closing the two downstream manual valves to establish containment isolation and initiate a program for manual draining of the drain pots based on level alarms and/or schedule. As a result, isolation of this penetration world already be established prior to the DBA/ harsh environment. If the valves failed open during a DBA requiring isolation of the torus, the liquid inventory in the torus would provide a water seal that would preclude the loss of gaseous or airborne material f rom the primary containment. As a result, leakage from this one inch penetration would be limited to minute amounts of water borne materials leaking past the turbine and gland seal condenser pump and blower seals. This leakage is estimated as having insignificant impact on overall containment integrity and the ability to coiaply with 10CFR100 limits.

Page 60 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. CV9068A, CV9068B TER No. 43 Sheet 2 of 2 Preparer: M den Date: P 7/[

Independent Review:

Date: TY Approval: MGC '- - - - - Date: Elb l E4-r N v

The other safety related function provided by these valves is to provide for automatic intermittent draining of the HPCI turbine exhaust line drain pots.

This is accomplished to prevent the accumulation of condensation that could result in a water hansner. A " failed-open" failure of these valves would have little impact with the exception of a small increase in the gland seal condenser heat loads. A " failed-closed" failure of these valves could result in excessive condensate accumulation. However, water level in the drain pot is monitored and alarmed. If the valves failed as indicated by ':he alarm, prior to a DBA, the operating staff would respond by providing rautine manual draining of the pots. As a result, it could be reasonably axpected that

- accumulation of sufficient condensate to inhibit subsequent HFCI initistion would be highly ur.likely. In the unlikely event that HPCI operntion is inhibited, redundant protection could be provided by ADS /CS, AD'i/LPCI or RCIC. The valves are not required to remain operable to support HPCI operation.

Based on these considerations, continued operation is justified.

COSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION ,

Equipment Identification No. A0 203-1A/D TER No. 85 Sheet 1 of 2 Preparer: b  % +-s- - Date: h 2 84 Independent Review:

-- Date: D Approval: /dtA3 Date: i!ff.flh/

n.

EQUIPMENT TYPE: Solenoid Valve / Terminal Blocks MANUFACTURER: AVC0/Walkdown could not identify MODEL: C5159/Walkdown could not identify These valve control modules provide for hydraulic actuation of the four inboard main steam isolation valves. Each module contains two pilot solenoid valves, both of which must be deenergized to initiate MSIV closure. Failure cf either valve to reposition on removal of electrical power will prevent closure of the respective MSIV. The valves are normally energized to hold hydraulic air under the MSIV operating piston. The terminal blocks, which

~

have not been given specific equipment identification numbers, are in the electrical circuit of the solenoid valves.

The MSIV's are relied upon to function during Pressure Regulator Failure, Loss of Feedwater Flow, Control Rod Drop Accident, Pipe Break Inside Primary Containment, and Pipe Break Outside Primary Containment

(

l to assure reactor vessel and primary containment isolation, and thus mitigate E consequences which could result in potential of fsite exposures comparable to the 10CFR100 guidelines.

Neither of the first three events listed above is expected to result in environmental conditions any more severe than those experienced during normal operation. Also, based on FSAR analyses and event profiles, no Pipe Break Outside Primary Containment is expected to result in conditions of pressure, l

l-temperature and humidity which are any more severe in the vicinity of these l

inboard MSIV's than those experienced during normal operation.

I' Of these latter two events and the Pipe Break Inside Primary Containment, the l

PBOC with core damage generates the most severe conditions of radiation for the control modules. Similar controls have been tested to a level of 3 x 107 rads. During the PBOC with core damage, cumulative exposure (plus However, 40 year normal dose) will not exceed this level for over 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

the MSIV's will receive the automatic isolation signal within 500 l

Page 62 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION e Equipment Identification No. A0 203-1A/D Sheet 2 of 2 TER No. 85 Preparer:

Date: E LI!N Independent Review:

Date: # k Approval: .

bI) Date: IfN Y

(\

ailliseconds of the pipe break. This is more conservative than either of the c,ther two events (although closure initiates later for the PBIC, exposures will not exceed 3 x 107 rads for over 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />).

Since no electrical equipment within the salve control modules will be required to function subsequent to closure initiation, post-accident radiation doses will not prevent MSIV closure for required events.

Only the P81C is expected to result in harsh conditions of pressure,These conditions temperature and humidity in the vicinity of A0 203-1A/D.

are not expected in the vicinity of the respective outboard MSIV control modules. These valves are tested periodically under controlled Technical Specification surveillance requirements; so that It isthere can be therefore reasonable assumed that, assurance that they will perform as desired.

should A0 203-1 A/D be made inoperable, the required containment isolation would be accomplished satisfactorily by A0 203-2A/0.

The nonmetallic component materials in the Automatic Valve Corporation C5159 solenoid operated air valve assemblies are being replaced this outage with components made of viton. Components containing viton have been previously l

tested and proven to have a qualified life of greater than one refueling cutage. A test program, testing similar valves, is currently in progress and Upon completion of the test I is expected to be complated in early 1985.

program a specific qualified life will be determined.

Based on all of the above, continued operation is justified.

i l

Page 04 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. A0 203-2A/D, J623, J624, J625, J626 TER No. 86 Sheet 1 of 2 Preparer: Date: b24 Independent Review: --

Date: U Approval: v OmG-Date: ,

3 v

EQUIPMENT TYPE: Solenoid Valve /Tenninal Blocks MANUFACTURER: AVCONalkdown could not identify MODEL: C5159Nalkdown could not identify _

These valve control modules provide for hydraulic actuation of the four outboard main steam isolation valves. Each module contains two pilot solenoid valves, both of which must be deenergized to initiate MSIV closure.

Failure of either valve to reposition on removal of electrical power will prevent closure of the respective MSIV. The valves are normally energized to hold hydraulic air under the MSIV operating piston. The terminal blocks are in the electrical ciccuit of the solenoid valves.

~

The MSIV's are relieo upon to function during Pressure Regulator Failure, Loss of Feedwater Flow, Control Rod Drop Accident, Pipe Break Inside Primary Containment, and Pipe Break Outside Primary Containment to assure reactor vessel and primary containment isolation, and thus mitigate consequences which could result in potential offsite exposures comparable to the 10CFR100 guidelines.

Neither of the first three events listed above is expected to result in cnvironmental conditions any more severe than those experienced during normal operation. Also, based on FSAR analyses and event profiles, no Pipe Break Inside Primary Containment is expected to result in conditions of pressure, temperature and humidity which are any more severe in the vicinity of these outboard MSIV's than those experienced during nonnal operation.

Of the latter two events listed above, the PBOC with core damage generates the most severe conditions of radiation for the control modules. Similar controls have been tested to a level of 3 x 107 rads. During the PBOC with core damage, cumulative exposure (plus 40 year normal dose) will never exceed this level over the 30 day period evaluated. Also the MSIV's will receive the automatic isolation signal within 500 milliseconds of the pipe break.

Page 64 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. A0 203-2A/D, J623, J624, J625, J626 TER No. 86 Sheet 2 of 2 Preparer: ve" Date: d2f/f4 Date: A Independent Review: -

~

Approval: /$tA , Date: N.24f@[ ,

v Since no electrical equipment within the valve control modules will be required to function subsequent to closure initiation, post-accident radiation doses will not prevent MSIV closure for required events.

Only the PBOC-7, PBOC-8 and PBOC-9 are expected to result in harsh conditions These cf pressure, temperature and humidity in the vicinity of A0 203-2A/D.

- conditions are not expected in the vicinity of the respective inboard MSIV control modules. These valves are tested periodically under controlled Technical Specification surveillance requirements; so that there can be reasonable assurance that they will perform as desired. It is therefore assumed that, should A0 203-2A/D be made inoperable, the required containment j

isolation would be accomplished satisfactorily by A0 203-1 A/D.

The nonmetallic component materials in the Automatic Valve Corporation C5159 solenoid operated air valve assemblies are being replaced this outage with components made of viton. Components containing viton have been previously tested and proven to have a qualified life of greater than one refueling outage. A test program, testing similar valves, is currently in progress and is expected to be completed in early 1985. Upon completion of the test program a specific qualified life will be determined.

Based on all of the above, continued operation is justified.

l l

i _ ..__ _ _ . _ _ _ _ _ , _ _ _ . . . _ _ _ - - _ _ _ _ . - _

' Page 65 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION N & k Equipment Identification No. Motor Control Centers D7, D8, 09 TER No. 88 Sheet 1 of 2 Preparer: b- Date: /

Independent Review:

Date: (9 Approval: s 'M Date: NZO!fY'

(\

~

EQUIPMENT TYPE: DC Motor Control Center MANUFACTURER: Cutler Hammer MODEL: 6AF685046 These three motor control centers (MCCs) provide DC power to a variety of safety related loads.

All three MCCs are located in open areas of the reactor building at elevation

- 23 (zones 1.9 and 1.10) and are exposed to a harsh superheated steam and radiation environment during a PBOC-1, PBOC-2T, PBOC-5, PBOC-8 and PB0C-9.

The most challenging environment for these three MCCs is a PBOC-1 (HPCI steam line break in the HPCI valve station) which results in a service profile that i

peaks at 238'F and 15.25 psig. All three MCCs are also exposed to a harsh radiation environment following any other PBOC and a PBIC.

Wyle Labs has completed an analysis of these MCCs based on walkdown information. This analysis justifies continued operation of these components en the following basis.

l Radiation

! The most limiting radiation exposure of 1.96 x 105 rads is sustained over a This exposure is composed of 1.3 x 105 rads l 30daymissionlengthbyD9. Beta (assuming a 90% self shielding credit for Beta due gamma and 6.6 x 10 L

to a minimum 30 mill thickness for all vital safety related components).

l Wyle Labs has determined based on a review of their extensive materials I

library, elimination of materials not commonly used in MCC construction and

! walkdown inspection of the MCCs, that no components with radiation damage threshold limits above this exposure are included in these MCCs. Based on

f. this analysis, it is judged that these MCCs can withstand the calculated j

i radiation exposure a id still perform their Class lE safety related functions.

Temperature. Humidity and Operating Time l

While no accident testing has been performed on these MCCs, proprietory testing known to Wyle Labs has been performed on another MCC containing j similar components. The test, which was of 92 hrs duration, had a maximum l

Page 66 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. Motor Control Centers D7, D8, D9 TER NoP 88 Sheet 2 of 2 f

Preparer: ^=J- Date: [MfM t

Independent Review: Date: / D Approval: S,oJA Date: 9/ Lob p .

v

temperature exposure of 271*F. This temperature exceeds the calculated

service profile for all three MCCs. Wyle Labs has performed a degradation i analysis using the Arrhenius equation technique that has confirmed that the test profile, although only 92 hours0.00106 days <br />0.0256 hours <br />1.521164e-4 weeks <br />3.5006e-5 months <br /> in length, envelops the service profiles for at least the first 13 days of the 30 day mission length of these MCCs.

Since the high temperature portion of the accident / service profile (which

! occurs over the first 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />) would be the portion most likely to cause an MCC failure, it is judged that the MCC could have functioned for the equivalent of the remaining 17 days while exposed to the calculated

(- . environmental conditions. Therefore, it has been concluded that the MCCs will remain functional for the 30 day mission length.

l Pressure j The accident testing of similar components as referred to in the previous section has performed at a peak pressure of 40 psig without apparent component degradation. This testing envelops the service profile for pressure for all thre MCCs.

Aging During the present refueling outage, Wyle Laboratories physically inspected every motor control center module which performs a Class lE function and l

found no visual signs of deterioration after 10 years of service.

Additionally, periodic surveillance testing is frequently performed in accordance with the technical specifications. Inspections of modules are made whenever corrective maintenance is required. Similar equipment has been qualified for 40 years operational life.

Based on the above facts, it is judged that the MCCs will continue to perform their Class 1E safety function.

Sunenary Based on the above discussions, continued operation is justified.

a , ..,,..,..m- - - . . _ _ , - . , , . m,,,m, ...-o,m_-. . . _ _ ~ . , _ - . . _ _ , - , - . . , _ , _ _ , , -

Page 67 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Y t Y k $'

Equipment Identification No. Motor Control Centers B14, B15 B17 B18, B20

-TER No. N/A, 89a, 90, 89b Sheet 1 of 3 Preparer: M b- .- Date: 9//fM/'

Date: li Independent Review: . ,_

Approval: b2 (\ Date: Ech v

EQUIPMENT TYPE: AC Motor Control Center MANUFACTURER: Nelson Electric MODEL: 1035E These five motor control centers (MCCs) provide 460v AC power to a variety of safety related loads.

B17, B18 and B20 are all located in open areas of the reactor building at

' elevation 23 (zones 1.9 and 1.10) and are exposed to a harsh superheated steam environment during a PBOC-1, PBOC-2T, PBOC-5, PBOC-8 or PBOC-9. The me:t challenging environment for these three MCCs is a PBOC-1 (HPCI steam line break in the HPCI valve station) which results in a service profile that i peaks at 238'E and 15.25 psig. These three MCCs are also exposed to a harsh radiation environment following any PBOC and a PBIC.

RBCCW compartments (zones 1.21 and B14 and B15 are located in the "A" and "B" 1.22) and are exposed to a harsh superheated steam environment during a PBOC-3 (HPCI' steam line break in the HPCI pump station). This PBOC results l

in a service profile which is presently calculated to peak at 301'F and 15.2 psig. This analysis is presently being reperformed to eliminate everconservatisms in the original model. It is expected, based on preliminary calculations, that this will result in a decrease of the peak temperature exposure in this room to values comparable with the PBOC-1 exposure to 817, B18 and B20. At no. time during the 30 day mission length after any PBOC or PBIC do B14 or B15 experience a harsh radiation environment.

Wyle Labs has completed an analysis of these MCCs based on walkdown information. This analysis justifies continued operation of these components en the following basis.

Radiation B14 and BIS do not experience a harsh radiation environment. For the other three MCCs, the most limiting exposure (of 2.26 x 105 rads) is sustained

.cver a 30 day mission length by B17 and B20. This exposure is composed of 1.6 x 10 5 rads gamma and 6.6 x 10 4 Beta (assuming a 90% self shielding l

credit for Beta due to a minimum 30 mill thickness for all vital safety i related components). Wyle Labs has determined based on a review of their l

l

e BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION 6 # M & b Equipment Identification No. Motor Control Centers B14, B15, B17, B18, B20 TER No. N/A, 89a, 90, 89b Sheet 2 cf 3 l' Preparer: bm Date: NfM Independent Review: -

Date: /7 Approval: N m)A.

Date: i.lto,/f (

v extensive materials library, elimination of materials not commonly used in MCC construction and walkdown inspection of the MCCs, that no components with radiation damage threshold limits above this exposure are included in these MCCs. Based on this analysis, it is judged that these MCCs can withstand the calculated radiation exposure and still perform their Class lE safety related functions.

Temperature. Humidity and Operating Time While no accident testing has been performed on these MCCs, proprietory

I testing known to Wyle Labs has been performed on another MCC containing l similar components. The test, which was of 92 hrs duration, had a maximum temperature exposure of 271*F. This temperature exceeds the calculated service profile for B17, B18 and B20 and is expected to envelop the revised service profiles for 814 and B15 which are presently under development. Wyle Labs has performed a degradation analysis using the Arrhenius equation technique that has confirmed that the test profile, although only 92 hours0.00106 days <br />0.0256 hours <br />1.521164e-4 weeks <br />3.5006e-5 months <br /> in length, envelops the service profiles for at least the first 13 days of the 30 day mission length of these MCCs. Since the high temperature portion of-the accident / service profile (which occurs over the first 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />) would be l the portion most likely to cause an MCC failure, it is judged that the MCC could have functioned for the equivalent of the remaining 17 days while exposed to the calculated environmental conditions. Therefore, it has been concluded that the MCCs will remain functional for the 30 day mission length.

! Pressure The accident testing of similar components as referred to in the previous

.section was performed at a peak pressure of 40 psig without apparent component degradation. This testing envelops the service profile for pressure for all four MCCs.

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P.ge 69 3OSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. Motor Control Centers B14 B1 B1 B18 B2 TER No. N/A, 89a, 90, 89b Sheet 3 of 3 Preparer: Date: ((/ M Independent Review: Date: 7 l9 Y Approval: b Date: 7/EA[fd'

<)

Aging During the present refueling outage, Wyle Laboratories physically inspected each MCC module which performs a Class 1E function and found no visual signs .

of deterioration af ter 10 years of service. Additionally, periodic surveillance testing is frequently performed ',n,accordance with the technical specifications. Inspections of modules are made whenever corrective maintenance is required. Similar equipment has been qualified for 40 years operational life. Based on the above f acts, it is judged that the MCCs will

- continue to perform their Class 1E safety function.

Sununa ry Based on the above discussions, continued operation is justified.

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e BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. Motor Termination Splices - VAC201 A, B; VEX 210A, B

.TER No. 91, 93 Sheet 1 of 2 Preparer: Date: f[fb/

Independent Review: ~ Date: /7

' Approval: .lb S h f./to[f[

Date:

g V

i EQUIPMENT TYPE: Motor termir:ation splices MANUFACTURER: Various MODEL: Various s

The HPCI Area Cooling (VAC201A, B) and the Standby Gas Treatment System Fan motor termination splices are tape type motor termination splices with a glyptal outer covering. These splices are similar to the splices tested in FIRL Report #F-C3056.

Temperature and Pressure Thetestsplices$4resubjectedtoasteamenvironmentfor71/2 days. The splices were~ electrically loaded throughout the exposure period. The peak temperature and pressure were 325'F and 80 PSIG for a duration of 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />.

The temperature and' pressure were reduced to 220'F and 5 PSIG for the remainder of the test. The samples were subjected to a chemical spray solution of 1900 ppm boron ti..oughout the test.

t  !

Opferability Time >

s l The,t'est time was 7 1/2 days. A degradation equivalency analysis shows that l the. test profile is thermally more degrading than the composite outside

( containment profils at PNPS for 30 days.

l s.

,An aging analysis shows that the materials of the tested splice have a (minimum expected life at 105'F of 272 years (glass tape). The expected life l

l- of the glyptal (assume alkyd varnish) at 105'F is greater than 1 x 10 5 l years.

Radiation l A radiation analysis shows that the materi,als of the tested splice have a minimum threshold value of 1.3E6 rads gamma (silicon rubber tape). Per RE!C Report No. 21, the dielectric properties of silicones are little affected 8

unless absorbed doses exceed 2 x 10 rads gamma.

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Page 71 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Ider.tification No. Motor Termination Splices - VAC201A, B; VEX 210A, 8

TER No. 91, 93 Sheet 2 of 2 .

Preparer: / be Date: [NM/

Independent Review: ____

Date: 7 !/ Ef Approval: od Date: 7/Lo/f'/

n v

Although the insulation resistance decreased during the test, all of the cable splices remained functional throughout the test. Therefore, continued operation is justified.

. - , _ , . ~ - . . . -

COSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION l

l Equipment Identification No. VAC204A, VAC204B, VAC204C, VAC204D l TER No. 92 Sheet 1 of 2 l Preparer:

^

liate: 2 U Independent Review: kb Date: 24

• i

() U l Approval: C:LCAD -- m Date: V24 /g4 G

EQUIPMENT TYPE: Unit Cooler Motors MANUFACTURER: Louis Allis MODEL: COG 4B Temperature The worst case postulated PBOC has a temperature spike to 228.7'F. Within 2.5 minutes the temperature will have decteased to 180*F, and within 10 minutes the temperature will be back down to 140*F. The motors are standard AC induction motors with class B insulation having a NEMA standard maximum continuous operating rating of 130*C (226*F). Due to the short duration of the extreme peak accident temperature and rapid decay of the accident conditions to normal, the temperature due to a PBOC should have no adverse affects on the motors.

f Pressure The worst case postulated PB0C has a pressure spike of .7 psig. Within 26 seconds the pressure will have decreased to normal atmospheric pressure. The motors are dripproof, open case motors that have no pressure retaining parts. Therefore, the pressure spike will have no adverse affects on the motors.

Humidity During the worst case postulated PBOC the humidity is assumed to approach 100% inmediately af ter the accident and then lower back to normal. The motors are a standard AC induction motors with class B insulation. The standard type construction is of a polyester enamel coated magnet wire which is then dipped twice in a polyester varnish after winding, and therefore the motors are suitable for moderate humidity levels. Once the motors are operating, the stator temperature rise will evaporate any moisture which may collect on the windings and preclude the buildup of additional moisture.

Therefore, a PBOC will have no detrimental ef fects on the motors.

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Page 73 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION  : I f

l Equipment Identification No. VAC204A, VAC2048 VAC204C, VAC204D l TER No. 92 Sheet 2 of 2

}

D' ate : I T ,

Preparer:

Independent Review:

Date: h 2Y fi i iw Date: %I24 /R4 Approval:

. N v

Radiation The worst case postulated LOCA radiation (including the 40 year dose) is 1.15 x 107 rads. The motors are AC induction motors with standard class B insulation. The radiation limiting materials are the polyester enamel and Class B polyester varnish used as the insulating materials for the windings.

insulating systems for various types of motors have been shown, by testing, to be capable of withstanding 2 x 10 8 rads when used in this application.

Therefore, the radiation due to a LOCA will have no detrimental effects on the motors.

Based on the above information, continued operation is justified.

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I BOSTON EDISON COMPANY l JUSTIFICATION FOR I I

CONTINUED OPERATION i

Equipment Identification No. HR-1A, 2A, 3A, 4A, 18, 28, 3B, 4B TER No. 97 (controller) Sheet 1 of 1 Preparer:

Date: '/ /F4 Independent Review: kL J Date: gf24fy v v Approval: ITil ~

Date: Bf77/%

,N U

EQUIPMENT TYPE: Humidity Control Relay MANUFACTURER: Honeywell MODEL: R7088C These relative humidity controllers are not required for Standby Gas Treatment System (SGTS) operation. The normal function of the controllers are to energize resistance heaters to control the humidity of the air stream being filtered. The humidity controls have been bypassed so that full heater operation is initiated upon operation of the SGTS exhaust fan. Therefore,

~. continued plant operation is justified.

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BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. Terminations-Ring Tongue (<4KV)

TER No.100 Sheet 1 of 2 Preparer: k - -

Date: M Y Independent Review: h r ,L Date: S//f Approval: C3LC '

Date: %/24/ M

(

w EQUIPMENT TYPE: Ring Tongue Terminals MANJFACTURER: Various MODEL: Various According to Wyle Laboratories Corrective Action Report No. 47066-TER-1, the installed ring tongue terminals include both insulted and non-insulated rcodels from a variety of manuf acturers. The insulation materials used on insulated model has not been specifically identified. The commonly used insulation materials for this application are nylon, PVC, PVF, and PVDF.

.lustification for continued operation is required as specific qualification tests do not exist.

Uninsulated ring tongue terminals are not susceptible to degradation or environmentally induced failure at the levels of stress produced by the environments at the Pilgrim I plant. Failure of these interfaces is a function of installation configuration and terminal design.

Insulated ring tongue terminals are supplied with an insulating material covering the barrel of the terminals. This insulation is provided to prevent bare metal from protruding beyond the terminal block or connection to which

! it is fastened, thus reducing the hazard of shock to personnel and a possible

( shorting path between adjacent terminals and equipment. At the voltage levels of these terminations, the physical presence of any of the industry standard insulating materials is sufficient to perform this function.

The environments which could cause significant insulation deterioration in the Pilgrim plant are temperature and radiation. Degradation induced by l-these environments takes the form of material softening, material l embrittlement, increased compression set, loss of elongation capability, or cracking when subjected to bending stresses or dynamic loads. None of these l degradation mechanisms will impact the physical barrier insulation capability of the materials in their static termination application.

(

l The justification discussed above has been substantiated by the application of numerous terminal lugs in nuclear equipment qualification tests. While these tests were not specifically designed to qualify the terminals and the models do not necessarily correlate with Pilgrim installed lugs, the tests demonstrate that in typical plant environments, neither insulated nor l

' { face Y@

BOSTON EDISON COMPANY l JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. Terminations-Ring Tongue (<4KV)

TER No.100 Sheet 2 of 2 Preparer:

^

^ Date: Y!IY Independent Review: h - L f

Date: SF Approval: Date:  % /24 /84

.\

v non-insulated terminal lugs constitute a significant potential failure mechanism. Samples of tests which included representative terminals as part of the test specimen or part of the test equipment are Wyle 45603-1, Wyle 45638, Franklin C5257, Wyle 43703, Wyle 44282, Wyle 44300, Franklin C5022.

Based on the above, continued operation with existing ring tongue terminals is justified.

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l BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Idertification No. C152, C153, C154, C155, C156, C157 C158, C159, C163 TER ho.107,108 Sheet 1 of 2 Preparer:

~ Date: N!?Y Independent Review:

_e7/ Date: Wh Approval: T5 Date: E / 24 /24-(\

w EQUIPMENT TYPE: Panel Indicating Lights MANUFACTURER: General Electric MODEL: ET-16 o Temperature Temperature tests have been successfully conducted by Wyle on ET-16 lights.

. The tests were conducted at 160*F. Proper operation of the lights was

- verified before and after the temperature exposure. For this application the maximum accident temperature is 238.1*F which exceeds the 160*F test temperature, however, only for 15 minutes. These lights are located inside an enclosure (unvented) which will cause the temperature experienced by the lights to lag the accident temperature experienced by the enclosure. Tests have been conducted by Wyle Laboratories on similar sized cabinets (except with vents) which characterized the internal temperature of the cabinets as a function of time in a LOCA environment.

Results of these tests (Wyle Report No. 44439-2) show the internal cabinet temperature lagged the external temperature by a minimum of 50*F during the first 15 minutes. In that test the temperature and pressure were rapidly (within approximately 10 seconds) ramped to 54 psig and 280'F (minimum) respectively. Because the pressure for this application is much less than the pressure for the test (J.6 psig versus 54 psig) it is judged that in a similar test to the same maximum temperature that the internal temperature of the cabinet would lag the external temperature by substantially greater than the 50*F experienced in the test. Further, in the tests conducted by Wyle, varied components (examples: pressure transmitter and solenoid valve) were installed in the cabinet and their mass temperature was recorded in the test. The temperature of a typical component (pressure transmitter) lagged the accident temperature by approximately 80*F af ter the first 15 minutes of the test. In the Wyle test, the lights were maintained at 160*F. Based on the above tests and engineering rationale, it is judged that the test temperature of 160*F envelops the temperature which the lights would experience in the accident condition. Therefore, the lights are judged suitcble for use in the temperature application.

BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. C152, C153, C154, C155, C156, C157. C158, C159, C163 TER No.107,108 Sheet 2 of 2 Preparer: Date: 2 U Independent Review: h- ,e---

Date: .F./8Fdf Approval: QCM -

Date: E /'24 / 24 t 's v

o Humidity These lights are never exposed 10 more than 80% RH. Maximum voltage on the lights is 120 VAC. Wyle Laboratories has tested a variety of lights at humidity conditions in the range of 90% to 100%. In general, no problems have been experienced for these conditions where voltage never exceeds 120 volts unless the items experienced deformation resulting f rom temperature.

Operation of the lights at the temperature conditions is justified in the above paragraph. Therefore, the lights are judged suitable for use in the humidity environment.

o Pressure The maximum pressure which the lights would be exposed to in an accident is 15.3 psia (0.6 psig). The configuration of the lights is such that they will not entrap air or otherwise cause a pressure imbalance which would result in a functional disparity in the lights. Therefore the lights are judged suitable for use in this pressure environment.

o Radiation l

I The maximum radiation which the lights will experience is less than 1 x 10 6 rads (2.3 x 105 rads gamma and 6.6 x 105 rads beta) based on a specific location radiation analysis. Proprietary Wyle Test Report No. 45625-1 A documents satisfactory operation of the lights following a radiation exposure of 2.1 x 106 rads. Therefore, the lights are judged suitable for use in the radiation environment.

l Based on the above information, continued plant operation is justified.

Page 79 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. Cable-Model PE/PVC T ER No . 110, 111, 112, 118, 119, 120, 121, 122, 123, 124, 252 Sh;et 1 of 1 -

Pr: parer: \L o

b o

cate: 9 'ze $4 independent Review: /// bs Date: NEM/V Approval: I Date: ( L1 ( 4

- u .

EQUIPMENT TYPE: Cable MANUFACTURER: General Electric MODEL: PE/PVC This equipment consists of polyethylene insulated polyvinylchloride jacketed

- cible provided by several manufacturers. While no qualification documentation or testing history has been founo for these specific cables, si;ilarly constructed cable has been successfully subjected to sequential ~

testing (proprietary TR #17513-1), which documents qualification of the insulation system to 1.63 x 108 rads gamma and a LOCA condition including temperatures up to 325'F.

The generic materials which make up the insulation system have expected lives cf greater than 1.4E4 years (PVC) and greater than 1.5E4 years (PE) in an ambient temperature of 105'F.

Therefore, continued operation is justified l

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Page 80 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION ,

Equipment Identification No. HPCI Turbine EG-R Electro Mechanical Hydraulic Actuator TER No.152 Sheet 1 of 2 Preparer: [l/$' N h - D' ate : ##/f/

Independent Review:

Date: I fY Approval: M Date: NZ2[f8[

O EQUIPMENT TYPE: Turbine Governor Control MANUFACTURER: Woodward MODEL: 8250-133 This device contributes to HPCIS turbine speed control and is, therefore, required solely to assure satisfactory HPCIS operation.

The HPCIS is relied upon to operate during and following .

Loss of Feedwater Flow, Total Loss of Offsite Power, Shutdown from Outside Control Room (Special Event),

Pipe Break Inside Primary Containment, Cortrol Rod Drop Accident, and Pipe 'Jreak Outside Primary Containment to assure continued core cooling, and thus mitigate consequences which could result in potential of fsite exposures comparable to the 10CFR100 guidelines.

None of the first three events listed above is expected to result in environmental conditions any more severe than those experienced during normal operation. The fourth event is addressed in the HPCIS Safety Evaluation, which states that, "The HPCIS is designed to provide adequate core cooling for small breaks... core never uncovers and is continuously cooled throughout

' the transient so that no core damage of any kind occurs for breaks that lie within the range of the HPCI." Thus, the size of LOCA presumed to generate postulated core damage is beyond the capacity of HPCIS to provide core cooling.

The Control Rod Drop Accident has been evaluated and no HPCIS equipment will be subjected to pressure, temperature, radiation or humidity conditions any more severe than those experienced during normal coeration.

I

Page 81 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTIUUED OPERATION Equipment Identification No. HPCI Turbine EG-R Electro Mechanical Hydraulic Actuator TER No.152 Sheet 2 of 3 .

9M/M Preparer: Date:

Independent Review:

Date: 1 N Approval: _/Ind

~

Date: 2hb v

Those pipe breaks outside containment which could be .?xpected to result in harsh conditions of pressure, temperature and humidity in the vicinity of the HPCI Turbine EG-R Electro Mechanical Hydraulic Actuator are the PBOC-3 and the PBOC-5. Each of these events, however, incapacitates the HPCIS. System operability is, therefore, not required for either PBOC.

On the other hand, system operability is required for the main steam line breaks, PBOC-7 and PBOC-8. However, FSAR analysis of the PNPS design basis Main Steam Line Break Accident indicates that, with a maximum 10.5 second -

MSIV closure and continued core coverage (from normal or standby systems.

including HPCIS), there would be no fuel damage. Without core damage, radiation exposures will not exceed 10 4 rads.

MSIV closure time is verified once per quarter under Technical Specification surveillance requirements. The closure time must be greater than 3 seconds and less than 5 seconds for the valve to be considered operable. For valve closure times shorter than 10.5 seconds, the postulated accident is considered less severe than that analyzed.

Core cooling systems are also verified operable periodically under plant surveillance requirements. Thus, if HPCIS was incapacitated as a consequence of the PBOC, then ADS, LPCI and Core Spray would be available to redundantly assure safe shutdown of the plant. If all core cooling systems operate as designed and tested, harsh radiation levels will not occur.

Therefore, continued operation is justified.

l Page 82 l

BOSTON EDISON COMPANY JUSTIFICATION FOR ,

CONTINUED OPERATION 1

1 Equipment Identification No. HPCI Turbine Cor, trol Cable Assemblies-TER No._153 Shee 1 of a

[Mfk

~

Preparsr: '^E Date:

Independent Review: Date: 7!I7/IY Approval: MM/\ Date: 7!28b L[

V EQUIPMENT TYPE

Turbine Governor Control Cables MANUFACTURER: Various MODEL: Various This device contributes to HPCIS turbine speed control and is, therefore, required solely to assure satisfactory HPCIS operation.

. The HPCIS is relied upon to operate during and following Loss of Feedwater Flow, -

Total Loss of Offsite Power, Shutdown from Outside Control Room (Special Event),

Pipe Break Inside Primary Containment, Control Rod Drop Accident, and Pipe Break Outside Primary Containment i to assure continued core cooling, and thus mitigate consequences which could I result in potential of fsite exposures comparable to the 10CFR100 guidelines.

1 None of the first three events listed above is expected to result in environmental conditions any more severe than those experienced during normal eperation. The fourth event is addressed in the HPCIS Safety Evaluation, which states that, "The HPCIS is designed to provide adequate core cooling for small breaks... core never uncovers and is continuously cooled throughout the transient so that no core damage of any kind occurs for breaks that lie within the range of the HPCI." Thus, the size of LOCA presumed to generate postulated core damage is beyond the capacity of HPCIS to provide core l cooling.

The Control Rod Drop Accident has been evaluated and no HPCIS equipment will be subjected to pressure, temperature, radiation or humidity conditions any more severe than those experienced during normal operation.

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Page 83 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. HPCI Turbine Control Cable Assemblies TER No.153 Sheet 2 of J.

Preparer: Date: b '

Independent Review: Date: li Approval: ~

Date: klob (J

Those pipe breaks outside containment which could be expected to result in harsh conditions of pressure, temperature and humidity in the vicinity of the HPCI Turbine Control Cable Assemblies are the PBOC-3 and the PBOC-5. Each of these events, however, incapacitates the HPCIS. System operability is, therefore, not required for either PBOC.

On the other hand, system operability is required for the main steam line breaks, PBOC-7 and PBOC-8. However, FSAR analysis of the PNPS design basis Main Steam Line Break Accident indicates that, with a maximum 10.5 second MSIV closure and continued core coverage (from normal or standby systems, including HPCIS), there would be no fuel damage. Without core damage, exposures will not exceed 10 4 rads. .

MSIV closure time is verified once per quarter under Technical Specification surveillance requirements. The closure time must be greater than 3 seconds and less than 5 seconds for the valve to be considered operable. For valve closure times shorter than 10.5 seconds, the postulated accident is considered less severe than that analyzed.

Core cooling systems are also verified operable periodically under plant surveillance requirements. Thus, if HPCIS was incapacitated as a consequence of the PBOC, then ADS, LPCI and Core Spray would be available to redundantly assure safe shutdown of the plant. If all core cooling systems operate as designed and tested, harsh radiation levels will not occur.

Therefore, continued operation is justified.

Page 84 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. HPCI Turbine Magnetic Pickup TER No.154 Sheet 1 of 2 Preparer: - Date: 9////W Independent Review: Date: 9 Y Approval: M (T Date: 7[Loh d U

EQUIPMENT TYPE: Turbine Speed Sensor MANUFACTURER: Woodward MODELi 1680-622 This device contributes to HPCIS turbine speed control and is, therefore, required solely to assure satisfactory HPCIS operation.

- The HPCIS is relied upon to operate during and following Loss of Feedwater Flow, -

Total Loss of Offsite Power, Shutdown from Outside Control Room (Special Event),

Pipe Break Inside Primary Containment, Control Rod Drop Accident, and Pipe Break Outside Primary Containment to assure continued core cooling, and thus mitigate consequences which could result in potential of f site exposures comparable to the 10CFR100 guidelines.

None of the first three events listed above is expected to result in environmental conditions any more severe than those experienced during normal operation. The fourth event is addressed in the HPCIS Safety Evaluation, which states that, "The HPCIS is designed to provide adequate core cooling for small breaks... core never uncovers and is continuously cooled throughout the transient so that no core damage of any kind occurs for breaks that lie within the range of the HPCI." Thus, the size of LOCA presumed to generate postulated core damage is beyond the capacity of HPCIS to provide core cooling.

The Control Rod Drop Accident has been evaluated and no HPCIS equipment will be subjected to pressure, temperature, radiation or humidity conditions any more severe than those experienced during normal operation.

l rage 85 e

BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. HPCI Turbine Magnetic Pickup

! TER No.154 Sheet 2 of 3 Preparer: [ Date: h/h Independent Review: -

Date: /7 Y Approval: b Date: Th!8 f fl v

Those pipe breaks outside containment which could be expected to result in harsh conditions of pressure, temperature and humidity in the vicinity of the HPCI Turbine Magnetic Pickup are the PBOC-3 and the PBOC-5. Each of these events, however, incapacitates the HPCIS. System operability is, therefore, not required for either PBOC.

On the other hand, system operability is required for the main steam line breaks, PBOC-7 and P80C-8. However, FSAR analysis of the PNPS design basis Main Steam Line Break t.ccident indicates that, with a maximum 10.5 second MSIV closure and continued core coverage (from normal or stand'oy systems, including HPCIS), there woald be no fuel damage. Without core damage, ~

exposures will not exceed 104 rads.

MSlv closure time is verified once per quarter under Technical Specification surveillance requirements. The closure time must be greater than 3 seconds and less than 5 seconds for the valve to be considered operable. For valve closure times shorter than 10.5 seconds, the postulated accident is considered less severe than that analyzed.

Core cooling systems are also verified operable periodically under plant surveillance requirements. Thus, if HPCIS was incapacitated as a consequence of the PBOC, then ADS, LPCI and Core Spray would be available to redundantly assure safe shutdown of the plant. If all core cooling systems operate as i

designed and tested, harsh radiation levels will not occur.

Therefore, continued operation is justified.

Page 86 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. HPCI Turbine Ramp Generator & Signal Converter Box <

TER No.155 Sheet 1 of 3 .

Preparer:

Date: [ /[f k Independent Review: - Date: l7!fY Approval: M /\

Date: T!&O!8I v

EQUIPMENT TYPE: Turbine Ramp Generator & Signal Converter MANUFACTURER: Woodward MODEL: 8270-848/8271-083 This device contributes to HPCIS turbine speed control and is, therefore, required solely to assure satisfactory HPCIS operation.

The HPCIS is relied upon to operate during and following Loss of Feedwater Flow, Total Loss of Offsite Power, Shutdown from Outside Control Room (Special Event),

Pipe Break Inside Primary Containment, Control Rod Drop Accident, and Pipe Break Outside Primary Containment to assure continued core cooling, and thus mitigate consequences which could result in potential of f site exposures comparable to the 10CFR100 guidelines.

None of the first three events listed above is expected to result in environmental conditions any more severe than those experienced during normal l

l operation. The fourth event is addressed in the HFCIS Safety Evaluation,

' which states that, "The HPCIS is designed to provido adequate core cooling for small breaks... core never uncovers and is continuously cooled throughout l

the transient so that no core damage of any kind occurs for breaks that lie-within the range of the HPCI." Thus, the size of LOCA presumed to generate postulated core damage is beyond the capacity of HPCIS to provide core l cooling.

The Control Rod Drop Accident has been evaluated and no HPCIS equipment will be subjected to pressure, temperature, radiation or humidity conditions any more severe than those experienced during normal operation, t

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Page 87 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. HPCI Turbine Ramp Generator & Signal Converter B2x TER No.155 Sheet 2 of 3 Preparer: D' ate : k//M/

-Independent Review: Date: /

Approval: Date: N2c[N

/\

v Those pipe breaks outside containment which could be expected to result in harsh conditions of pressure, temperature and humidity in the vicinity of the HPCI Turbine Ramp Generator and Signal Converter Box are the PBOC-3 and the PB0C-5. Each of these events, however, incapacitates the HPCIS. System cperability is, therefore, not required for either PBOC.

On the other hand, system operability is required for the main steam line breaks, PBOC-7 and PB0C-8. However, FSAR analysis of the PNPS design basis Main Steam Line Break Accident indicates that, with a maximum 10.5 second -

MSIV closure and continued core coverage (from normal or standby systems, including HPCIS), there would be no fuel damage. Without core damage, exposures will not exceed 104 rads.

MSIV closure time is verified once per quarter under Technical Specification surveillance requirements. The closure time must be greater than 3 secondt and less than 5 seconds for the valve to be considered operable. For valve closure times shorter than 10.5 seconds, the postulated accident is censidered less severe than that analyzed.

Core cooling systems are also verified operable periodically under plant surveillance requirements. Thus, if HPCIS was incapacitated as a consequence cf the PBOC, then ADS, LPCI and Core Spray would be available to redundantly assure safe shutdown of the plant. If all core cooling systems operate as designed and tested, harsh radiation levels will not occur.

Therefore, continued operation is justified.

l

Page 88 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION-Equipment Identification No. Bias Speed Potentiometer TER No. -156 Sheet 1 of a Preparer: Date: f/f / M Independent Review: = Date: i!!1 FY Approval: Date: T [2a/fd O

' EQUIPMENT TYPE: -Turbine Speed Ct,ntroller

. MANUFACTURER: Woodward MODEL: .1657-523

- This device contributes to HPCIS turbine speed control and is, therefore, requi ed solely to assure satisfactory HPCIS operation.

. The HPCIS is reliet' upon to operate during and following Loss of Feedwater Flow, ,

Total Loss of Offsite Power, Shutdown from Outside Control Room (Special Event),

Pipe Break Inside Primary Containment,.

l

' Control Rod Drop Accident, and Pipe Break Outside Primary Containment to assure continued core cooling, and thus mitigate consequences which could result in potential of fsite exposures comparable to the 10CFR100 guidelines.

None of the first three events listed above is expected to result in

, environmental conditions any more severe than those experienced during normal l operation. The fourth event is addressed in the HPCIS Safety Evaluation, which states that, "The HPCIS is designed to provide adequate core cooling -

for small breaks... core never uncovers and is continuously cooled throughout

-the transient so that no core damage of any kind occurs for breaks that lie within the range of the HPCI." Thus, the size of LOCA presumed to generate postulated core damage is beyond the capacity of HPCIS to provide core cooling.

The Control Rod Drop Accident has been evaluated and no HPCIS equipment will be subjected to pressure, temperature, radiation or humidity conditions any more severe than those experienced during normal operation.

f

Page 89 i

BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. Bias Speed Potentiometer TER No.156 Sheet 2 of 2 Preparer: hl e+ Date: bMI Independent Review:

Date: [!/9 '[

Approval: Date: 9hObY O

Those pipe breaks outside containment which could be expected to result in harsh conditions of pressure, temperature and humidity in the vicinity of the Bias Speed Potentiometer are the P80C-3 and the PBOC-5. Each of these events, however, incapacitates the HPCIS. System operability is, therefore, not required for either PB0C.

On the other hand, system operability is required for the main steam line breaks, P80C-7 and PBOC-8. However, FSAR analysis of the PNPS design basis Main Steam Line Break Accident indicates that, with a maximum 10.5 second MSIV closure and continued core coverage (f rom normal or standby systems, including HPCIS), there would be no fuel damage. Without core damage, .

exposures will not exceed 10 4 rads.

MSIV closure time is verified once per quarter under Technical Specification surveillance requirements. The closure time must be greater than 3 seconds and less than 5 seconds for the valve to be considered operable. For valve closure times shorter than 10.5 seconds, the postulated accident is considered less severe than that analyzed.

Core cooling systems are also verified operable periodically under plant surveillance requirements. Thus, if HPCIS was incapacitated as a consequence of the PBOC, then ADS, LPCI and Core Spray would be available to redundantly assure safe shutdown of the plant. If all core cooling systems operate as designed and tested, harsh radiation levels will not occur.

Therefore, continued operation is justified.

i l

Page 90 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. Resistor Box TER No.157 Sheet 1 of 3 Preparer: b ***e- Date: ((/M Independent Review: b -

Date: I9 Approval: Date: 7[Eo!8Y n

EQUIPMENT TYPE: Turbine Governor Control MANUFACTURER: Woodward MODEL: 8270-281 This device contributes to HPCIS turbine speed control and is, therefore, required solely to assure satisf actory HPCIS operation.

The HPCIS is relied upon to operate during and following Loss of Feedwater Flow. .

Total Loss of Offsite Power, Shutdowa from Outside Control Room (Special Event),

Pipe Preak Inside Primary Containment, Control Rod Drop Accident, and Pipe Break Outside Primary Containment a to afsure continued core cooling, and thus mitigate consequences which could res' alt in potential of f site exposures comparable to the 10CFR100 guidelines.

hone of the first three events listed above is expected to result in environmental conditions any more severe than those experienced during normal operation. The fourth event is addressed in the HPCIS Safety Evaluation, which states that,The HPCIS is designed to provide adequate core cooling for small breaks... core never uncovers and is continuously cooled throughout the transient so that no core damage of any kind occurs for breaks that lie within the range of the HPCI." Thus, the size of LOCA presumed to generate l postulated core damage is beyond the capacity of HPCIS to provide core cooling.

The Control Rod Drop Accident has been evaluated and no HPCIS equipment will be subjected to pressure, temperature, radiation or humidity conditions any more severe than those experienced during normal operation.

4

N E

Page 91

{

BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. Resistor Box Sheet 2 of A g TER No.157 Preparer: Date: k//h Independent Review: Date:

Approval: Date: If N b

n Those pipe breaks outside containment which could be expected to result in harsh conditions of pressure, temperature and humidity in the vicinity of the Resistor Box are the PBOC-3 and the PBOC-5. Each of these events, however, E incapacitates the HPCIS. System operability is, therefore, not required for k either PBOC.

On the other hand, system operability is required for the main steam line breaks, PBOC-7 and PBOC-8. However, FSAR analysis of the PNPS design basis

- - Main Steam Line Break Accident indicates that, with a maximum 10.5 second MSIV closure and continued core coverage (from normal or standby systems, including HPCIS), there would be no fuel damage. Without core damage, -

exposures will not exceed 10 4 rads.

MSIV closure time is verified once per quarter under Technical Specification surveillance requirements. The closure time must be greater than 3 seconds and less than 5 seconds for the valve to be considered operable. For valve closure times shorter than 10.5 seconds, the postulated accident is considered less severe than that analyzed.

Core cooling systems are also verified operable periodically under plant surveillance requirements. Thus, if HPCIS was incapacitated as a consequence of the PBOC, then ADS, LPCI and Core Spray would be available to redundantly assure safe shutdown of the plant. If all core cooling systems operate as designed and tested, harsh radiation levels will not occur.

Therefore, continued operation is justified.

i - _ _ _ _ _ _ _ _

i Page 92 BOSTON EDISON COMPANY l JUSTIFICATION FOR l CONTINUED OPERATION Equipment Identification No. EG-M Control Box

-TER No. 158 Sheet 1 of 2 Pr: parer: ^% Date: N/fh Independent Review:

Date: i!'9 !EY Approval: bh Date: 9[2A[8/

n v

EQUIPMENT TYPE: Turbine Governor Control MANUFACTURER: Woodward MODEL: 8270-849/8270-811 This device contributes to HPCIS turbine speed control and is, therefore, r; quired solely to assure satisfactory HPCIS operation.

Th2 HPCIS is relied upon to operate during and following Loss of Feedwater Flow.

Total Loss of Offsite Power, Shutdown from Outside Control Room (Special Eunt),

Pipe Break Inside Primary Containment, Control Rod Drop Accident, and Pipe Break Outside Primary Containment to assure continued core cooling, and thus mitigate consequences which could result in potential of f site exposures comparable to the 10CFR100 guidelines.

N;ne of the first three events listed above is expected to result in environmental conditions any more severe than those experienced during normal cperation. The fourth event is addressed in the HPCIS Safety Evaluation, which states that, "The HPCIS is designed to provide adequate core cooling fcr small breaks... core never uncovers and is continuously cooled throughout the transient so that no core damage of any kind occurs for breaks that lie within the range of the HPCI." Thus, the size of LOCA presumed to generate postulated core damage is beyond the capacity of HPCIS +o provide core cooling.

Th? Control Rod Drop Accident has been evaluated and no HPCIS equipment will be subjected to pressure, temperature, radiation or humidity conditions any more severe than those experienced during normal operation.

- ~ _ - . - - _ - , - _ _ . . _ _ , . _ .-

Page 93 BOSTON EDISON COMPANY JUSTIFICATION FOR l CONTINUED OPERATION l l

Equipment Identification No. EG-M Control Box TER No.158 Sheet 2 of 2 Preparer: k Date: bfk' Independent Review: Date: i 7 Y-Approval; b Date: i!20/fi

/\

v Those pipe breaks outside containment which could be expected to result in harsh conditions of pressure, temperature and humidity in the vicinity of the EG-M Control Box are the PBOC-3 and the PBOC-5. Each of these events, however, incapacitates the HPCIS. System operability is, therefore, not required for either PBOC.

t On the other hand, system operability is required for the main steam line breaks, FBOC-7 and PB0C-8. However, FSAR analysis of the PNPS design basis

- Main Steam Line Break Accident indicates that, with a maximum 10.5 second MSIV closure and continued core coverage (from normal or standby systems, including HPCIS), there would be no fuel damage. Without core damage, .

exposures will not exceed 10 4 rads.

MSIV closure time is verified once per quarter under Technical Specification surveillance requirements. The closure time must be greater than 3 seconds and less than 5 seconds for the valve to be considered operable. For vi.1ve closure times shorter than 10.5 seconds, the postulated accident is considered less severe than that analyzed.

Core cooling systems are also verified operable periodically under plant surveillance requirements. Thus, if HPCIS was incapacitated as a consequence of the PBOC, then ADS, LPCI and Core Spray would be available to redundantly assure safe shutdown of the plant. If all core cooling systems operate as designed and tested, harsh radiation levels will not occur.

Therefore, continued operation is justified.

l-T

- -,r-w s-- -----m,,-g.m,- - -- we.- mw ,-m.,-m.w--,,-,n.---,, w

_..--------,--4 -.--,,--------,m- m- - . m -

1 Page 94

)

BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. DPIS-261-2A,B,C,0,E,F,G,H,J,K,L.M,N,P,R,5 TER No.172 Sheet 1 of l Preparer: Gh Date: 8 8I Independent Review: I f

_ Date: I Approval: TdC N . i. Date: B/'27/24 s T w

EQUIPMENT TYPE: Differential Pressure Switch MANUFACTURER: Barton MODEL: 278 High steam flow in each main steam line is sensed by four indicating type differential pressure switches which sense the pressure difference across the flow restrictor in that line. High steam flow could indicate a break in a main steam line. The main steam line high differential pressure switches effect automatic isolation of all main steam lines at a setting of approximately 140% of normal main stean ficw. ,

These switches are located in the RCIC Ouad mezzanine, elev. 2'9" on Panel C-2256. These switches are required to operate in the event of P80C-7 (Main Steam Line Break in the Condenser Bay) and PBOC-8 (Main Steam Line Break in the Steam Tunnel). In the event of PBOC-7 and PBOC-8, the isolation signal will be generated within 500 milliseconds of the break due to high differential pressure across the main steam line flow restricters. The harsh environment on the RCIC Quad Mezzanine occurs after this required safety function has been performed for both PBOC-7 and PBOC-8. This is also true for Main Steam Line Breaks Inside Containment. Once the MSIV's are signalled to close, no f ailure mode of the steam flow switches can prevent or reverse main steam line isolation valve closure. Deliberate operator action is necessary to reopen these valves. Closure of the switch contacts due to a short caused by the harsh environment will result in MSIV closure which is the safe position of the MSIV's.

In addition to the differential pressure switches, low pressure at the turbine inlet will initiate MSIV closure within about 200 milliseconds after the break occurs. These switches, PS-261-30A, B, C, 0 are located in a mild environment. These provide a backup to the differential pressure signal caused by the break.

Therefore, since completion of the safety function prior to exposure to the accident environment is accomplished and subsequent failures of the equipment does not degrade any safety function and an alternative means of accomplishing the same safety function exists, continued operation of Pilgrim Station is justified.

Page 95 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION

- Equipment identification No. dPIS 5040A, dPIS 5040B TER No.173 Sheet 1 of 1 Preparer: kL Eate ,*- Date: S M Independent Review: Date: O!87 Approval: b la Date: 8/38[N O

EQUIPMENT TYPE: Differential Pressure Switch MANUFACTURER: Barton MODEL: 288A The primary containment is designed for an. internal pressure not more than 2 psi less than the concurrent external pressure. If the suppression chamber pressure falls more than 0.5 psi below the Reactor Building pressure,

- dPIS 5040A&8 will open contacts to deenergize SV 5040A&B respectively. These valves will, in turn, vent air frsm A0 5040A&B, respectively; allowing those valves to.open. Consequently, air will be allowed to pass through vacuum -

breakers X212A&8 into the Torus to repressurize containment. Failure of the differential pressure switches to deenergize SV 5040A&B when a containment vacuum is present will, therefore, threaten containment integrity.

1 On the other hand, A0 5040A&B also provide containment isolation. An isolation signal is provided to assure that no operator action can energize SV 5040A&B. However, this isolation signal is in series with each of the

- differential pressure switches; such that isolation will not prevent vacuum relief. Failure of the differential pressure switches in a position which opens A0 5040A&8 despite the existence of a containment isolation signal will, therefore, threaten a breach of primary containment.

FSAR Appendix G analysis indicates that primary containment vacuum relief is required solely as an auxiliary for primary containment during the Control Rod Drop Accident and the Pipe Break ~ Inside Primary Containment. Neither of these events will result in harsh conditions of pressure, temperature and humidity in the vicinity of the switches. Also, the greatest expected cumulative exposure (post-LOCA plus 40 year normal) is 7.4 X 105 rads, which is less than the qualified dose of 3 x 106 rads.

Therefore, these switches are considered to be environmentally qualified.

i The documentation packages for these switches are being completed and when completed, environmental qualification will be proven. Therefore, continued operation is justified.

a

-mv ,,--- . ~-- ,,, .-v,e,,,,,_,,..n,,,,-nw- , ,,,, ,,,_ m.. m v.,,e-y, _mn.,_e,,,_ _m,nw..w,-.w.m. ,,w,,..,,,--

Page 96 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. DPIS1001-79B TER No.176 Sheet 1 of 2 h a.4 - Date:

Preparer:

Independent Review:

Date: N27 Date: 8[38[Pd Approval: .. M 4 A ?2 EQUIPMEH1 TYPE: Differential Pressure Switch MANUFACTURER: Barton MODEL: 289A Function To protect the RHR pumps from overheating at low flow rates, a minimum flow bypass pipeline, which routes water f rom the pump discharge to the A single suppression pool, is provided for each pair of pumps. Each motor-operated valve controls the condition of each bypass pipeline.

minimum flow bypass valve (i.e. M01001-18A, M01001-188) automatically opens DPIS1001-798 is used to sense upon sensing low flow in both injection lines.The valves automatically close when the flow in Loop B for this purpose.

flow approaches 20 percent of rated LPCI flow in either injection line.

Continued plant operation is justified on the following bases:

Aging Based on Conditions of aging were evaluated using the Arrhenius technique.

the analysis, which considered all non-metallic materials within the switch, an estimated life in excess of 40 years was established. This calculation supports projected operability of the differential pressure switch beyond 1986.

Pressure The service profile for the location of this device reaches a peak of 15.3 psia; whereas the test pressure reaches a maximum of 7" H2 O (14.95 psi).Bcsed The service profile is above 14.95 psia for approximately 18 seconds.

on this fact and the weathertight construction of the instrument, in our engineering judgment no functional disparities will occur.

Radiation DPIS1001-798 is qualified to a level of 3 x 10 6 rads. The levels of total are integrated accident dose plus 40 year normal dose for area 1.2 1.15 x 107 rads for LOCA and 1.08 x 107 rads for HELB with core damage.

f Page 97

=

BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION ..

Equipment identification No. DPIS1001-798 TER No.176 Sheet 2 of 2 .

Preparer: b Date: ( M Independent Review:

r Date: _ N#f <

Approval: NC Date: ihkk O

~

Cumulative doses over time for these events suggest a qualified mission time cf either 38 hours4.398148e-4 days <br />0.0106 hours <br />6.283069e-5 weeks <br />1.4459e-5 months <br /> post-LOCA or 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> post-HELB. Either period is considered of adequate duration to assure proper startup of RHR in the LPCI ..

mode following the respective event. To assure proper operation subsequent to this initial startup, a fully qualified instrument provides operators, in -

~

the Main Control Room, with indication of RHR loop flow. The eperators have also been provided with remote manual control of valves M01001-18A and M01001 -18B. Should it be evident to operators that kuR loop flow is less than normal, actions can be taken sufficiently early to preclude pump damage.

Temperature ,

The service profile for the location of this device is less severe than the test temperature profile. Peak service temperature of 229'F is higher than the test temperature of 212*F. However, the time duration that tha service I temperature is above 212*F is less than one minute. The test temperature is -

about 40*F higher than the service profile for the remainder of the test period (6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />). In our engineering judgment and based on preliminary ' ..

calculations for similar components, the internal temperature under the service condition should not reach the test temperature of 212'F. On this 'N basis, the temperature profile in the test report is actually more severe than the service temperature profile.

Steam Exposure A prototype of this component was subjected to 100% humidity for'6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. In ~ .

cur engineering judgment, this test was more severe than the environment to ..-

which this component may be subjected during an accident.

g

Page 98 BOETON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment identification No. DPIS1001-79A TER No.180 Sheet 1 of 2 Preparer: NO _ - m . Date: %l'l%fS4 Independent Review: \ L bue4O Date: fr 'ztJ fr4 01 U Approval: IAU44KIA Date: !8I

()

EQUIPMENT TYPE: Differential Pressure Switch MANUFACTURER: Barton MODEL: 289A l

F.pnction

' TohotecttheRHRpumpsfromoverheatingatlowflowrates,aminimumflow bypass pipeline, which routes water from the pump discharge to the suppression pool, is provided for each pair of pumps. A single

• motor-operated valve controls the condition of each bypass pipeline. Each l cinimum flow bypass valve (i.e. M01001-18A, M01001-18B) automatically opens l

upon sensing low flow in both injection lines. DPIS1001-79A is used to sense flow in loop A for this purpose. The valves automatically close when the flow approaches 20 percent of rated LPCI flow in either injection line.

Continued plant operation is justified on the following bases:

Agi_n.g Conditions of aging were evaluated using the Arrhenius technique. Based on the analysis, which considered all non-metallic materials within the switch, an estimated life in excess of 40 years was established. This calculation supports projected-operability of the dif ferential pressure switch beyond j 1986.

Pressure The service profile for the location of this device reaches a peak of 15.4 psia, whereas the test pressure reaches a maximum of 7" H2 O (14.95 psi).

The service profile is above 14.95 psia for approximately 18 seconds. Based on this fact and the weathertight construction of the instrument, in our cngineering judgment no functional disparities will occur.

i 4,

'4 Radiation I

DPIS1001-79A is qualified to a level of 3 x 106 rads. The levels of total integrated accident dose plus 40 year normal dose for area 1.1 are 1.14 x 107 rads for LOCA and 1.08 x 10 7 rads for HELB with core damage.

Page 99 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION l

Equipment Identification No. DPIS1001-79A TER No.180 Sheet 2 of 2 Preparer: GGCL - - Date: E 10 8 /84 Independent Review: N Date: @ 2 f4 Approval: Date: 6/ti[ff O

Cumulative doses over time for these events suggest a qualified mission time cf either 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> post-LOCA or 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> post-HELB. Either period is considered of adequate duration to assure proper startup of RHR in the LPCI mode following the respective event. To assure proper operation subsequent to this initial startup, a fully qualified instrument provides operators, in the Main Control Room, with indication of RHR loop flow. The operators have also been provided with remote manual control of valves M01001-18A and 188.

Should it be evident to operators that RHR loop flow is less than normal,

!- cctions can be taken sufficiently early to preclude pump damage.

Temperature ,

The service profile for the location of this device is less severe than the test temperature profile. Peak service temperature of 225'F is higher than the test temperature of 212*F. However, the time duration that the service temperature is above 212*F is less than one minute. The test temperature is about 40*F higher than the service profile for the remainder of the test period (6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />). In our engineerir.g judgment and based on preliminary calculations for similar components, the internal temperature under the service condition should not reach the test temperature of 212*F. On this basis, the temperature profile in the test report is actually more severe than the service temperature profile.

Steam Exposure A prototype of this component was subjected to 100% humidity for 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. In our engineering judgment, this test was more severe than the environment to which this component may be subjected during an accident.

Page 100 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION I

( Equipment Identification No. PS1451 A/8, PS1464A/B TER No.181(51/64 A), 208(51/64 B) Sheet 1 of 1 Preparer: - -

Data: i li Independent Review: Date: f/kPM7 Approval: b ~

Date: 9/to[f C/

i\

f EQUIPMENT TYPE: Pressure Switch MANUFACTURER: Static-0-Ring

} MODEL: SN-AA3-X2PP/5N-AA3-X3PP These pressure switches provide a permissive to the ADS system logic.

Automatic blowdown of the reactor vessel will not occur until indication of

~

satisfactory low pressure ECCS operation. These pressure switches provide indication of satisf actory Core Spray system operation.

Pipe Breaks Outside Containment and Pipe Breaks Inside Containment are the cnly design basis events which produce a harsh environment in the areas of these switches.

l ADS requires low-low reactor water level, high drywell pressure, indication of Core Spray or RHR pump discharge pressure and expiration of a 2 minute time delay relay in order to automatically actuate. For PB0C's, high drywell pressure will not occur and operator action would be necessary to maintain adequate core cooling. No failure modes associated with exposure of these switches to a PBOC produced harsh environment will prevent manual actuation cf ADS. Therefore, these switches do not need to be qualified for the Gffects of a PBOC.

These switches have been analyzed to 1 x 106 rads. For a PBIC, radiation levels of 1 x 106 rads are reached 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> af ter the pipe tareak. The FSAR credits operator action only when the operator can reasonably be expected to cccomplish the required action under the existing conditions. In our judgement, at 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> into the event, operator action to initiate ADS in accordance with NOD Procedure 5.4.2 if required, can reasonably be assumed.

Therefore, continued operation is justified.

l

Page 101 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION i

Equipment Identification No. PS1001-93A, B, C, D; PS1001-104A, B, C, D TER No.182(93A/C),182(104A/C), 209(93B/D), 209(1048/D) Sheet 1 of 1 Preparer:

Date: O

(

Independent Review: h Date: f/d/M Approval: [ ___

Date: M/f t/

(\

v

[ EQUIPMENT TYPE: Pressure Switch MANUFACTURER: Static-0-Ring MODEL: 5N-AA3-X5PP/5N-AA3-X3PP l

l These pressure switches provide a permissive to the ADS system logic.

Automatic blowdown of the reactor vessel will not occur until indication of satisfactory low pressure ECCS operation. These pressure switches provide i

indication of satisfactory RHR system operation.

Pipe Breaks Outside Containment and Pipe Breaks Inside Containtnent are the only design basis events which produce a harsh environment in the areas of these switches.

ADS requires low-low reactor water level, high drywell pressure, indication of Core Spray or RHR ;3 ump discharge pressure and expiration of a 2 minute time delay relay in order to automatically actuate. For PBOC's, high drywell pressure will not occur and operator action would be necessary to maintain adequate core cooling. No failure modes associated with exposure of these switches to a PBOC produced harsh environment will prevent manual actuation of ADS. Therefore, these switches do not need to be qualified for the effects of a PBOC.

These switches have been analyzed to 1 x 106 rads. For a PBIC, radiation levels of 1 x 106 rads are reached 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after the pipe break. The FSAR credits operator action only when the operator can reasonably be expected to accomplish the required action under the existing conditions. In our judgement, at 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> intc the event, operator action to initiate ADS in accordance with N0D Procedure 5.4.2 if required, can reasonably be assumed.

Therefore, continued operation is justified.

Page 102 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION I

Equipment Identification No. HPCIS Turbine Bearing Oil Pressure Switch TER No.185 Sheet 1 of 2 j

Preparer: Date: f/fNf -

Independent Review:

Date: N Approval: Date: 9[Z0!8k a _

I EQUIPMENT TYPE: Oil Pressure Switch MANUFACTURER: Square D MODEL: 9012 l

i This switch provides a permissive to start the HPCIS Auxiliary 011 Pump on I

system initiation. Af ter about 30 seconds of automatic turbine startep, the pressure supplied by the shaft driven oil pump is sufficient and this device signals the aux oil pump to stop. Failure of this switch to permit the pump start signal will result in a failure to open the two hydraulically l

centrolled turbine steam inlet valves, thus preventing system initiation on ~

demand. The functions of this switch, however, are required solely to assure satisfactory HPCIS operation.

The HPCIS is relied upon to operate during and following Loss of Feedwater Flow, Total Loss of Offsite Power, Shutdown from Outside Control Room (Special Event),

Pipe Break Inside Primary Containment, Control Rod Drop Accident, and Pipe Break Outside Primary Containment to assure continued core cooling, and thus mitigate consequences which could risult in potential of fsite exposures comparable to the 10CFR100 guidelines.

f N:;ne of the first three events listed above is expected to result in environmental conditions any more severe than those experienced during normal cperation. The fourth event is addressed 'n the HPCIS Safety Evaluation, which states that, "The HPCIS is designFJ to provide adequate core cooling fer small breaks... core never uncove s and is continuously cooled throughout the transient so that no core damage of any kind occurs for breaks that lie within the range of the HPCI." Thus, the size of LOCA presumed to generate postulated core damage is beyond the capacity of HPCIS to provide core cooling.

The Control Rod Drop Accident has been evaluated and no HPCIS equipment will be subjected to pressure, temperature, radiation or humidity conditions any more severe than those experienced during normal operation.

Page 103 BOSTON EDISON COMPANY I

JUSTIFICATION FOR CONTINUED OPERATION

( Equipment Identification No. HPCIS Turbine Bearing 011 Pressure Switch TER No.185 Sheet 2 of 2 Preparer: -

Date: hk Independent Review: -

Date: / Y Approval: Date: i/Lo[d 0

(

Those pipe breaks outside containment which could be expected to result in harsh conditions of pressure, temperature and humidity in the vicinity of the HPCIS Turbine Bearing Oil Pressure Switch are the PBOC-3 and the PBOC-5.

Each of these events, however, incapacitates the HPCIS. System operability is, therefore, not required for either PBOC.

On the other hand, system operability is required for the main steam line breaks, PBOC--7 and PB0C-8. However, FSAR analysis of the PNPS design basis Main Steam Line Break Accident indicates that, with a maximum 10.5 second MSIV closure and continued core coveraae (from normal or standby systems, ~

including HPCIS), there would be no fuel damage. Without core damage, exposures will not exceed 10 4 rads.

MSIV closure time is verified once per quarter under Technical Specification surveillance requirements. The closure time must be greater than 3 seconds and less than 5 seconds for the valve to be considered operable. For valve closure times shorter than 10.5 seconds, the postulated accident is considered less severe than that analyzed.

Core cooling systems are also verified operable periodically under plant surveillance requirements. Thus, if HPCIS was incapacitated as a consequence of the PBOC, then ADS, LPCI and Core Spray would be available to redundantly assure safe shutdown of the plant. If all core cooling systems operate as designed and tested, harsh radiation levels will not occur.

Therefore, continued operation is justified.

Page 104 BOSTON EDISON COMPANY JUSTIFICATION FOR l CONTINUED' OPERATION Equipment Identification No. PS1001-90A/D TER No.189b,c ( A, C), 203a, b (B, D) Sheet 1 of 1 Preparer: h Date: E!D!/Y Independent Review: er % Date: b Approval: &dO- - - - - Date: ff /T1/ 84 f \

w EQUIPMENT TYPE: Pressure Switch MANUFACTURER: Static-0-Ring MODEL: 12N-AA4-PP The function of these pressure switches is to provide a high drywell pressure permissive to start the RHR and Core Spray pumps. These switches will be exposed to a harsh steam and radiation environment following a PBOC-2B and 2T (Reactor Water Cleanup System Pipe Breaks) and a harsh radiation environment following a PBIC and all other PBOC's. .

From FSAR Appendix G, high drywell pressure does not result from a PBOC.

Therefore, actuation of these switches to mitigate the effects of a PBOC is not required.

.For PBIC's, radiation levels of 1 x 106 rads are not reached until at '. cast 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> after the pipe break occurs. As per GE letter the limiting materials are neoprene and Buna-N. Per D.O.R. Guidelines, Buna-N has a radiation threshold of 1 x 106 rads and neoprene a radiation threshold of 1 x 107 rads. Therefore, switch failure due to radiation would not be sxpected to occur until at least 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> af ter the pipe break. Automatic start of the RHR and Core Spray pumps would not be required at this time.

Therefore, continued operation is justified.

Page 105 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION i Equipment Identification No. PS-512A/D TER No.190 (A, B), 202 (C, D) Sheet 1 of 1 Preparer: Date:

Independent Review: I/ - Date: J'MM Approval: M_ U_ Date: T[E*[N v

EQUIPMENT TYPE: Pressure Switch MANUFACTURER: Static-0-Ring MODEL: 12NN-AA4-PP The function of these pressure switches is to provide a scram signal to the Reactor Protection System and to isolate Secondary Containment upon indication _of high drywell pressure. These pressure switches are exposed to

.- a harsh steam and radiation environment following PBOC-28 and 2T (Reactor Water Cleanup System Breaks) and a harsh radiacion environment following a -

PBIC and all other PB0C's.

According to FSAR Appendix G, PBOC's do not produce high drywell pressure.

Furthermore, subsequent failures of these pressure switches in the harsh rnvironment caused by these PBOC's will not reverse the previously accomplished safety functions of scram and secondary containment isolation.

Therefore, these switches do not need to be qualified for the effects of PBOC's.

For PBIC's, radiation levels of 1 x 106 rads are not reached until at least 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> af ter the pipe break occurs. As per GE letter the limiting materials are neoprene and Buna-N. Per D.O.R. Guidelines, Buna-N has a radiation threshold of 1 x 106 rads and neoprene a radiation threshold of 1 x 107 rads. Therefore, switch failure due to radiation would not be expected to occur until at least 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> after the pipe break. The scram and secondary containment isolation functions would have been completed prior to this time.

Therefore, continued operation is justified.

- ~ -

s.- - -

-,-,.,,,.,n.- - - - - , - - - , - , - , - , , , a,.-- - - - - , -

Page 106 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION I Equipment Identification No. PS1001-89A/D f TER No.191 ( A), 205 (B),189a (C),197 (D) Sheet 1 of 1 Preparer: MIMet Date: f//fk Independent Review: Date: 7!!T !?'[

Approval: Date: T fi

(\

v EQUIPMENT TYPE: Pressure Switch MANUFACTURER: Static-0-Ring MODEL: 12N-AA4-PP  !

The function of these pressure switches is to provide a high drywell pressure permissive to the ADS initiation logic. These switches are exposed to a harsh steam and radiation environment following PBOC -2B and 2T (Reactor i' Water Cleanup System Pipe Breaks) and a harsh radiation environment following a PBIC and all other PB0C's. ,

According to FSAR Appendix G, PB0C's do not produce high drywell pressure.

Operator action is credited in the PNPS Emergency Operating Procedures to initiate ADS if required. Subsequent failure of these switches caused by a harsh environment will not prevent manual operation of ADS from the control room. Therefore, these switches do not need to be qualified for the ef fects of PB0C's.

For PBIC's, radiation levels of 1 x 10 6 rads are not reached until at least 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> af ter the pipe break occurs. As per GE letter the limiting materials are neoprene and Buna-N. Per D.O.R. Guidelines, Buna-N has a radiation threshold of 1 x 106 rads and neoprene a radiation threshold of 1 x 107 rads. Therefore, switch failure due to radiation would not be expected to occur until at least 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> af ter the pipe break. RCS depressurization will have been completed prior to this time in accordance with the requirements of NOD Procedure 5.4.2.

Therefore, continued operation is justified.

Page 107 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. PS1001-83A/D l TER No. 192 (A), 193 (C). 198 (D), 204 (B) Sheet 1 of 1

Preparer

.b Date: 8!24!P4 Independent Review: krY Date: V![

Approval:- NL - Date: 8I2 W i4 sN v

EQUIPNENT TYPE: Pressure Switch MANUFACTURER: Static-0-Ring 140 DEL: 12N-AA4-PP/12N-AA4-X2PP/12N-AA5 I

These pressure switches provide a drywell pressure permissive to the control logic of RHR valves 1001-23A/B,1001-26A/B and 1001-37A/B. These valves must cpen in order to provide drywell and suppression pool spray for the purpose

. cf primary containment cooling. These pressure switches may be exposed to c

> harsh steam and radiation environment following PBOC-2B and 2T (Reactor Water Cleanup System Pipe Breaks) and a harsh radiation environment following a ,

PBIC and all other PBOC's.

From FSAR Section 5, the Containment Spray Subsystem provides containment spray capability as an alternate method for reducing containment pressure following a LOCA. This subsystem is designed to remove energy from the drywell by condensing steam or to cool noncondensable gases which have collected in the suppression pool. Since a PBOC does not result in these conditions, these pressure switches do not need to be able to withstand the environmental conditions associated with PBOC's.

For PBIC's, radiation levels of 1 x 106 rads are not reached until at least 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> after the pipe break occurs. As per GE letter the limiting materials are neoprene and Buna-N. Per D.O.R. Guidelines, Buna-N has a radiation threshold of 1 x 106 rads arid neoprene a radiation threshold of 1 x 107 rads. Therefore, switch failure due to radiation would not be cxpected to occur until at least 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> after the pipe break. It can reasonably be assumed that the containment spray subsystem would not be required at this time.

Therefore, continued operation is justified.

Page 108 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION I

Equipment identification Mo. PS1360-9 (A-D)

TER No. 194 Sheet 1 of 3 Preparer: b5 Date: f(f24!ff Independent Review:

v-IN -

'M - Date: I&

Ap; o ': NM >y >" Date:  %/27/24 i \

v i

EQUIPMENT TYPE: Pressure Switch MANUFACTURER: Barksdale MODEL: PlH-M855SS-V PS1360-9 (A-D) are Barksdale model PlH-M85SS-V pressure switches used to sense low pressure in the steam line supply lines to the RCIC pump turbine.

l- The switches are used to signal the closure of two motor operated valves in the.RCIC steam supply line in order to prevent steam and radioactive gases from escaping through the turbine shaft seals into the reactor building over -

a 30 day mission length. This protection is only required after reactor steam pressure has decreased to such a low value.that the turbine can no longer be operated (approximately 100 psig or less). This condition is

! expected to be reached during reactor vessel cooldown and depressurization within a few minutes following a LOCA or approximately 6-8 hrs following a small break PBIC or PBOC. It is expected that the reactor vessel will reach atmospheric pressure.approximately 2-4 hours later at which time, this protective function will no longer be required. These switches are mounted in the RCIC steam leak instrument rack (C2257-B) located in the mezzanine of the RCIC c',adrant. These switches could be exposed to a harsh superheated steam ao radiation environment during a PBOC-5 (HPCI steam line break in the torus compartment) or PBOC-6 (RCIC steam line leak in the RCIC pump room) or to solely a harsh radiation environment during any other PBOC or a PBIC.

Continued operation with these switches can be justified based on the following analyses.

.lustification o Temperature and Humidity The PBOC-5 service profile (246'F maximum and 100% RH) exceeds the test profile (extended exposure to saturated steam at 212*F) for approximately the first 3 minutes of the transient. However, the thermal inertia of the switch and instrument rack in the presence of superheated steam should result in the temperatures actually experienced in the vital portions of the switch being enveloped by the test profile. In the unlikely event the switches did fail, two scenarios could occur. If the switch failed closed, RCIC, which is not credited for this transient, would remain isolated. If the switch failed

Page 109 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipnent Identification No. PS1360-9 (A-D)

TER No.194 Sheet 2 of 3 Preparer: N Date:  ?!24ffg Independent Review: Date: '

f Approval: MG Date: ti/27/g4

. A v

cpen, the control room operator could be reasonably assumed to close the valves several hours later following reactor vessel cooldown/depressurization End temination of RCIC.

The.P80C-6 service profile (short term exposure to 155'F and 90% humidity) is

( less severe than the test profile (extended exposure at 212*F and 100%

relative humidity) as documented in AETL Test Report 596-0398. Therefore, the test temperature profile in the test is actually more severe than the ,

service condition and continued operation of the plant is justified.

l~

! e Pressure The service profile reaches a peak of 14.9 psia, whereas the test pressure reaches a maximum of 7"2H O (14.95 psia). Based on this fact and due to

weathertight construction of this instrument, in our engineering judgment, no functional disparities will occur. Therefore, continued plant operation is justified.

o Radiation From a Wyle Labs analysis of the materials used for construction of this component, the most limiting material is a fiberboard type insulator which has a dar:. age threshold of approximately 106 rads for this application. The leak tight nature of the switch is expected to preclude beta radiation exposure to this components. It is estimated that the gama dose to this component will meet the 10 6 threshold approximately 400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> following a LOCA. It is expected that the RCIC steam line would have isolated tn low pressure and sealed in prior to this time. In the event that this exposure induced a failure of the switch, the steam line valves would be capable of opening if the operator reset the isolation and either the operator held the control switches in the open position or a low reactor vessel level or high drywell pressure was sensed. In the unlikely event that these conditions were met, opening of the valves would have a negligible effect on the ability to maintain exposures below 10CFR100 limits since RCIC operation should be l

Page 110 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION l Equipment identification No. PS1360-9 (A-D)

TER No.194 Sheet 3 of 3 Preparer: N Date: 24 !P4 Independent Review: dl Date: ff Approval: G Date:  %/1~1/24

, N v

completed and the reactor vessel would be expected to be nearing a cold depressurized condition at the time the damage threshold would be reached.

In addition, failure of the switch would not inhibit the ability to reclose these valves. Continued operation is justified.

o Aging Wyle Labs has completed aging and thermal degradation analyses that confirm that the six hour qualification exposure documented in AETL Test Report 596-0398, envelopes the conditions experienced at PNPS over 40 years and a 30 -

day mission length accident exposure for these switches.

Page 111 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION l Equipment Identification No. PS2368A, PS2368B TER No.195 Sheet 1 of 3

~

Preparer: Mb Date: 9/MM Independent Review:

Date: /i!FT Approval: 1 lb

-p Date: 9,[2M!Y V

EQUIPMENT TYPE: Pressure Switch MANUFACTURER: Barksdale MODEL: B2T-M12SS The HPCIS turbine is automatically shutdown by tripping the turbine stop valve closed on any of several signals. One of those signals is high turbine exhaust pressure as sensed by PS2368A and PS23688. These switches serve

~

( - their safety-related f unction only during HPCIS operation to assure the physical integrity of the turbine exhaust pipeline. .

The HPCIS is relied upon to operate during and following Loss of Feedwater Flow, Total Loss of Offsite Power, Shutdown from Outside Control Room (Special Event),

Pipe Break Inside Primary Containment, Control Rod Drop Accident, and Pipe Break Outside Primary Containment to assure continued core cooling, and thus mitigate consequences which could result in potential offsite exposures comparable to the 10CFR100 guidelines.

None of the first three events listed above is expected'to result in environmental conditions any more severe than those experienced during normal operation. The fourth event is addressed in the HPCIS Safety Evaluation, which states that, "The HPCIS is designed to provide adequate core cooling for small breaks... core never uncovers and is continuously cooled throughout the transient so that no core damage of any kind occurs for breaks that lie within the range of the HPCI." Thus, the size of LOCA presumed to generate postulated core damage is beyond the capacity of HPCIS to provide core cooling.

The Control Rod Drop Accident has been evaluated and no HPCIS equipment will be subjected to pressure, temperature, radiation or humidity conditions any more severe than those experienced during r.ormal operation.

1 Page 112 4

BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. PS2368A, PS2368B TER No. 195 Sheet 2 of a Preparer: ~7- Date: [h h ^

Independent Review: '

Date: i 9 Approval: -

M Date: T!M s s N

(\

v Those pipe breaks outside containment which could be expected to result in harsh conditions of pressure, temperature and humidity in the vicinity of the pressure switches are the PBOC-3 and the PBOC-5. Each of these events, however, incapacitates the HPCIS. System operability is, therefore, not required for either P80C.

On the other hand, system operability is required for the main steam line breaks, PBOC-7 and PB0C-8. However, FSAR analysis of the PNPS design basis Main Steam Line Break Accident indicates that, with a maximum 10.5 second MSIV closure and continued core coverage (from normal or standby systems, ,

including HPCIS), there would be no fuel damage. Without core damage, exposures will not exceed 10 4 rads.

MSIV closure time is verified once per quarter under Technical Specification surveillance requirements. The closure time must be greater than 3 seconds and less than 5 seconds for the valve to be considered operable. For valve closure times shorter than 10.5 seconds, the postulated accident is considered less severe than that analyzed.

Core cooling systems are also verified operable periodically under plant surveillance requirements. Thus, if HPCIS was incapacitated as a consequence cf the PBOC, then ADS, LPCI and Core Spray would be available to redundantly assure safe shutdown of the plant. If all core cooling systems operate as designed and tested, harsh radiation levels will not occur.

Therefore, continued operation is justified.

J w se , - - - -- - - , , , , , -- - , , - - . - - , - - - , - , , - , . - , .,-e--,-.,,----,------,,,,wr, -n,-->.---m,.

Page 113 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION l

Egyipment Identification No. PS2360-1 L TER No. 196 Sheet 1 of 3 Preparer: -

Date: U Independent Review: I[d"7- -

Date: Mfh Approval: Se Date: 9[2c.[fd, nv EQUIPMENT TYPE:: Pressure Switch MANUFACTURER: Barksdale MODEL: D2H-M150-SS This pressure switch detects HPCI pump low suction pressure and is, j -therefore, required solely to assure satisfactory HPCIS operation.

', The HPCIS is relied upon to operate during and following Loss of Feedwater Flow,

• Total Loss of Offsite Power, Shutdown from Outside Control Room (Special Event),

Pipe Break Inside Primary Containment, Control Rod Drop Accident, and

> Pipe Break Outside Primary Containment to assure continued core cooling, and thus mitigate consequences which could result in potential offsite exposures comparable to the 10CFR100 guidelines.

None of the first three events listed above is expected to result in Gnvironmental conditions any more severe than those experienced during normal cperation. The fourth event is addressed in the HPCIS Safety Evaluation, which states that, "The HPCIS is designed to provide adequate core cooling for small breaks... core never uncovers and is continuously cooled throughout the transient so that no core damage of any kind occurs for breaks that lie within the range of the HPCI." Thus, the size of LOCA presumed to generate postulated core damage is beyond the capacity of HPCIS to provide core cooling.

The Control Rod Drop Accident has been evaluated and no HPCIS equipment will be subjected to pressure, temperature, radiation or humidity conditions any more severe than those experienced during normal operation.

Those pipe breaks outside containment which could be expected to result in harsh conditions of pressure, temperature and humidity in the vicinity of I this pressure switch is the PBOC-3 and the PBOC-5. Each of these events, however, incapacitates the HPCIS. System operability is, therefore, not required for either PBOC.

Page 114 l

l BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. PS2360-1 TER No. 196 Sheet 2 of A Date: l Preparer:

Independent Review: M [M Date: fM////

Approval: ._

Date: f24[f n

v On the other hand, system operability is required for the main steam line breaks, PBOC-7 and PBOC-8. However, FSAR analysis of the PNPS design basis Main Steam Line Break Accident indicates that, with a maximum 10.5 second MSIV closure and continued core coverage (from normal or standby systems, including HPCIS), there would be no fuel damage. Without core damage, exposures will not exceed 10 4 rads.

MSIV closure time is verified once per quarter under Technical Specification

- surveillance requirements. The closure time must be greater than 3 seconds and less than 5 seconds for the valve to be considered operable. For valve closure times shorter than 10.5 seconds, the postulated accident is -

considered less severe than that analyzed.

Core cooling systems are also verified operable periodically under plant surveillance requirements. Thus, if HPCIS was incapacitated as a consequence of the PBOC, then ADS, LPCI and Core Spray would be available to redurdantly assure safe shutdown of the plant. If all core cooling systems operate as designed and tested, harsh radiation levels will not occur.

Therefore, continued operation is justified.

l l

Page 115 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. PS-2389 (A-D)

TER No. 207 Sheet 1 of 3 Preparer: Date: M Independent Review: \v b h8k/ v

> Date: 2 4 b4

=

l Approval: R A D -- m Date: T/17 /M N l

-J l

EQUIPMENT TYPE: Pressure Switch MANUFACTURER: Barksdale MODEL: PlH-M855SS-V PS-2389(A-D) are 8arksdale model PlH-M85SS-V pressure switches used to sense low pressuie in the steam line supply lines to the HPCI pump turbine. The switches are used to signal the closure of two motor operated valves in the HPCI steam supply line in order to prevent steam and radioactive gases from escaping through the turbine shaft seals into the reactor building. This protection is only required af ter reactor steam pressure has decreased to .

such a low value that the turbine can no longer be operated (approximately 100 psig or less). This condition is expected to be reached during reactor vessel cooldown and depressurization within a few minutes following a LOCA or approximately 6-8 hrs following a small break PBIC or PBOC. It is expected that the reactor vessel will reach atmospheric pressure approximately 2-4 hours later at which time, this protective function will no longer be required. These switches are mounted in the HPCI steam leak instrument rack (C2257-A) located in the NW RHR quadrant. These switches could be exposed to a harsh superheated steam and radiation environment during a PBOC-5 (HPCI steam line break in the torus compartment) or to solely a harsh radiation Environment during any other PBOC or a PBIC. Continued operation with these switches can be justified based on the following analyses.

Analytical Justification o Temperature and Humidity

> AETL Test Report 596-0398 documents the qualification test'ng of a similar component in a harsh steam environment. The test profile consisted of a rise to 212*F in an unspecified time with a dwell at 212*F for six hours.

However, the PBOC-5 Service profile for this location consists of a rapid spike to 229'F with a return to less than 212*F in less than 3 minutes. It is our engineering judgment that due to the thermal inertia of the components, the internal temperature experienced by these switches during the predicted service event will be significantly less than that which was experienced in the test. Therefore, the test temperature profile is essentially more severe than the service conditions and continued operation of the plant is justified. It should be noted that HPCI operation is not

Page 116 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment identification No. PS-2389 (A-D)

TER No. 207 Sheet 2 of 3 l

Preparer:

^

Date: U Y Independent Review: S/-b MU O Date: b24 Approval: @(/ .-

rw N Date:  % 177/F4 l required during this transient and that the valves controlled by these switches will be automatically closed in response to increased HPCI flow and space temperature resulting from the leak.

o Pressure The service profile reaches a peak pressure of 15.3 psia and decays to atmospheric pressure within seconds. In our engineering judgment, exposure to this pressure change will muse no functional disparities due to

. weathertight construction of these switches. It shnuld be noted that HPCI cperation is not required during this transient and that the valves controlled by these switches will be automatically closed in response to increased HPCI flow and space temperature resulting from the leak. -

Therefore, continued plant operation is justified.

o Radiation From a Wyle Labs analysis of the materials used for construction of this component, the most limiting material is a fiberboard type insulator which has a damage threshold of approximately 106 rads for this application. The leak tight nature of the switch is expected to preclude beta radiation exposure to this components. It is estimated that the gamma dose to this component will meet the 106 threshold approximately 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> following a LOCA. It is expected that the HPCI steam line would have isolated on low pressure prior to this time. In the unlikely event that this exposure

' induced a failure of the switch, the steam line valves would be capable of opening if the operator held the control switches in the open position or if a low reactor vessel level or high drywell pressure is sensed. In the unlikely event that these conditions were met, opening of the valves would have a negligible effect on the ability to maintain exposures below 10CFR100 limits since HPCI operation should be completed and the reactor vessel would be expected to be nearing a cold depressurized condition at the time the damage threshold would be reached. In addition, failure of the switch would not inhibit the operators ability to reclose these valves. Continued operation is justified.

rdgt2 A1/

BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment identification No. PS-2389 (A-0)

TER No. 207 Sheet 3 of 3 Preparer: Yk ---

Date:  ?!M[F'[

Independent Review: Date: R 74 , EI Approval: C- - - - Date:  %/2")124 (v T o Aging Wyle Labs has completed aging and thermal degradation analyses that confirm that the six hour qualification exposure documented in AETL Test Report 596-0398, envelopes the conditions experienced at PNPS over 40 years and a 30 day mission length accident exposure for these switches.

4 i

" ~ ~w ,,,,-e --- - - ~ - - -. ~ . - - , , ,. , , s,

Page 118 BOSTON EDISON COMPANY i JUSTIFICATION FOR l CONTINUED OPERATION Equipment Identification No. LIS-263-72A,LIS-263-72B, LIS-263-72C, LIS-263-72D TER No. 213b, 212a, 213a, 212b Sheet 1 of 2 Preparer: M Date: M2vh Independent Review:

Date: D 1

Approval: N Date: t/'23 / % l

(

~

\ l 1

EQUIPMENT TYPE: Level Indicating Switch MANUFACTURER: Yarway MODEL: 4418C The function of these level switches is to provide automatic initiation signals to the ECCS, RCIC and Diesel Generators on reactor water level of

-49" and to trip the HPCI and RCIC turbines on reactor water level of +48".

These level switches are Yarway Model 4418C. These switches are believed to be qualified with the exception of the mercury switches which are installed in this model.

The only events which result in a harsh envircament at the location Of these .

level switches are PBOC's and P81C's.

For PBOC's, only Reactor Water Cleanup System breaks result in a harsh environment at the switch locations. The service profile for these areas reaches a peak pressure of 15.3 psig at 4.9 seconds und a peak temperature of 189.6*F at 29 seconds. The pressure transient is over at 7 seconds when the pressure has dropped to essentially atmospheric pressure. In our engineering judgment, the mercury switch will undergo no functional disparities as a result of exposure to this service profile. If the feedwater system remains in service af ter reactor scram, then a low-low water level of -49" will not be reached. If feedwater is not available, then reactor water level will quickly drop to -49" and ECCS initiation will result. This water level will occur prior to reaching harsh radiation levels at 10 minutes. If these switches fail and cause a trip of HPCI and RCIC on a spurious high water

-level signal, the operator would have at least 10 minutes to utilize ADS to blowdown the reactor vessel so that ccre cooling can be mair.tained by low pressure ECCS. With the exception of the HPCI and RCIC systems, no failure mode of these switches could result in reversal of a completed safety action or prevent the accomplishment of any other safety action.

For a PBIC, radiation levels do not significantly increase above normal levels until 10 minutes after the break has occurred. % r pipe breaks that are in the range of unassisted HPCI performance, no fuci damage occurs and radiation levels do not significantly increase above normal levels. For larger pipe breaks, reactor water level will drop to -49" before radiation

,3 ._,

BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. LIS-263-72A,LIS-263-72B, LIS-263-72C, LIS-263-72D TER No. 213b, 212a, 213a, 212b Sheet 2 of 2 Preparer: kk Date: [hM/ '

Date: AT IT Independent Review:

NtkCL Date: ElT) / R6 Approval:

<\

v In addition, high drywell levels significantly increase above normal levels.

pressure which will result from a PBIC will provide automatic initiation of LPCI, Core Spray, HPCI, RCIC and the Diesel Generators.

Therefore, continued operation is justified.

O I

l l

h Page 120 i

i BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION w

Equipment Identification No. LIS263-57A, LIS263-578, LIS263-58A, LIS263-58B

~TER No. 214b, 214a, 210, 211 Sheet 1 of 2 Preparer:

b" Date: /M/

Independent Review:

Date: T!li F'/

Date: hl,o[N Approval: . -1 _2dtMg v

EQUIPMENT TYPE: Level Indicating Switch MANUFACTURER: Yarway MODEL: 4418C The function of.these level switches is to provide recirculation pump trip, rtactor building isolation, reactor scram and isolation of various If reactor primary water ccntainment penetrations on low reactor water level (+9").

level drops to low-low level (-49") then they effect main steam lineThese level sw isolation and recirculation pump trip.

4418C.

These switches are believed to be qualified with the exception of the mercury switches which are installed in this model. '

The only events which result in a harsh environment at the location of these level switches are Pipe Breaks Outside Containment (PBOC) and Pipe Breaks Inside Containment (PBIC).

For P80C's, only Reactor Water Cleanup System breaks result in a harsh l Calculations indicate that a reactor environmer.t at the is switch locations.

reached at 23 seconds af ter this pipe break occurs.

water level of +9" The service profile for these areas reaches a peak pressure ofThe 15.3 psig at pressure 4.9 seconds and a peak temperature of 189.6*F at 29 seconds.

transient is over at 7 seconds when the pressure has dropped to essentially In our engineering judgment, the mercury switch will atmospheric pressure.inctional disparities as a result of exposure to this service l undr' * - .he feedwater system remains in service af ter reactor scram, l p r- If feedwater is not 1 t' aw water level of -49" will not be reached. 49" and main steam

- ten reactor water level will quickly drop to -

on will result. This water level will occur prior to reaching tion levels at 10 minutes.

In the .itghly unlikely event that long term exposure to the humidity inherent in result.

P80C causes switch failure, then spurious closure of the In addition,

' when closure of the MSIVs following cooldown would be eminent.

the operating staff would have sufficient opportunity at this point in post transient recovery, to jumper between points DD-1 to DD-2, and 88-1 to BB-2 i

. - - _ - _ -. _ _ _ _ _ , . . _ ,~ .. , _ ._ _ __ _ .. _ __. _ ,_._ _ __ _ ._. _ .____ _ _.-___ , . _ _ . _ -

l BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. LIS263-57A, LIS263-578, LIS263-58A, LIS263-588 TER No. 214b, 214a, 210, 211 Sheet 2 of 2 Preparer: I/IOm _ Date: 9If[//

~

Date: li Y Independent Review:

Approval:

Date: '

20ffd

(\

v in panel 915 in the cable spreading room and points 00-1 to DD-2 and 88-1 and BB-2 in panel 917 in the cable spreading room to eliminate these switches from these circuits.

For a PBIC, radiation levels do not significantly increase above normal levels until 10 minutes af ter the break has occurred. For pipe breaks that are in the range of unassisted HPCI performance, no fuel damage occursFor and radiation levels do not significantly increase above normal levels.

larger pipe breaks, reactor water level will drop to In -49" before high addition, radiation drywell levels significantly increase above normal levels. As a pressure will result from PBIC's and quickly cause a reactor scram.

- backup to MSIV closure, if fuel damage occurs, the main steam line radiation monitors will close the MSIV's.

For both PBIC's and PBOC's, no subsequent failure modes of these switches will result in reversal of a completed safety action or prevent other 5.sfety actions from being accomplished.

Therefore, continued operation is justified. .

---a - --- - -, ,--y p , ,p ---,y-.3 ,,,r

EOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION y Equipment Identification No. LITS 263-73A, LITS 263-73B TER No. 227 (A), 226 (8) Sheet 1 of 1 M N Preparer: hbW Date:

^

Date: d N Independent Review:

b Date: S Wf Y Approval:

O l

EQUIPMEN1 TYPE: Level Indicating Switch MANUFACTURER: Yarway MODEL: 4418EC The function of these switches is to provide reactor water level indication in the main control room and to provide a reactor water level permissive to the containment spray subsystem of the RHR system.

- The safety-related display function of these switches has been replaced These by

> - Rosemount dif ferential pressure transmitters DPT1001-650A & B.

Rosemount transmitters Model 1153 Series 8 are qualified per IEEE-323-1974 and the 00R guidelines to test conditions in excess of the cnd IEEE-344-1975

service conditions.

' The containment spray subsystem provides containment spray capability as an A PBIC alternate method for reducing containment pressure fellowing a PBIC. A harsh could produce a harsh radiation environment at the switch locations.

radiation level After this would notswitch time, be exceeded failure dueuntil 1/2 hourcould to radiation af teroccur.

the accident occurred.

However, a keylocked manual override switch located 'n the main control room i s provided to completely bypass the 2/3 core coverage permissive in the containment spray logic so that manual operation of containment spray could still be accomplished.

Therefore, continued operation is justified.

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- . . . .. .~ _ . . .. _ _ ~ . .- _ . . . . . - . . . . . . ._ .

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B03 TON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION _

j i

Equipment Identification No. LS2351 A, LS23518 3 TER No. 232 Sheet 1 of 2 ,

Preparer: [b Date: f//f/M Independent Review:

~

Date: 77 Approval: bh A Date: Ntofff -

V ==

=

EQUIPMENT TYPE:

11ANUF ACTURER:

Level Switch Robertshaw

]

MODEL: SL-702A1 _2 These level switches provide signals to HPCIS valves M02301-35 and -

U M02301-36. On high suppression pool water level, the valves are automatically opened to shift HPCIS pump suction from the condensate storage tanks to the suppression pool. Because this opening cannot occur in the 3

. presence of a system isolation signal, failure of either or both level 18 switches will not impair the isolation function of the torus suction valves.

~ ",

Also, when the HPCIS is not operating, these level switches will serve no safety-related function (since suppression pool water level will not be -

affected by opening of the torus suction valves). These devices are Y therefore, required to function only during HPCIS operation. 9

==

The HPCIS is relied upon to operate during and following -

A Loss of Feedwater Flow, d Total Loss of Offsite Power, T Shutdown from Outside Control Room (Special Event), f Pipe Break Inside Primary Containment, -

Control Rod Drop Accident, and '

Pipe Break Outside Primary Containment T

to assure continued core cooling, and thus mitigate consequences which could -

result in potential of f site exposures comparable to the 10CFR100 guidelines. s~

None of the first three events listed above is expected to result in i environmental conditions any more severe than those experienced during normal -

operation. The fourth event is addressed in the HPCIS Safety Evaluation, i which states that, "The HPCIS is designed to provide adequate core cooling F for small breaks... core never uncovers and is continuously cooled throughout i the transient so that no core damage of any kind occurs for breaks that lie within the range of the HPCI." Thus, the size of LOCA presumed to generate *

?

postulated core damage is beyond the capacity of hPCIS to provide core cooling.  :

x

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-I s

BOSTON EDISON COMP 1.NY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. LS2351A, LS2351B TER No. 232 Sheet 2 of A . . _ 4 Preparer: / Date: _ [//M[

Independent Review: -

Date: 7 Approval: _

w Date: 2 94

()

- .m

.}

The Control Rod Drop Accident has been evaluated and no HFCIS equipment will be subjected to pressure, temperature, radiation or humidity condit ions any more severe than those experienced during normal operation.

Those pipe breaks outside containment which couls' be expected to result in .

harsh conditions of pressure, temperature and h)midity in the vicinity of the level switches are the ?30C-3 and tha 080C-5. Lach of these events, however, incapacitates the HNIS. System operability is, therefore, not required f either Po0C.

On the other hand, system operability is required f or the main steam line breaks, PBOC-7 and PB0C-8. However, FSAR analysis of the PNPS design basis -

Main Steam Line Break Accident indicates that, with a maximum 10.5 second MSIV closure and cor.tinued core coverage (from normal or standby systems, including HPCIS), there would be no fuel dar. age. Without core damage, .- .

4 exposures will not exceed 10 4 rads.

MSIV closure time is verified once per quarter under Technical Specification { -}

surveillance requirements. The closure time must be greater than 3 seconds '3; and less than 5 seconds for the valve to be coniidered operable. For valve '

di W-closure times shorter than 10.5 seconds, the postulated accident is s considered Icss severe than that analyzed. -j Core cooling systems are also verified operable periodically under plant surveillar.;e requirements. Thus, if HPCIS was incapacitated as a consequence of the PB0C, then ADS, LPCI and Core Spray would be available to redundantly -

assure safe shutdown of the plant. If all core cooling systems operate as designed and tested, harsh radiation leve'.s will not 3ecur.

Theref ore, continued operation is ju'tified.

g.

Page 125 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPEdATION i

Equipment identification No. GE Cable-Model S157275 Inside Drywell TER No. 250 Sheet 1 of 1 Preparer: NS D' ate : 8I I Independent Review: -7 Date: h/ f f

Approval: CSLCL Date: Birt /%

.N v

l EQUIPMENT TYPE: Cable l

MANUFACTURER: General Electric MODEL: 5157275 l

This component is GE Vulkene SIS switchboard wire which is fully qualified by test for all requirements except that the test radiation value is 4E7 rads gansna while the actual accident requirement is 6.3E7 gamma and 8.5E8 beta.

Per DDR Guidelines, the minimum insulation thickness of 0.030 allows reduction of the beta dose to 8.5E7 making the total dose 14.8E7.

~

Franklin Institute Test report F-C2920 documents exposure of GE "Vulkene" non-jacketed single conductor cable to levels of radiation up to SE8 gamma with subsequent LOCA testing. While not specifically referencing Model E57275, these tests were conducted prior to GE's introduction of "Vulkene Supreme" and can be considered to be generically applicable to #57275 Vulkene insulation.

This test, coupled with the actual specimen performance documented in the

1. 577.75 qualification test, is sufficient to justify continued operation.

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Page 126

)

BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION

l. ,

i Equipraent Identification No. HS-1 A, 2A, 3A, 4A,18, 2B, 3B, 48 TER No. 256 -Sheet 1 of 1

• 1

,2 l P eparer:

Date: EbTffY Independent Review: kl.

0 0 b Date: 8!24ff4 Approval: T b.... . Date: RI? 7/Rd N

V EQUIPMENT TYPE: Humidity Sensor l MANUFACTURER: Honeywell MODEL: Q464A These relative humidity sensors are not required for Standby Gas Treatment System (SGTS) Operation. The normal function of these sensors is to detect high humidity in the SGTS inlet and energize relays, which in turn cause the heater relays and heaters to be energized. The humidity controls have been

(~ bypassed, so that full heater operation is initiated upon operation of the SGTS exhaust fan. Therefore, continued plant operation is justified.

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Page 127 l

BOSTON EDISON COMPANY JUSTIFICATION FOR l CONTINUED OPERATION

' Equipment identification No. TSW-1 A, TSW-1B HTR T.S.

TER Fo. 258 Sheet 1 of 1 .

Preparer:

- Date: / T!D Independent Review: M MA% - Date: f///M Approval: MN (\

Date:

• 2b[f'I V

EQUIPMENT TYPE: Temperature Switch

( MANUFACTURER: Fenwal MODEL: 40-102010-115 These temperature switches provide a safety high temperature shut-of f of the SGTS heaters (VGTF201A, B). Operation of the SGTS is only required post LOCA cnd the harsh environment to which SGTS is exposed is only radiation . The dose in the braa is approximately 5.6 x 107 rads. They are capillary tube type of tempt < <t; ire switches with the following chemical compounds in the capillary tube:

l 1. Ortho-terphenyl 30%

2. Dipheny-ether 50%

3. Biphenyl 20%

The damage threshold of these components is at least 1 x 109 rads.

Therefore, continued plant operation is justified.

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Page 128 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION e EquiDment Identification No. C68. C69relay /xfmr/ wire heater TER No. 259, 260, 261, 262 Sheet 1 of 1 A---^ Date: f!/ 7 [8'/ '

Preparer:

Independent Review:

Date: h//M Date: T t,Dk Y Approval: , '

/T v

EQUIPMENT TYPE: Contactor/Transf ormer/ Wire MANUFACTURER: Allen Bradley/Sola/ Unknown l MODEL: 7000C-N200Z1/047645/ Unknown Transformer l

The mantif acturer and model listed inThe the transformer Franklin TERis only(#260) are incorrect.

required The transformer was manufactured by Sola.

)~ to operate post-LOCA, and is not subjected to excessive temperature and pressure. The transformer materials include kraf t paper, mylar tape, cotton, 5 ,

and polyester; all of which have a damage threshold greater than 2 x 10 rads. The amount of radiation to which the tralsformer may be subjected is 1.1 x 10 5 rads, therefore continued plant operation is justified.

Contaggr and Wire are not required

! 1he heater contactors They are only required to operate post-LOCA and af ter a fuel (TER #261) and wire (TER #259/#262) post- PB0C.

handling accident. A component specific calculation was performed 5 rads, if on panels SGTS

( C68 and C69. The result was a worst case dose of 1.1 x 10 Wyle Labs has recently performed a f

.cperated 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day post-LOCA. radiation materials analysis that determined These components calculated exposure without suffering deleterious effects.

' are therefore considered to be qualified pending receipt and review of the Research performed by EPRI has indicated that with the subject analysis. exception of Teflon, all potential wire insulation materials have a radiatio t-threshold level greater than the radiation dose experienced at these panels.

) However, Teflon did not exhibit a 25% loss in tensile-strength until the samples had received a dose in excess of that experienced at these panels.

Therefore, the insulation material will not fail and continued operation is l

I justif M -

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Page 129 BOSTON EDISON COMPANY

! JUSTIFICATION FOR CONTINUED OPERATION l

Equipment Identification No. Electroswitch 24/40 in Alternate Shutdown Panels TER No. 264, 266 Sheet 1 of 3 I

Preparer: b Date: M M Independent Review: rd Dt.t e : M2M f

Approval: L./kmh Date: h7/f!fQ A

EQUIPMENT TYPE: Panel Control Switches MANUFACTURER: Electroswitch MODEL: 24/40 The switches are located in remote shutdown panels which provide a means df accomplishing a safe shutdown of the plant from outside the main control room. They are not required to operate in a PBOC or LOCA. However, the switches must be demonstrated to not have a failure mode during an accident l which would transfer control away f rom the control room.

Temperature -

Temperature tests have been successfully conducted by Electroswitch on Series 24 (Report No. 2392-2) and Series 40 (Report No. 2392-14) switches. The tests were conducted at 176*F (80*C) for 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br />. Proper operation of the switches was verified before and af ter the temperature exposure. For this application the maximum accident temperature is 238.l'F which exceeds the M6*F test temperature, however, only for 15 minutes. These switches are located inside an enclosure (unvented) which will cause the temperature l experienced by the switches to lag the accident temperature experienced by l the enclosure. Tests have been conducted by Wyle Laboratories en similar

! ~s ized cabinets (except with vents) which characterized the internal temperature of the cabinets as a function of time in a LOCA environment.

Results of these tests (Wyle Report No. 44439-2) show the internal cabinet temperature lagged the external temperature by a minimum of 50*F during the first 15 minutes. In that test the temperature and pressure were rapidly (within approximately 10 seconds) ramped to 54 psig and 280*F (minimum) respectively. Because the pressure for this application is much less than the pressure for the test (0.6 psig versus 54 psig) it is judged that in a similar test to the same maximum temperature that the internal temperature of the cabinet would lag the external temperature by substantially greater than the 50*F experienced in the test. Further, in the tests conducted by Wyle, varied components (examples: pressure transmitter and solenoid valve) were installed in the cabinet and their mass temperature was recorded in the test. The temperature of a typical component (pressure transmitter) lagged the accident temperature by approximately 80'F af ter the first 15 minutes of l

I Page 130 l

BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION

'Equirment Identification No. Electroswitch 24/40 in Alternate Shutdown Panels TER ha. 264, 266 Sheet 2 of 3

! Preparer: . Dbeu Date: h 24 Independent Review: g4/ /&w Date: P/tPMY y r Approval: . 4 )) d O4S $.d Date:  ?/ & Ifi (T

the test. In the Electroswitch test, the switches were maintained at 176*F for 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br />. Based on the above tests and engineering rational, it is judged that the test temperature of 176*F envelops the temperature which the switches would experience in the accident condition. Therefore, the switches are judged suitable for use in the temperature application.

Humidity These switches are never exposed to more than 95% RH. Maximum voltage on the

~

switches is 110 VAC. Wyle Laboratories has tested a variety of switches and terminal blocks at humidity conditions in the range of 90% to 100% including f

i some LOCA tests. In general, no problems have been experienced for thtse -

conditions where voltage never exceeds 110 volts unless the items experienced deformation resulting from temperature. Operation of the switches at the temperature conditions is justified in the above paragraph. Also, Electroswitch has subjected the switches to 95% RH for 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />, unpowered.

Operation of the switches was satisfactory in functional tests conducted prior to and following the humidity test. Therefore, the switches are judged suitable for use in the humidity environment.

Pressure The maximum pressure which the switches would be exposed to in an accident is 15.3 psia (0.6 psig). The configuration of the switches is such that they will not entrap air or otherwise cause a pressure imbalance which would result in inadvertent actuation of the switches. Therefore the switches are judged suitable for use in this pressure environment.

Radiation i The maximum radiation which the switches will experia:ce is less than 1 x 106 rads (2.3 x 105 rads gamma and 6.6 x 105 rads beta) based on a specific location radiation analysis. Electroswitch Test Report No. 3030-1 documents satisfactory operation of the switches following a radiation exposure of 1 x 107 rads. Therefore, the switches are judged suitable for use in the radiation environment.

i

Page IJ1 l

BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. Electroswitch 24/40 in Alternate Shutdown Panels TER No. 264, 266 Sheet 3 of 3 Preparer:

• Sb _

Date: V 24 N l Independent Review: N/I d 27 Date: '

M2 M/

Approval:

1 I3 NAG f Date: N37[TI O

I Aging Conditions of aging were evaluated using the Arrhenius technique. Based on the analysis which considered all nonmetallic materials within the switch, an estimated life in excess of 40 years was established. This calculation supports projected operability of the switches well beyond 1986.

Therefore, continued operation is justified.

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rage w I

BOSTON EDISON COMPANY j- JUSTIFICATION FOR CONTINUED OPERATION ,

Equipment Identification No. CS42-1724, CS42-1725, CS42-1824, CS42-1825 Sheet 1 of 1 TER No. 269 .

Date: Y!8Y Preparer:

Date: Ff24 if 8'4 l

Independent Review: kb y i

g tl T7 /M Approval: GhDw m .,

< \

Date:

v EQUIPMEN'. TYPE: Control Panel Switches MANUFACTURER: General Electric MODEL: CR2940 The functional requirement of these switches is that normally closed contacts The switches are mounted in an internal to the switches enclosed control panel. remain shut.The non-metallic portion of the switch is made of Dupont Delrin.

The only way the contacts could open would be for catastrophic f ailure of the 031rin. The parameters that could cause catastrophic failure, would be ,

temperature disintegrating).

(Delrin softening or embrittling) or radiation (DelrinThe radiation 6 rads, therefore 1.6 x 105 rad, but it has radiation is not a problem. been tested to 1 x 10The temperature due to the worst case postulat break is 238.1*F, 24.5 seconds into the accident, and considering that Delrin has been tested to a much higher temperature (311*F) temperature is not a I

problem. Therefore, continued operation is justified, t

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- ~ ~--- - __ ________ ______.___ _ _

Page 133 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION

& N Equipment Identification No. 312D Anaconda, 712B Anaconda /SI57279 TER No. N/A Sheet 1 of 1 Preparer: Date: 30!IY Independent Review: \ b hM Date: I!IO fd f

Approval: fd ---(g

'2 Date: 8!30,[ L/

j .

v EQUIPMENT TYPE: Cable

> MANUFACTURER: Anaconda / General Electric MODEL: FR-EP-CPE/Vulkene Supreme The insulation systems used on these cables have been environmentally qualified. The documentation packages for these cables are being comple.ted and when completed, environmental qualification will be proven. Therefore, I continued operation is justified.

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Page 134

} BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION

! Equipment Identification No. 412A Okonite,106 Kerite, 2126 Rockbestos, SC16 l Rockbestos TER No. N/A Sheet 1 of 1 -

Preparer:

Date: Y Y Independent Review: he Date: kW[

Approval: O Date: 8/~24/E4 LT EQUIPMENT TYPE: Cable MANUFACTURER: Okonite/Kerite/Rockbestos MODEL: Okalon/FR/Firewall 111 The insulation systems used on these cables are environmentally qualified.

The documentation packages for these cables are being completed and when i completed, environmental qualification will be proven. Therefore, continued l- cperation is justified.

9 F

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Page 13b l

BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION W W Equipment Identification No. C129A, C129B 1

l TER No. N/A Sheet 1 of 2

~

Preparer: MI - Date. 87MW 3 Independent Review: I Date: 9-f74fff Approval: M Date: 3c/f4-f)

EQUIPMENT TYPE: Instrument rack w/ terminal block and wire MANUFACTURER: Walkdown could not identify i

MODEL: Walkdown could not identify These instrument racks house a n2mber of pressure switches for high drywell pressure. Instrument wire to eight of these switches and some terminal

~ blocks could not be identified duiing a walkdown. The affected switches provide for the following safety f t.nctions in response to high drywell pressure.

I~

RPS Trip Secondary Containment Isolation Permissive Logic for ADS Initiation .

Permissive Logic for CS/LPCI Pump Operation Permissive Logic for Drywell/ Torus Spray These racks are located in the reactor building at elevation 74' (zone 1.14G) and are exposed to a harsh high radiation environment foi owing any PBOC or a PBIC. Continued operation can be justified from either a technical or

! systematic basis.

Technical Analysis PBOC(s) do not re ult in a high drywell pressure condition (FSAR Appendix G). Therefore none of the affected pressure switches would be required to actively function while exposed to a harsh steam and radiation environment following a PBOC.

These instrument racks are exposed to approximately 106 rads over a 30 day mission length following a PBIC. Based on a Wyle Labs review of their extensive material library, and elimination of materials not commonly utilized in applications such as MCCs and instrument racks, it has been concluded that it is unlikely that any wire insulation unable to withstand this radiation exposure is installed in these racks.

f

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Page 136 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. C129A, C129B TER No. N/A Sheet 2 of 2 Preparer: M2 [h- Date: b8/8'/

Independent Review: /xA. Date: iftif Approval: Al Date: 30 F/-

G_

As previously, discussed, the manufacturer of terminal blocks in these racPs could not be positively determined during a walkdown. However, Sandia National Laboratories and other laboratories have compiled extensive test (

data on terminal blocks (both protected and unprotected) of various manufacturers. Sandia tested over 400 terminals in their own f acilities.

The partial test data indicates that the continued operability of the terminal strips while exposed to the calculated harsh environment is adequately assured. Based on these considerations, continued operation is

. justified.

Systematic Analysis Of the eight potentially affected instruments all but one were associated with the 'A' trains of RPS, ADS, and ECCS. Therefore, redundant assurance of required safety functions would likely be provided by the "B" train if any cf l

these switches failed to perform. The exception was caused by PSS12A on C129A and PS5128 on C1298. These switches provided for a RPS trip and secondary containment isolation during a PBIC. These switches are required to actively function during the first few minutes of a PBIC prior to exposure to a harsh radiation environment. In the unlikely event that the switches subsequently failed, no required safety function would be compromised.

Page 137 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION k

Equipment Identification No. C150, C151 TER No. N/A Sheet 1 of 6 Preparer: [MM ,

_ Date: N2fk Independent Review: b bW Date: 2'//M Approval: h fSt U

~

Date: T/3oi

.\

EQUIPMENT 1YPE: Control Panel Switch / Light MANUFACTURER: Electroswitch/ General Electric MODEL: 40/ET-16 Remote shutdown panels C150 and C151 are located in the "A" and "B" RBCCW rooms (zones 1.21 and 1.22) and are exposed to a harsh superheated steam cnvironment (peaking at approximately 225*F and 15.2 psia) following a PBOC-3 (HPCI steart line break in the HPCI pump room). The panels contain series 40 i-Electroswitch Control Switches and GE Model ET-16 indicating lights. Failure Cf these components could cause loss of control of several RBCCW and salt service water pumps. The 225'F temperature is based on the preliminary results of a reanalysis o;' the PBOC-3 environment for these rooms. Continued cperation can be justified on the following basis.

Series 40 Electroswitch o Temperature c

Temperature tests have been successfully conducted by Electro; witch on Series 24 (Report No. 2392-2) and Series 40 (Report No. 2392-14) switches. The l

Proper operation of the tests were conducted at 176*F (80*C) for 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br />.

switcnes was verified before and after the temperature exposure. For this application the maximum accident temperature is approximately 225'F which exceeds the 176*F test temperature, for approximately 15 minutes. These switches are located inside an essentially leak tight NEMA-12 enclosure (unvented) which will cause the temperature experienced by the switches to lag the accident temperature experienced by the enclosure. Tests have been conducted by Wyle Laboratories on similar sized cabinets (except with vents) which characterized the internal temperature of the cabinets as a fur.ction of time in a LOCA environment.

Results of these tests (Wyle Report No. 44439-2) show that the internal l

l temperature of the vented cabinets lagged the external temperature by a minimum of 50*F during the first 15 minutes of exposure to a saturated steam

} environment. In that T:st the temperature and pressure were rapidly (within r

I approximately 10 seconds) ramped to 54 psig and 280'F (minimum) respectively. Because the pressure for this application is much less than I

Page 138 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. C150, C151 TER No. N/A Sheet 2 of 6 Preparer: [A/d br -f Date: I/47 Independent Review: N Date: fbi 4 Approval: (S4 Date: T 8/9 r _-- ,

v the pressure for the test (0.5 psig versus 54 psig) and in light of the Gssentially leak tight nature of the enclosure, the hot environment is sxpected to be essentially precluded f rom entering the panel. It is therefore our engineering judgement that in a similar test of the unvented cabinets to the same maximum temperature but significantly lower pressure that the internal temperature of the cabinet would lag the exterr.al temperature by substantially greater than the 50*F experiencec in the test.

Further, in the tests conducted by Wyle, varied compunents (examples:

pressure transmitter and solenoid valve) were installed in the cabinet and their mass temperature was recorded in the test. The temperature of a typical component (pressure transmitter) mounted in the vented cabinet lagged the accident temperature by approximately 80*F af ter the first 15 minutes of the test. It should be noted that saturated steam blanketing of high thermal -

inertia components such as the cabinet, as demonstrated in Limitorque Report 80027, would result in the accident environment being the equivalent of an cxposure to 215'F to the exterior of the cabinet. The interior of the cabinet would be expecte1 to lag 50 - 80*F minimum below this. In the Electroswitch test, the switches were maintained at 176*F for 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br />.

Based on the above tests and engineering rationale, it is judged that the test temperature of 176*F is comparable to the temperature which the switches would experience in the accident condition. Therefore, the switches are judged suitable for use in the temperature application.

o Humidity The compartment within which these switches are mounted experiences 100% RH for a short time period. The humidity then decays rather quickly to a long term equilibrium of approximately 60%. Due to the essentially leak tight nature of the NEMA-12 enclosures, the switches should not experience the initial humidity spike. Maximum voltage on the switches is 120 VAC. Wyle Laboratories has tested a variety of switches and terminal blocks at humidity conditions in the range of 905 to 100% including some LOCA tests. In general, no problems have been experienced f or these conditions where voltage never exceeds 120 volts unless the items experienced deformation resulting from temperature. Operation of the switches at the temperature conditions is I justified in the above paragraph. Also, Electroswitch has subjected the

Page 139 BOSTON EDISON COMPANY l JUSTIFICATION FOR CONTINUED OPERATION k

Equipment identification No. C150, C151 TER No. N/A Sheet 3 of 6 Preparer: [t/ /~ __ e Date: ktfMr r

Independent Review: (M W Date: 9/24 ff 4 Approval: Date: 8 36 fV O

switches to 95% RH for 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />, unpowered. Operation of the switches was l

satisfactory in functional tests conducted prior to and following the l humidity test. Therefore, the switches are judged suitable for use in the humidity environment.

o Pressure The maximum pressure which the switches would be exposed to in an accident is 15.2 psia (0.5 psig). The configuration of the switches is such that they

l. will not entrap air or otherwise cause a pressure imbalance which would .

I result in inadvertent actuation of the switches. Therefore the switches are l

judged suitable for use in this pressure environment. -

, o Radiation The maximum radiation which the switches will experience is approximately 1.8 x 103 rads. Electroswitch Test Report No. 3030-1 documents satisf actory operation of the switches following a radiation exposure of 1 x 107 rads.

Therefore, the switches are judged suitable for use in the radiation cnvironment.

o Aging Conditions of aging were evaluated using the Arrhenius technique. Based on the analysis which considered all nonmetallic materials within the switch, an estimated life in excess of 40 years was established.

Therefore, continued oper:ation is justified.

L _ __ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ l

Page 140 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION

)pmentIdentificationNo.C150,C151k INo. N/A Sheet 4 of 6 I

Fr;r: h :n<2 Date: MY79MV hp;nd:ntReview: N bh Date: h' N val: Date: M34/24 l' ()

lodel ET--16 Lichts f

Temperature rature tests have been successfully conducted by Wyle on ET-16 lights, t:sts were conducted at 160*F. Proper operation of the lights was fi:d before and after the temperature exposure, For this application the

, mum accident temperature is approximately 225'F which exceeds the 160*F k temperature for approximately 25 minutes. These lights are located

@ an essentially leak tight NENA-12 enclosure (unvented) which will pn th2 temperature experienced by the lights to lag the accident rature experienced by the enclosure. Tests have been conducted by Wyle ,

attrics on similar sized cabinets (except with vents) which ctGrized the internal temperature of the cabinets as a function of time LOCA environment.

{tsofthesetests(WyleReportNo. 44439-2) show that the internal prature cf the vented cabinets lagged the external temperature by a num cf 50*F during the first 15 minutes of exposure to a saturated steam ponment. In that test the temperature and pressure were rapidly (within

$ximately 10 seconds) rampe.1 to 54 psig and 280'F (minimum)

Dctiv21y. Because the pressure for this application is much less than tressure for the test (0.5 psig versus 54 psig) and in light of the Itiallyleaktightnatureoftheenclosure,thehotenvironmentis

'ted 3 to be essentially precluded from entering the panel. It is Dfers cur engineering judgement that in a similar test of the unvented nets to the same maximum temperature but significantly lower pressure j lithe internal temperature of the cabinet would lag the external Drature by substantially greater than the 50'F experienced in the test.

her, in the tests conducted by Wyle, varied components (examples:

)tra transmitter and solenoid valve) were installed in the cabinet and

? mass temperature'was recorded in the test. The temperature of a

)al component (pressure transmitter) mounted in the vented cabinet lagged DccWGnt temperature by approximately 80*F af ter the first 15 minutes of Test. It should be noted that saturated steam blanketing of high thermal fia components such as the cabinet, as demonstrated in Limitorque Report b.=,, .

Page 141

.?

BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION

~

4 Equipment Identification No. C150, C151 '

TER No. N/A Sheet 5 of 6 Preparer: /1/ l h w D' ate : f/29M j Independent Review: N/20.ve Date: NZhbf Approval: Date: 3d[

(\

~

)

B0027, would result in the accident environment being the equivalent of a 215* saturated steam exposure to the exterior of the cabinets. The interior of the cabinet would be expected to lag 50*F to 80*F below this. In the Wyle l test, the lights were maintained at 160*F. Based on the above tests and engineering rationale, it is judged that the test temperature of 160*F is comparable to the temperature which the lights would experience in the

> accident condition. Therefore, the lights are judged suitable for use in the temperature application.

o Humidity i

The compartment within which this cabinet is mounted experiences 100% RH for a short time period. The humidity then decays rather quickly to an equilibrium of approximately 60%. Due to the leak tight nature of the NEMA-12 enclosures, the lights should not experience the initial humidity spike. Maximum voltage on the lights is 120 VAC. Wyle t.aboratories has tested a variety of lights at humidity conditions in the range of 90% to 100%. In general, no problems have been experienced for these conditions l where voltage never exceeds 120 volts unless the items experienced deformation resulting from temperature. Operation of the lights at the temperature conditions is justified in the above paragraph. Therefore, the lights are judged suitable for use in the humidity environment.

i o Pressure The maximum pressure which the lights would be exposed to in an accident is .

15.2 psia (0.5 psig). The configuration of the lights is such that they will l

not entrap air or otherwise cause a pressure imbalance which would result in a functional disparity in the lights. Therefore the lights are judged l ,

suitable for use in this pressure environment.

I

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l Page 142 BOSTON EDISON COMPANY ,

JUSTIFICATION FOR CONTINUED OPERATION f &

l Equipment Identification No. C150, C151 TER No. N/A Sheet 6 of 6 i

1 Preparer: /1/l[4ew r

Date: P/M/y Independent Review: b h'# Date: k7 f1'7 f N Approval: Date: $ 30 Rd '

I

_\m o Radiation t

The maximum radiation which the lights will experience is approximately 1.8 x 103 rads. Proprietary Wyle Test Report No. 45625-1A documents satisfactory (peration of the lights following a radiation exposure of 2.1 x 106 rads.

Therefore, the lights are judged suitable for use in the radiation environment.

Based on the above information, continued plant operation is justified.

t .

Page 143 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION

1. 4-Equipment identification No. C2205A, C"079, C2260, C2201 TER Mo. N/A Sheet 1 of 2 .

Preparer: h Dat.e: Mt/h Ind: pendent Review: b Date: 28!f4 Approval: Date: E [3c[ N f\

v EQUIPMENT TYPE: Instrument rack w/teminal block and wire MAWUFACTURER: Walkdown could not identify

)

l MODEL: Walkdown could not identify l

Th:se instrument racks contain some instrument wire and some terminal blocks which could not be identified during walkdown. These components are of concern since many if not all of the instruments in these racks are safety relcted. The racks are located in the reactor building and are exposed to a harsh steam environment following several different PBOCs and to radiation following any PBOC or a PBIC. Although the manuf acturrr of these components can not be positively identified, continued operation can be justified on the .

following basis.

The design specification for these instrument racks required the use of polyvinylchloride (PVC) jacketed polyethelene (PE) insulated cable or equivalent. It is our belief that based on this specification and a ccnfirmation by walkdown that none of the identified cable failed to meet this specification, that the unidentifiable cable is very likely PE-PVC.

Wyle Labs has indicated that PE-PVC cable has been subjected to sequential tssting which documents qualification of the PE-PVC insulation system to 1.03 x 108 rads ganna and a LOCA steam environment with temperature up to 325'F. The service profiles experienced by the instrument racks over a 30 day mission length are enveloped by this testing. In addition, the generic materials which make up the insulation system have expected lives of greater than 104 years in a 104*F ambient environment.

As previously discussed, the manuf acturer of teminal blocks installed in these junction boxes could not be positively determined during a walkdown.

However, Sandia National Laboratories and other laboratories have eGpiled cxt:nsive test data on teminal blocks (both protected and unprotected) of various manufacturers. Sandia tested over 400 terminals in their own fccilities. The partial test data indicates that the continued operability cf the terminal strips while exposed to the calculated harsh environment is cdequately assured.

Page 144 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPE 7ATION W W Equipment identification No. C2205A, C22078, C2260, C2201 TER No. N/A Sheet 2 of 2 Preparer: k Date: NST[6 Independent Review: # Date: M!Aiff Approval: s (s u--

AI<A

,g Date: f /30[C Y Based on these considerations, we believe that the unidentified wire and terminal blocks in these instrument racks will remain operable and continued cperation is justified.

I

-_ 1

rc oe A*a BOSTON EDISON COMPANY i JUSTIFICATION FOR CONTINUED OFERATION Equipment identification No. C2207A TER No. N/A Sheet 1 of 1 Preparer:

" Date: FI Independent Review: b:rr Date: [ f Approval: 6 O _f- (- \ -

Date: 9/24 / 24

~

EQUIPMENT TYPE: Instrument rack w/teminal block MANUFACTURER: Walkdown could not identify MODEL: Walkdown could not identify The manufacturer of terminal blocks in this local control panel could not be positively detennined during a walkdown. However, Sandia National Laboratories and other laboratories have compiled extensive test data on terminal blocks (both protected and unprotected) of various manufacturers.

Sandia tested over 400 teminals in their own f acilities. The partial test data indicates that the centinued operability of the terminal strips while cxposed to the calculated harsh environment is adequately assured. Based on these considerations, continued operation is justified. .

I

. - - - ,--...e., ,--y-.,.-,__,,,+,--------,--,,,,--....-...e,-y.w-- - - . - . --r-w---.,

Page 146 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. C2257A TER No. N/A Sheet 1 of 1 .

Preparer: Date: #~/EP /f-v Independent Review:

' -~

Date: 8Y Approval: Date: Jo

($

- a a .

i EQUIPMENT TYPE: Instrument rack w/ wire and terminal blor.ks

( MANUFACTURER: Walkdown could not identify l MODEL: Walkdown could not identify I

The manufacturer of the terminal block associated with DPIS2352 on C2257A has not been identified. However, Sandia National Laboratories and other laboratories have compiled extensive test data on terminal blocks (both

. protected and unprotected) of various manufacturers. Sandia tested over 400 terminals in their own facilities. The partial test data indicates that the continued operability of the terminal strips while exposed to the calculated .

harsh environment is adequately assured. Based on these considerations, continued operation is justified.

The nnnufacturer of the instrument rack wire from the terminal blocks AA and DD to DPIS2353 and DPIS2352, respectively, is unknown. The wire is in a conduit from the switches to the enclosure for the terminal block. The differential pressure switches are only required to provide a signal (which

" seals in") to the Primary Containment Isolation Control System during a HPCI Pipe Break. The differential pressure switches and therefore the terminal block and wire will perform their function prior to the environment becoming harsh. Therefore, continued plant operation is justified.

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Page 147 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. C22578 TER No. N/A Sheet 1 of 1

~

Preparer: Date: 27!EY Independent Review: /4 / h M _ Date: kl#/II Approval: Date: I[21[/h

()

EQUIPMENT TYPE: Instrument rack w/ terminal blocks MANUFAC1URER: Walkdown could not identify MODEL: Walkdown could not identify Th2 manufacturer of the terminal block assoc'iated with DPIS1360-1B on C2257B hss not been identified. However, Sandia National Laboratories and other Icboratories have compiled extensive test data on terminal blocks (both

. protected and unprotected) of various manufacturers. Sandia tested over 400 terminals in their own facilities. The partial test data indicates that the continued operability of the terminal strips while exposed to the calculated harsh environment is adequately assured. Based on these considerations, .

continued operation is justified.

I 1

Page 148 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION f Equipment identification No. C2303 T2303 TER No. N/A Sheet 1 of 2 l

I Date: li Prepsrer:

Independent Review: I/ de";' Date: [N M Approval: -

~

lb Date: T[20/ Rd O _

, EQUIPMENT TYPE: HPCI Control Panels MANUFACTURER: Various MODEL: Various These panels contribute to HPCIS turbine start-up and speeil control and are, therefore, required solely to assure satisfactory HPCIS operation.

The HPCIS is relied upon to operate during and following

~

Loss of Feedwater Flow, Total loss of Offsite Power, -

Shutdown from Outside Control Room (Special Event),

Pipe Break Inside Primary Containment, Control Rod Drop Accident, and Pipe Break Outside Primary Containment to assure continued core cooling, and thus mitigate consequences which could result in potential of fsite exposures comparable to the 10CFR100 guidelines.

None of the first three events listed above is expected to result in environmental conditions any more severe than those experienced during normal operation. The fourth event is addressed in the HPCIS Safety Evaluation, which states that, "The HPCIS is designed to provide adequate core cooling for small breaks... core never uncovers and is continuously cooled throughout the transient so that no core damage of any kind occurs for breaks that lie within the range of the HPCI." Thus, the size of LOCA presumed to generate postulated core damage is beyond the capacity of HPCIS to provide core cooling.

The Control Rod Drop Accident nas been evaluated and no HPCIS equipment will be subjected to pressure, temperature, radiation or humidity conditions any more severe than those experienced during normal operation.

Page 149 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. C2303, T2303 TER No. N/A Sheet 2 of 2 Preparer: b-- Date: Y Independent Review: der Date: [/rd Approval: Date: 9. ,[L4,ft d.

g Those pipe breaks outside containment which could be expected to result in harsh conditions of pressure, temperature and humidity in the vicinity of these panels are the PBOC-3 and the PBOC-5. Each of these events, however, incapacitates the HPCIS. System operability is, therefore, not required for t'her PBOC.

On the other hand, system operability is required for the main steam line breaks, PBOC-7 and PBOC-8. However, FSAR analysis of the PNPS design basis Main Steam Line Break Accident indicates that, with a maximum 10.5 second MSIV closure and continued core coverage (from normal or standby systems, including HPCIS), there would be no fuel damage. Without core damage, cxposures will not exceed 10 4 rads. -

MSIY closure time is verified once per quarter under Technical Specification surveillance requirements. The closure time must be greater than 3 seconds and less than 5 seconds for the valve to be considered operable. For valve closure times shorter than 10.5 seconds, the postulated accident is considered less severe than that analyzed.

Core cooling systems are also verified operable periodically under plant surveillance requirements. Thus, if HPCIS was incapacitated as a consequence of the P80C, then ADS, LPCI and Core Spray would be available to redundantly assure safe shutdown of the plant. If all core cooling systems operate as designed and tested, harsh radiation levels will not occur.

Therefore, continued operation is justified.

\ _ - - _ _ _ - - _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ ___ _

Page 150 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. C61 A, C61B Indicating Lights TER No. N/A Sheet 1 of 1 Preparer:

Date: E!A7!N

, Independent Review: NbM V

Date: I 2. pM

! Approval: GCWb . . . . . Date: 417711i4 i

(T l EQUIPMENT TYPE: Control Panel Indicating Lights

' MANUFACTURER: General Electric MODEL: CR29400C These lights are for indication at the local control panels. They are not necessary for operation of the fans, however, f ailure could af fect the control circuit and therefore degrade operation of their respective area 1- cooling fans. There are three possible f ailure modes; open, short internal to the light, or short to the panel.

If a light f ails open there will be no ef fect on the circuit and the f an will continue to operate normally, if a light develops an internal short circuit there will be no effect on the circuit and the fan will continue to operate normally.

If a light develops a short to the panel the control circuit may be disabled cnd the fan may be deenergized. However, the only possible failure mechanism would be excessive moisture inside the panel such that the water created a path for current f rom the light connections to the panel. This failure mechanism is unlikely because the panels are gasketed, which will reduce the moisture inside, and because of the distance between the electrical connections and the panel. The distance is enough so that creation of an electrical arc, in this 120VAC control circuit, between the connections and the panel is unlikely. Also, if one of the fans becomes disabled it is highly unlikely that this would cause a significant effect on the equipment in the ef fected room, because the RHR rooms (areas 1.1 and 1.2) have redundant fans.

Based on the above information, continued operation is justified.

- _ _ _ _ _ _ _ . _ . _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ J

Page 151 1

BOSTON EDISON COMPANY l JUSTIFICATION FOR  !

CONTINUED OPERATION Equipment Identification No. C61A, C61B Relays TER No. N/A Sheet 1 of 1 .

Preparer: Date: E!A7[?'l Independent Review: Date: f!Zl Approval:

y (M's g

Date: f[th.f'I, EQUIPMENT TYPE: Control Panel Relays MANUFACTURER: Johnson /Agastat MODEL: KZ-4000-8/2412AN These relays are for indication only. They are not necessary for operation of the f ans, however, failure could af fect the control circuit and therefore degrade operation of their respective area cooling fans. There are three possible failure modes; open, short internal to the relay, or short to the panel.

If a relay fails open there will be no effect on the circuit and the fan will -

continue to operate normally.

If a relay develops a short to the panel or an internal short circuit, the cont *ol circuit may be disableu and the fan may be deenergized. However, the only possible failure mechanism would be excessive moisture inside the panel such that the water created a path for current from the relay connections to the panel or to other relay connections. This failure mechanism is unlikely because the panels are gasketed, which will reduce the moisture inside, and because of the distance between the electrical connections and the panel.

The distance is enough so that creation of an electrical arc between the connections and the panel, in this 120VAC control circuit, is unlikely.

Also, if one of the fans becomes disabled it is highly unlikely that this wculd cause a significant effect on the equipment in the effected room, ,

because the RHR rooms (areas 1.1 and 1.2) have redundant fans.

Based on the above information, continued operation is justified. i l

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,_ _ . _ . . _ _ _ ._.. _ _ ~ _-

- - - - - - - - - - - - - ~ - -

Page 152 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. CS42-1821, CS42-1822 TER No. N/A Sheet 1 of 1 EbN7Y Preparer: -

Date:

Independent Review: W ' l' f

Date: kNh Approval: %1 Date: 2/24/84 Q

EQUIPMENT TYPE: Control Panel Switches MANUFACTURER: General Electric MODEL: CR2940 The functional requirement of these switches (that control VAC201) is that nomally closed contacts internal to-the switches remain shut. The switches are mounted in an enclosed control panel. The non-metallic portion of the switch is made of Dupont Delrin.

~

The only way the contacts could open would be for catastrophic failure of the Delrin. The parameters that could cause catastrophic failure, would be temperature (Delrin sof tening or embrittling) or radiation (Delrin ,

disintegrating). The radiation to which the switch might be subjected is 1.6 x 105 rads, but it has been tested to 1 x 106 rads, therefore radiation is not a problem. The temperature due to the worst case postulated break is 238.1*F, 24.5 seconds into the accident, and considering that Delrin has been tested to a much higher temperature (311*F) temperature is not a problem.

Therefore, continued operation is justified.

- - , - - , - - - - - - - e -,.-rr-- , , - ,-m -,- , --o 4n,wew-ww-r-

Page 153 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. CX2, CX4, 520, CX8 i TER No. N/A Sheet 1 of 1 Preparer:

~ Date: 2YhY Independent Review: Date: ,

2/N/

Approval: CTO ,. _ _ Date: %f 24 /84

/\

U EQUIPMENT TYPE: Cable MANUFACTURER: Various MODEL: PE This equipment consists of polyethylene insulated cable (installed outside of the drywell) provided by several manufacturers. While no qualification documentation or testing history has been found for these specific cables, similarly constructed cable has been successfully subjected to sequential testing (proprietary TR #17513-1), which documents qualification of the insulation system to 1.63 x 10 8 rads gamma and a LOCA condition including temperatures up to 325'F. These conditions are more severe than the -

conditions at PNPS.

The generic materials which make up the insulation system have expected lives of greater than 1.5E4 years (PE) in an ambient temperature of 105'F.

Based on the above, it is judged that the PE cable installed is justified for continued use pending further testing or replacement.

Page 154 i

BOSTON EDISON COMPANY

. JUST1FICATION FOR CONTINUED OPERATION Equipment Identification No. J32 TER No. N/A Sheet 1 of 1 Preparer: Dati: E 77!N Independent Review: [M W Date: [/27/(V l

Approval:

• ~

[L %O Date: 8 [li[14 EQUIPMENT TYPE: Junction box w/ terminal block MANUFAtlDRER: Buchanan MODEL: 243 L

This junction box 's in the electrical circuit of the following tenperature switches:

Switch Location Setpoint TS2370C HPCI Valve Room exh. duct 160

• F-170

• F TS2371C Torus Area exh. duct 190'F-200*F -

TS2372C HPCI Valve Room exh. duct 160* F-170* F TS2373C Torus Area exh. duct 190*F-200*F Exceeding the setpoint is an indication of a HPCI steam line break. The closing of the temperature switch contacts causes an auto isolation signal (which " seals in") to be sent to M02301-4, 5, 35, and 36, which shut to isolate the HPCI steam supply line and the HPCI pump suction line from the Torus. The terminal block inside the junction box need only operate up to the point that the isolation signal " seals in". Because the terminal block is inside the junction box there will be a time lag between the temperature switches being subjected to the pipe break and the terminal blocks being subjected to the pipe break. The terminal blocks will not be subjected to an elevated temperature prior to performing their safety function. Therefore, continued plant operation is justified.

I l

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Page 155 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. J216 TER No. N/A Sheet 1 of 1 Preparer:

D' ate : I*

Independent Review: Date: E 84 Approval: Date: 30

()

EQL'IPMENT TYPE: Junction Box w/ Terminal Block MANUFACTURER: Walkdown could not identify MODEL: Walkdown could not identify This junction box is in the electrical c.rcuit for solenoid valve SV220-44, that in turn tantrols A0220-44 (Reactor Coolant Sample Line Inboard Isolation valve). SV220-44 is acrmally shut and is required to be shut to ensure primary containment isolation post-accident. If A0220-44 is open at the beginning of an accident, the isolation signal causes SV220-44 to deenergize which will cause A0220-44 to shut. In addition to this inboard isolation valve, this line has an in-series outboard isolation valve. There are no -

design basis events which expose both isolation valves or their associated electrical circuitry to a harsh environment during their mission times.

Thus, isolation of this line is assured for all design basis events.

Therefore, continued operation is justified.

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l Page 156 j l

i BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION l Equipment identification No. J217 TER No. N/A Sheet 1 of 1 Preparer: Date: E!8Y!?k Independent Review: rM Date: kl. (( f Approval: O A Date: 15124 /24

<N w

EQUIPMENT TYPE: Junction box w/tenninal block MANUFACTURER: Walkdown could not identify MODEL: Walkdown could not identify This junction box is in the electrical circuit for solenoid valve SV220-45, that in turn controls A0220-45 (Reactor Coolant Sample Line Outboard Isolation Valve). SY220-45 is normally shut and is required to be shut to ensure primary containment isolation post-accident. If A0220-45 is open at the beginning of an accident, the isolation signal causes SV220-45 to deenergize which will cause A0220-45 to shut. All credible failures of the terminal block within J217 will also deenergize SV220-45 and cause A0220-45 to shut. Therefore, failure of J217 will have no adverse effects, and continued plant operation is justified.

i

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Pag: 157 BOSTON ELISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. J444, J463 TER No. N/A Sheet 1 of 1 Preparer: b. - ~ Date: 2 FN Independent Review: h b bM U 0 Date: fr'!2(!8Y Approval: Date: 3/27/s4 i \

v EQUIPMENT TYPE: Junction box w/ terminal block MANUFACTURER: Walkdown could not identify MODEL: Walkdown could not identify These junction boxes are in the electrical circuits for solenoid valves that are required to deenergize to shut Reactor Building isolation dampers. The dampers shut immediately af ter low reactor water level, high drywell pressure or high radiation in refueling floor exhaust duct is sensed. If the terminal block inside the junction box fails af ter the dampers are shut, there will be no detrimental effects because the dampers are already shut. In the unlikely event that the terminal block fails prior to the solenoids deenergizing and the dampers shutting, the failure will simply speed up the process of ,

isolating the Reactor Building. Af ter the dampers have shut, there is no plausible failure of the terminal block that could reopen the valve.

Therefore, continued operation is justified.

1

, . . , .-- - ..y ,- ._ . ---,w -,-- - , .- .-- , - - - - -. -

Page 158 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. J451 TER No. N/A Sheet 1 of 1 Preparer:

Date: Th EY Independent Review: Ih . ?W Date: 8/8F/7 Approval: C3 PAC'% , - Date: CP14/24 t \

w EQUIPMENT TYPE: Junction box w/ terminal block MANUFACTURER: Suchanan MODEL: 243 This junction box is in the electrical circuit for the following valves:

SYS0338 Nonnal Purge Suppy to Drywell SV5033C Normal Hitrogen Makeup to Drywell

~

SV5035B Purge Air to Drywell SY5036B Purge Air to Torus SV5042B Purge Exhaust from Torus SY5044B Purge Exhaust from Drywell .

SV5033C is nonnally energized and A05033C is normally open. All other valves are normally deenergized and their respective air operated valves are normally shut. All of the air operators fail shut. All of the solenoid valves receive Containment Isolation signals upon a LOCA. The isolation signal causes the solenoid valves to deenergize (if not already deenergized) and the air operated v'alves to shut. All credible failures of the terminal block within J451 will also deenergize the solenoid valves and cause the air operated valve to shut. Therefore, failure of J451 will have no adverse ef fects, and continued plant operation is justified.

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Page 159 i

BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION f

Equipment identification No. J462, J466 M

TER No. N/A Sheet 1 of f Prenarer: k h Date: 9!Id Independent Review: d/d Date: _ [2fhf Approval: X b'2.3 Date: if3c/f4 G

~

EQUIPMFNT TYPE: Junction Box w/ Terminal Block MANUFAClURER: Walkdown could not identify MODEL: Walkdown could not identify J462 and J466 contain terminal blocks for various solenoid valves and damper position switches for the Standby Gas Treatment System. They have been identified as Buchanan-243 nylon terminal blocks and are located on Elevation 23' in the Reactor Building. These blocks could be exposed to a harsh steam and radiation environment following a P80C and a harsh radiation environment following a PBIC.

PNPS FSAR Appendix G does not credit Standby Gas Treatment System operation -

for mitigating the ef fects of a P90C. No failure mode of these terminal blocks could prevent any safety action necessary for mitigating the ef fects of a PBOC from occurring. Therefore, these blocks are not required to be qualified for the harsh steam and radiation environment resulting from a PBOC.

For a PBIC, radiation levels at the location of these terminal blocks are approximately 3.5 x 106 rads af ter 30 days. These blocks have a radiation threshold of 8.5 x 105 rads and a 25% darrage threshold of 4.7 x 106 rads. Also, the worst failure mode associated with the failure of these terminal blocks is loss of power to the circuit. The solenoids are energized when the SSTS dampers are closed. The dampers' fail-safe position is open and occurs when the solenoids are deenergized. Thus, this failure mode. is not of concern for the solenoid valves. Loss of power to the position indication switches would result in loss of all position indication in the control room (no illumination of red or green lights). However, SGTS flow indication in the Control Room would be provided by flow transmitters in the common A and B train outlet. These flow transmitters are located in a mild environment and would be expected to function post-accident.

In addition, none of the failure modes associated with these blocks would prevent initiation of the SGTS nor cause the system to trip af ter it had initiated.

Therefore, continued operation is justified.

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e BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. J538, J539 TER No. N/A Sheet 1 of 1 Preparer:

Date: E!N!8I Independent Review: k V Date: '

Ifh Approval: GCLO->w .

Date: E124/E4 M

EQUIPMENT TYPE: Junction box w/ terminal block MANUFACTURER: Buchanan MODEL: 525/222 These junction boxes are in the electrical circuit for relative humidity sensors (HS-1 A, 2A, 3A, 4A,18, 28, 3B, 48). The relative humidity sensors are not required for StandLy Gas Treatment System (SGTS) Operation. The normal function of the sensors is to detect high humidity in the SGTS inlet and energize-relays, which in turn cause the heater relays and heaters to be energized. The humidity controls have been bypassed, so that full heater operation is initiated upon operation of the SGTS exhaust fan. Therefore,

~

these junction boxes are not required and continued plant operation is justified. .

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Page 161 )

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I NOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION p fquipment Identification No. J561 J874,Sheet J866, 1J863 of i TER No. N/A Date: 3A7!?Y, e, Preparer: -

Date:  ? 4 ?!iir4 Independent Review: \ L UbM U Date: C/T7/R4 Approval: NM - - m i . <

N w

EQUIPMENT TYPE: Junction box w/ terminal b1cck MANUFACTURER: Walkdown could not identify MODEL: Walkdown could not identify The manuf acturer of the terminal block in However, these junction Sandiaboxes National could not be positively determined during a walkdown. Laboratories and other laborato terminal blocks (both protected and unprotected) of various manufacturers. The partial test Sandia tested over 400 terminals in their own facilities.

data indicates that the continued operability of the terminal strips Based whileon exposed to the calculated harsh environment is' adequately assured.

these considerations, continued operation is justified. .

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Page 162 1

BOSTON EDISON COMPANY I JUSTIFICATION FOR CONTINUED OPERATION l s:

Equipment identification No. J599, J600, J601, J602, J606 TER No. N/A Sheet 1 of 1

' ' Y

~

Date: ,

Preparer:

Independent Review: "W Date: V -

M_b\- - ,_ Date: El% / E4-Approval:

1 T v

EQUIPMENT TYPE: Junction box w/ terminal block MANUFAC1URER: Walkdown could not identify MODEL: Walkdown could not identify c

This junction box is in the electrical circuit of the following temperature switches:

Location Setooint Switch RCIC Valve Station 190* - 200*

TS1360-16C RCIC Valve Station 190* - 200*

TS1360-14C 140* - 150*

TS1360-17C Torus Area Exhaust Duct Torus Area Exhaust Duct 140' - 150*

151360-15C 190* - 200*

TS1360-16D RCIC Valve Station RCIC Valve Station 190* - 200*

151360-140 140' - 150*

TS1360-17D Torus Area Exhuast Duct Torus Area Exhaust Duct 140* - 150' 151360-15D Exceeding the setpoint is an indication of a RCIC steam line break. The closing of the temperature switch contacts causes an auto isolation signal (which

• seals in") to be sent to M01301-16 and 17, which shut to isolate the RCIC steam supply line. The terminal block inside the junction box need only operate up to the point that the isolation signal

• seals in'. Because the terminal block is inside the junction box there will be a time lag between the temperature switches being subjected to the pipe break and the terminal blocks being subjected to the pipe break. The terminal blocks will never be subjected to an elevated temperature prior to performing their safety

' function. Therefore, continued plant operation is justified.

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- . - -- - . ~ . . - _ . - - . - , , _ -, ,_ ,.,_

rage Au.) I l

BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION y

Equipment Identification No. J603, J604 Sheet 1 of 1 TER No. N/A Date: 9!E7!8#f Preparer:

Date: M2fM7 Independent Review: _M [b 7-r -

g. Date: t /2,1/N Approval: f'lL[$N O Junction box w/ terminal block EQUIPMENT TYPE:Walkdown could not identify MANUFACTURER:

MODEL:

Walkdown could not identify This junction box is in the electrical circuit of the following temperature -

switt.hes:

Setpoint Location.

Switch 160*F-170*F TS2370C HPCI Valve Room exh. duct 160* F -170* F TS2370D HPCI Valve Room exh. duct 160* F-170* F TS2372C HPCI Valve Room exh. duct 160* F-170* F ,

TS2373C HPCI Valve Room exh. duct The Exceeding the setpoint is an indication of a HPCI steam line break.

closing of the temperature switch contacts causes shut to isolate the HPCI steam supply line and the HPCI pu Because the terminal f rom the Torus.

up to the point that the isolation signal " seals in".

block is inside the junction box there will be a time lag between the temperature switches being subjected to the pipe break and the termina blocks being subjected to the pipe break.

subjected to an elevated temperature prior to performing their safety function. Therefore, continued plant operation is justified.

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Page 164 l

BOSTON EDISON COMPANY I JUSTIFICATION FOR CONTINUED OPERATION a Equipment Identification No. J720 Sheet 1 of 1 TER No. N/A dY f 9'[

Preparer: N b; ' Date:

kE4 @4 Independent Review: _ h/, hM Date:

Date: S /'27 / g4 Approval: j m u

( \

w Junction box w/ terminal block EQUIPMENT TYPE:Walkdown could not identify MANUFAC1URER:

MODEL:

Walkdown could not identify This junction box is in the electrical circuit for M0/N-113 and SVL-70.

M0/N-113 (SGTS , exhaust fan damper unit 'B') has be SVL-70 is the solenoid this junction box will not cause the damper to move. 'B' unit. Failure valve that operates the outlet isolation damper for SGTS of.the terminal block within J720 will cause SVL-70 to deenergize .

AON-112 open. to f ail open.Therefore failure of this junction box will have no adverse effects on plant safety and continued plant operation is justified.

reye aus BOSTON EDISON COMPANY JUSTIFICATION FOR ,

CONTINUED OPERATION Equipment identification No. J859 J TER No. N/A Sheet 1 of 1 Preparer:

Date: E / 8Y Independent Review: d/I ham Date: 8/b/Br Approval: Date: CI!lo t h _

(\ '/ l

~

EQUIPMENT TYPE: Junction box w/ splice MANUFACTURER: Kerite MODEL: 5-5NS-HT The insulatic system used on the splices in this junction box are environmentally qualified. The documentation packages for these splices are being completed and when completed, environmental qualification of the splices and this junction box will be proven. Therefore, continued operation is justified.

4 6

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rage lov BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. M01001-19 TER No. N/A Sheet 1 of 1 Preparer: I/N4 7 Date: McM/

Independent Review: k Date: li Approval: ker.JD Date: iftMM (j

EQUIPMENT TYPE: Motor Operator MANUFACTURER: Limitorque MODEL: SMB-0-25 M01001-19 operates the block valve in the cross tie between the "A" and "B" train RHR pump combined discharge headers. The valve is located in the CRD mezzanine pump room at elevation 2'9" (zone 1.8). The valve is normally key-locked open and should remain open to ensure that all four RHR pumps dt. liver LPCI to the selected loop. This valve could be exposed to a harsh steam and radiation environment during a PBOC-5 (HPCI Steam Line Break in the Torus Compartment) or solely to a harsh radiation environment during any other PBOC or a PBIC. The valve is required to remain functional for a 30 day mission tirr.e to facilitate operation of the RHR system in a variety of -

< modes. Limitorque Report B0003 documents the qualification of a similar operator and motor for a harsh steam and radiation environment that envelopes the service profile for all postulated transients af fecting M01001-19 including the PBOC-5. M01001-19 is therefore considered to be qualified pending completion of an inspection to verify that appropriate terminal blocks were utilized for power lead termination (required by IE Notice 83-72). Inspection of the terminal blocks in the Limitorque operators is in progress. No deficiencies in the terminal blocks have been reported and therefore there is a high degree of assurance that the terminal blocks in this motor operator are qualified. Continued operation is therefore justified.

. ~ . _ _ ~_,= -,e.. _ . _ , . _ _ . _ , _ . . . ,

~w - - , ,

Page 167 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment identification No. M01301-49 TER No. N/A Sheet 1 of 1 Preparer: bNh Date: 24 74 '

-^ Date: 2 dgy independent Review: -

1. T Date: 8 /2-r / R 4 Approval:

s \

v EQUIPMENT TYPE: Motcr Operator MANUF#.CTURER: Limitorque MODEL: SM8-00-10 M01301-49 operrtes the block valve in the discharge of the RCIC pump. This valve is located outside the containment in the RCIC Pump Room (zone 1.10).

M01301-49 utilizes a 125v DC reliance motor with class "HR" insulation for which complete qualification documentation is not available. M01301-49 is normally closed and is automatically signaled opened in response to a low

' - reactor vessel level to facilitate injection of RCIC coolant into the i

vessel. The only transients for which RCIC operation is credited are Control Rod Drop, total loss of AC power and loss of feedwater.

However, these transients have been evaluated and no RCICs equipment will be subject to pressure, temperature, radiation or humidity conditions any more severe than those experienced during normal operation. Therefore operability of M01301-49 during exposure to a harsh environment need not be demonstrated for transients requiring RCIC operation.

N01301-49 serves a second safety related function by providing containment isolation for transients not requiring RCIC operation. M01301-49 would remain in a normally closed position during such transients and would not be required to actively function. In the unlikely event that M01301-49 was open

and failed open, redundant isolation of this penetration would be provided by M01301-48, A01301-50 and 58A.

Based on these considerations, continued operation is justified.

i

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$ l BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION t

4 (

l Equipment Identification No. M03800, M03801, M03805, M03806 TER No. N/A Sheet 1 of 1 1

Preparer: [b Date: [b/M

• independent Review: No Date: d' '1 Approval: Date: O P4-O t

! EQUIPMENT TYPE: Motor Operator i MANUFACTURER: Limitorque MODEL: SMS-000

! M03801, M03805, M03800 and M03806 operate the block / isolation valves in.the '

i . salt service water discharge from TBCCW heat exchangers and R8CCW heat

! exchangers respectively. These valves are located in the RBCCW Pump Rooms i and are normally maintained in a throttled open position. Fa11nwing a design i basis accident, M03801 and M03805 will close to a preset throttle position and M03800 and M03806 will go full open to ensure an adequate supply of salt service water to the R8CCW heat exchangers to f acilitate LPCI/RHR torus

' cooling operation. All four operators are equipped with Reliance Motors i utilizing Class 8 Insulation for outside containment application.

• l i During a P81C, these valves are exposed to increased radiation. However, a i harsh radiation environment does not develop until well after the 30 day i mission life of these valves has passed and as a result, the valve operators need not be qualified for a P81C.

t l A valve operator and motor combination similar to M03805 and M03806 was

qualified for extended exposure to steam at 250*F as documented in Lintitorque j Report 80003. During a P80C-3, these valve operators are exposed to i superheated steamtresulting in a service profile which peaks at approximately i

225*F and is enveloped by the qualification test profile. Therefore the l

valves are considered to be essentially qualified for this steam exposure

} pending an inspection required by 1EN 83-72 to verify that appropriate

! terminal blocks were used for power lead terminations. Inspection of the i terminal blocks is in progress and no deficiencies have been reported to date. Therefore there is a high degree of assurance that the terminal blocks

. in these operators are qualified and the operators will remain operable during the steam exposure. In addition, the valves would not be exposed to s l

harsh radiation environment over their 30 day mission length. Based on these considerations, continued operation is justified.

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Page 169 l

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BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION E Equipment Identification No. M02301-6 TER No. N/A Sheet 1 of 1 Preparer: h M Date: /

Independent Review: M#5 Date: 8!2 8i Q U Approval: Q2RC'the Date: E(24If4 lj EQUIPMENT TYPE: Motor Operator MANUFACTURER: Limitorque MODEL: SMB-0-25 M02301-6 operates the valve in the line from the condensate storage tanks to .

the HPCI pump suction. The valve is located in the RBCCW pump room-B (zone 1.22) and is norm ily open. The valve will automatically be closed to facilitate a transfer of HPCI suction to the torus in the event that high

~

torus level or low condensate storage tank level is senseo.

During a PBOC-3 (HPCI Steam Line Break in the HPCI Pump Station) this valve would be exposed to a harsh environment. However, HPCI operation is not .

required for this transient so the exposure of this valve is inconsequential since it serves no function other than supporting HPCI operation.

During any other P80C, a PBIC or a Control Rod Crop, this valve mustHowever, remain operable over the five (5) hours mission time of the HPCI System.

analysis has indicated that the valve would not be exposed to a harsh environment during this time frame.

Based on these considerations, continued operation is justified.

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i Page 170 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION I

t '

Equipment Identification Nr M04009A, M040098, M04085A TER No. N/A Sheet 1 of 1 Preparer: MI b Date: P/3ddf Independent Review:

~ Date: T U 8

Approval: M Date: 8 O

EQUIPMENT TYPE: Motor Operator MANUFACTURER: Limitorque MODEL: SMB-000-5 M04009A, M04009B and M04085A areu req' ired for isolation of non-essential loads in the RBCCW System and may also be used for subsequent restoration of non-essential RBCCW loads once the heat load of th.e RHR heat exchangers has decreased. These valves are located outside containment in the RBCCW Pump Compartments and are normally open.

During a PBIC, these valves will be exposed to increased amounts of .

radiation. However, the increase will be insufficient to cause a harsh As a environment exposure until after the valves mission length has elapsed.

result, the operability of these valves post-PBIC is assured.

A valve operator and motor similar to these valve operators was qualified for extended exposure to saturated steam at 250*F as documented in Limitorque Qualification Test Repcrt B0003. During a PBOC-3, these valves are exposed to superheated steam'resulting in a peak ar.cident temperature of approximately 225*F. These valve operators are therefore considered to be qualified pending completion of an inspection to verify that appropriate terminal blocks were utilized for power lead termination (required by IE i Notice 83-72). Inspection of the terminal blocks in the Limitorque operators have been reported and therefore there is a high degree of assurance that the l

~

terminal blocks in these valve operators are qualified. Based on this determination, continued operation is justified.

a

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Page 171 BOSTON EDISON COM?ANY JUSTIFICATION FOR CONTINUED OPERATICN Equipment Identification No. M04065 TER No. N/A Sheet 1 of 1 Preparer: A/M[/ee Date: ME7d/

Independent Review: bb 3 Date: h 74 Approval: --

M Date: i[3 RF.

EQUIPMENT TYPE: Motor Operator MANUFACTURER: Limitorque MODEL: SMB-000-5 5

- M04065 operates the block valve in the RBCCW supply line to fuel pool heat

. exchanger E-206A. This valve is normally open and needs to be capable of closing to reduce non-essential loads on the RBCCW system during a design basis event requiring RBCCW cooling water supply to the RHR heat exchanger (s). This valve is located outside containment in the fuel pool heat exchanger room (zone 1.13).

A valve operator and motor similar to M04065 was qualified in a steam environment to 250*F, 25 psig and 2 x 10 7 rads as documented in Limitorque Report B0003. This qualification profile envelopes the service profile for all potential harsh environment exposures to M04065 and is therefore considered qualified pending completion of an inspection to verify that appropriate terminal blocks were utilized for power lead termination (required by IE Notice 83-72). Inspection of the terminal blocks in the Limitorque operators is in progress. No deficiencies in the terminal blocks have been reported and therefore there is a high degree of assurance that the terminal blocks in this motor operator are qualified. Based on this determination, continued operation is justified. ,

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Yage u &

O' BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment identification No. M04083, M04084 TER No. N/A Sheet 1 of 1 Preparer: N Date: NMk Independent Review: ^

Date: P!30!IY Approval: _

Date: Th0h 'Y O

EQUIPMENT TYPE: Motor Operator MANUFACTURER: Limitorque MODEL: SM8-000-2 M04083 and M04084 operate the RBCCW bypass valves for the RBCCW to Salt Service Water Heat Exchangers. The valves are located in the RBCCW compartments (zones 1.21 and 1.22) and are normally maintained in a throttled position. If the valves failed to operate, the ability of the RHR system to '

, cool the torus would be degraded.

During a P81C, these valves are exposed to increased radiation. However, a harsh exposure does not occur until well af ter the 30 day mission life of .

these valves has passed. As a result, operability of these valves post-PBIC is assured.

A valve operator and motor similar to these valve operators was qualified for extended exposure to saturated steam at 250*F as documented in Limitorque Qualification Test Report 80003. During a PBOC-3, these valves are exposed to superheated steam resulting in a peak accident temperature of approximately 225'F. These valve operators are therefore considered to be qualified pending completion of an inspection to verify that appropriate teminal blocks were utilized for power lead termination (required by IE Notice 83-72). Inspection of the terminal blocks in the Limitorque operators is in progress. No deficiencies in the terminal blocks have been reported and therefore there is a high degree of assurance that the terminal block in these valve operators are qualified. Based on this determination, contilJed

, operation is justified.

rage 4,s BOSTON EDISON COMPANY

> JUSTIFICATION FOR CONTINUED OPERATION i

Ecuipment identification No. N912, N923 TER No. N/A Sheet 1 of a Preparer: Date:

Independent Review: _.

Date: M/Of Approval: l Date: hk4 nv EQUIPMENT TYPE: Local Control Switch MANUFACTURER: General Electric MODEL: CR2940 N312 is a local start switch for P223 (Gland Seal Condenser Blower) and N923 is a local start switch for P220 (Gland Seal Condenser Condensate Pump).

These switches contribute to HPCIS turbine operation and are, therefore, required solely to assure satisfactory HPCIS operation.

The HPCIS is relied upon to operate during and following -

' Loss of Feedwater Flow, .

Total Loss of Offsite Power, Shutdown from Outside Control Room (Special Event),

Pipe Break Inside Primary Containment, Control Rod Drop Accident, and -

Pipe Break Outside Primary Containment i to assure continued core cooling, and thus mitigate consequences which could result in potential offsite exposures comparable to the 10CFR100 guidelines.

None of the first three events listed above is expected to result in environmental conditions any more severe than those experienced during normal 4

operation. The fourth event is addressed in the HPCIS Safety Evaluation, which states that, "The HPCIS is designed to provide adequate core cooling for small breaks... core never uncovers and is continuously cooled throughout the transient so that no core damage of any kind occurs for breaks that lie within the range of the HPCI." Thus, the size of LOCA presumed to generate postulated core damage is beyond the capacity of HPCIS to provide core  !

cooling.

I The Control Rod Drop Accident has been evaluated and no HPCIS equipment will I be subjected to pressure, temperature, radiation or humidity conditions any more severe than those experienced during normal operation.

Page 174 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. N912, N923 TER No. N/A Sheet 2 of 2 Preparer: Date: T Independent Review: /M M Date: fit Approval: Date:

n

.fd.

Those pipe breaks outside containment which could be expected to result in harsh conditions of pressure, temperature and humidity in the vicinity of these switches are the PBOC-3 and the PBOC-5. Each of these events, however, incapacitates the HPCIS. System operability is, therefore, not required for either PBOC.

On'the other hand, system operability is required for the main steam line breaks, PBOC-7 and PBOC-8. However, FSAR analysis of the PNPS design basis Nain Steam Line Break Accident indicates that, with a maximum 10.5 second

, MSIV closure and continued core coverage (from normal or standby systems, including HPCIS), there would be no fuel damage. Without core damage, exposures will not exceed 104 rads.

MSIV closure time is verified once per quarter under Technical Specification surveillance requirements. The closure time must be greater than 3 seconds and less than 5 seconds for the valve to be considered operable. For valve closure times shorter than 10.5 seconds, the postulated accident is considered less severe than that analyzed.

Core cooling systems are also verified operable periodically under plant surveillance requirements. Thus, if HPCIS was incapacitated as a consequence of the PBOC, then ADS, LPCI and Core Spray would be available to redundantly assure safe shutdown of the plant. If all core cooling systems cperate as designed and tested, harsh radiation levels will not occur.

Therefore, continued operation is justified.

Page 17 5 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. N921 TER No. N/A Sheet 1 of 2 ,

Preparer: - '

Date: 17 !N Ll/I M- +

Independent Review: _

Date: f/n/#

Approval: Date: NZ4ffi A

v EQUIPMENT TYPE: Local Control Switch MANUFACTURER: General Electric MODEL: CR2940 N921 is a local switch for P229 (HPCI Turbine Auxiliary Oil Pump). P229 is only required during turbine startup and shutdown.

The HPCIS is relied upon to operate during and following Loss of Feedwater Flow, Total Loss of Offsite Power, Shutdown from Outside Control Room (Special Event),

Pipe Break Inside Primary Containment, -

Control Roo Drop Accident, and Pipe Break Outside Primary Containment to assure continued core cooling, and thus mitigate consequences which could result in potential of f site exposures comparable to the 10CFR100 guidelines.

None of the first three events listed above is expected to result in environmental conditions any more severe than those experienced during normal operation. The fourth event is addressed in the HPCIS Safety Evaluation, -

which states that, "The HPCIS is designed to provide adequate core cooling for small breaks... core never uncovers and is continuously cooled throughout the transient so that no core damage of any kind occurs for breaks that lie within the range of the HPCI." Thus, the size of LOCA presumed to generate postulated core damage is beyond the capacity of HPCIS to provide core cooling.

The Control Rod Drop Accident has been evaluated and no HPCIS equipment will be subjected to pressure, temperature, radiation or humidity conditions any more severe than those experienced during norr'al operation.

reue m BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. N921 TER No. N/A Sheet 2 of 2 Preparer: Date: O Y Independent Review: /[/ h- Date: M//M Approval: Date: T/Ze./fd, g ,

v Those pipe breaks outside containment which could be expected to result in harsh conditions of pressure, temperature and humidity in the vicinity of this switch is the PBOC-3 and the PBOC-5. Each of these events, however, incapacitates the elPCIS. System operability is, therefore, not required for either PBOC.

On the other hand, system operability is required for the main steam line breaks, PBOC-7 and PBOC-8. However, FSAR analysis of the PNPS design basis Main Steam Line Break Accident indicates that, with a maximum 10.5 second

- MSIV closure and continued cure coverage (from normal or standby systems, including HPCIS), there would be no fuel damage. Without core damage, exposures will not exceed 104 rads.

MSIV closure time is verified once per quarter under Technical Specification ,

surveillance requirements. The closure time must be greater than 3 seconds and less than 5 seconds for the valve to be considered operable. For valve closure times shorter than 10.5 seconds, the postulated accident is considered less severe than that analyzed.

Core cooling systems are also verified operable periodically under plant surveillance requirements. Thus, if HPCIS was incapacitated as a consequence of the PBOC, then ADS, LPCI and Core Spray would be available to redundantly assure safe shutdown of the plant. If all core cooling systems operate as designed and tested, harsh radiation levels will not occur.

Therefore, continued operation is justified.

ep 4

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, -.-m--m-y..,,- ---.- - . - - - - -

. Pag 2 177 i BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment identification No. P202 (A-F)  ;

TER No. N/A Sheet 1 of 2 '

Preparer: /44/howc Date: U30dV Independent Review: Date: [rff/f ,

Approval: ) Date: 9 (d 8

(\ t EQUIPMENT TYPE: RBCCW Pump and Motor Termination Splice MANUFACTURER: General Electric MODEL: SK364AK2020 t

These motors operate the RBCCW pumps and are located in the reactor auxiliary bay at elevation 3' (zones 1.21 and 1.22). These motors are exposed to a harsh superheated steam environment peaking at approximately 225'F following a PBOC-3 (HPCI steam line break in the HPCI pump compartment). The motors are equipped with class '8" insulation (P2020 was rewound). All sir motors utilize a tape type motor termination splice. Continued operation can be justified based on the following considerations.

Motors All 6 motors were supplied by General Electric with class B insulation.

However, the motor for P2020 was subsequently rewound by the GE Apparatus Shop in Medford MA. The motor was inspected by GE upon receipt, rewound with "as-is" or equal insulation in the same manner as it was received, and a C of C was issued to that effect. The rewind materials are therefore traceable as having class 8 or equivalent insulation.

Similar General Electric motors with class B insulation were subject to a qualification test (QSR 111-A-04) which included exposure to a harsh superheated steam environment peaking at 350*F and 66 psig. This envelopes the accident profile for these components. Although the test profile was only for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, Wyle Labs has performed a degradation analysis that shows the test profile was more severe than the 30 day accident profile.

Solices Plant walkdowns verified that tape type motor termination splices with a glyptal outer covering were utilized on these components. Similar splices have been qualification tested (FRL F-C3056). The test splices were subjected to a steam environment for 7-1/2 days. The splices were electrically loaded throughout the exposure period. The peak temperature and pressure of 325'F and 80 psig was maintained for a duration of 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />. The temperature and pressure were reduced to 220'F and 5 psig for the remainder

Pace 178 i

BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. P202 (A-F)& '

TER No. N/A  :

Sheet 2 of 2 '

Preparer:

MM b m Opte: f/10MY Independent Review:

Date: _ fff f f M Approval: )

(\

Date: 3 O!f

~ '~f _

of the test. The samples were subjected to a chemical spray solution throughout the test.

Wyle Labs has completed degradation equivalency j analysis which shows that the test profile is thermally more degrading than the composite outside containment profile at Pilgrim Station for 30 days. An aging analysis was also performed by Wyle Labs shows that the materials of the tested splice have a minimum expected life at 105'F of 272 years (glass tape).

The 1expected greater than x 105 years. life of the glyptal (assume alkyd varnish) at 105'F is Based on these considerations, continued operation is justified.

1 I

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BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. P229 ,

TER No. N/A Sheet 1 of 2 Preparer: -

Date: -

Independent Review: 42/ b r Date: f/IfM/

Approval:

Date: T,b . N gg -

i v

EQUIPMENT TYPE: Lube Oil Pump Motor MANUFACTURER: Baldor MODEL: 310401 -404 4

P229 is the HPCI Turbine Auxiliary 011 Pump. It is only required during turbine startup and shutdown.

The HPCIS is ralied upon to operate during and following

' Loss of Feedwater Flow, Total Loss of Offsite Power, Shutdown from Outside Control Room (Special Event),

Pipe Break Inside Primary Containment, Control Rod Drop Accident, and ~

Pipe Break Outside Primar,' Containment to assure continued core cooling, and thus mitigate consequences which could result in potential offsite exposures comparable to the 10CFR100 guidelines.

None of the first three events environmental conditions any m listed above is expected to result in operation. ore severe than those experienced during normal The fourth event is addressed in the HPCIS Safety Evaluation, which states that, "The HPCIS is designed to provide adequate core cooling for small breaks... core never uncovers and is continuously cooled throughout the transient within so that the range of the noNPCI." core damage of any kind occurs for breaks that lie Thus, the size of LOCA presumed to generate i postulated cooling. core damage is beyond the capacity of HPCIS to provide core The Control Rod Drop Accident has been evaluated and no HPCIS equipment will be subjected to pressure, temperature, radiation or humidity conditions any more severe than those experienced during normal operation.

Those pipe breaks outside containment which could be expected to result in harsh conditions of pressure, temperature and humidity in the vicinity of this pump is the PBOC-3 and the PBOC-5.

, incapacitates the HPCIS. Each of these events, however, i

either P80C. System operability is, therefore, not required for l

BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. P229 TER No. N/A Sheet 2 of 2 Preparer: --

~ Date: /7!FY' Independent Review: I// Date: f!#///

Approval: Date: 9./2e/8 d g .

v On the other hand, system operability is required for the main steam line breaks, PBOC-7 and PBOC-B. However, FSAR analysis of the PNPS design basis Main Steam Line Break Accident indicates that, with a maximum 10.5 second MSIV closure and continued core coverage (f rom nortnal or standby systems, including HPCIS), there would be no fuel damage. Without core damage, exposures will not exceed 104 rads.

MSIV closure time is verified once per quarter under Technical Specification surveillance requirements. The closure time must be greater than 3 seconds and less than 5 seconds for the valve to be considered operable. For valve

- closure times shorter than 10.5 seconds, the postulated accident is considered less severe than that analyzed.

Core cooling systems are also verified operable periodically under plant surveillance requirements. Thus, if HPCIS was incapacitated as a consequence .

of the PBOC, then~ ADS, LPCI and Core Spray would be available to redundantly assure safe shutdown of the plant. If all core cooling systems operate as designed and tested, harsh radiation levels will not occur.

Therefore, continued operation is justified.

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Pagti Ao4 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment identification No. PS2390A, PS23908 TER No. N/A Sheet 1 of 2 Preparer: -

Date: k!IT )F'/

Independent Review: d/) b Date: bfh Approval: Date: 28 b nv EQUIPMENT TYPE: Pressure Switch MANUFACTURER: Static-0-Ring MODEL: 6N-AA2-XSPP These pressure switches provide a condensate storage tank level signal to HPCI valve control to open M02301-35, 36. M02301-35, 36 also serve as HP.CI isolation valves. The HPCI isolation signal overrides the Condensate Storage Tank level signal provided by these pressure switches. Therefore, PS2390A, B

, are required solely to assure satisfactory HPCIS operation.

The HPCIS is relied upon to operate during and following 4

Loss of Feedwater Flow,

Total Loss of Offsite Power, '

j Shutdown from Outside Control Room (Special Event),

Pipe Break Inside Primary Containment, Control Rod Drop Accident, and Pipe Break Outside Primary Containment to assure continued core cooling, and thus mitigate consequences which could result in potential offsite exposures comparable to the 10CFR100 guidelines.

None of the first three events listed above is expected to result in environmental conditions any more severe than those experienced during normal operation. The fourth event is addressed in the HPCIS Safety Evaluation, 4

which states that, "The HPCIS is designed to provide adequate core cooling for small breaks... core never uncovers and is continuously cooled throughout the transient so that no core damage of any kind occurs for breaks that lie within the range of the HPCI." Thus, the size of LOCA presumed to generate postulated core damage is beyond the capacity of HPCIS to provide core cooling.

The Control Rod Drop Accident has been evaluated and no HPCIS equipment will be subjected to pressure, temperature, radiation or humidity conditions any

more severe than those experienced during normal operation.

i

&d 9tf 604 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. PS2390A, PS2390B TER No. M/A Sheet 2 of G Preparer:

Opte: __//19[Fl' IApproval:

Independent Review: I lidM h; Date: k#M

(\

v Date: _

i[2e[fh['

harsh conditions of pressure, temperature and hum these pressure switches are the PBOC-3 and the PBOC-5.

however, incapacitates the HPCIS. Each of these events, required for either PBOC. System operability is, therefore, not breaks, PBOC-7 and PBOC-8.On the other hand, system operability is req Main Steam Line Break Accident indicates tHowever, FSAR analysis of the PNPS MSIV closure and continued core coverage (hat, with a maximum 10.5 second including HPCIS), there would be no fuel damage.from normal or standby systems, n posures will not exceed 104 rads. Without core damage, MSIV closure surveillance time is verified once per quarter under Technical Specificatio requirements. .

and less than 5 seconds for the valve to be considered operable.T For valve closure times shorter than 10.5 seconds, the postulated accident is considered less severe than that analyzed.

surveillance requirements. Core cooling systems are also verified operable of thesafe assure PBOC, shutdownthen ADS, of the plant. LPCI and Core Spray would be av designed and tested, harsh radiation will not occur.If all core cooling systems ope Therefore, continued operation is justified.

l i

Page 183 BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. PS4008, PS4058 TER No. N/A Sheet 1 of 2 Preparer:

d/l dem i

IIndependentReview: -

Date:

Date:

M3/k 3/ 'l Approval:

M Date: 9[7 o ,

EQUIPMENT TYPE: Pressure Switch MANUFACTURER: Barton MODEL: 288A P202 (A-F) to the RBCCW Control Circuitry.These pressure s pump (s), which are in " auto".below 31 psig the pressure swite.h se pumps from starting automatically upon failure of one pump. Failure o 4

The pressure switches are located in the RBCCW compartments (zones 12 1.22) and are exposed to a harsh superheated steam environment resu peak temperature / pressure of approximately 225'F/1.5 psig. ,

i not length. exposed to a harsh radiation environment during their 30 day missionThe swit i

sumarized in qualification test report R3-288A-1. Continued opera Temoerature

. test temperature profile.The service profile for the location of this device is than the test temperature of 212*f.The peak service temperature of 225*F is higher However, the service temperature is 4

above 212'F for only a few minutes and the test temperature is significan i' higher than the service profile for the remainder of the test s.ariod (6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />).

It should be noted that saturated steam blanketing of high thermal

' inertia components Limitorque Report 80027 such as this pressure switch, as demonstrated in equivalent of an exposur,e to 215'F to the exterior of In the switches.w temperature less than the test temperature of 212*F.

of the pressure switches under the service i profile in the temperature profile. test report is actually more severe than the serviceOn this basi i

I

\

i BOSTON EDISON COMPANY JUSTIFICATION FOR l CONTINUED OPERATION Equipment identification No. PS4008, PS4058

, TER No. N/A Sheet 2 of 2 Preparer: d/2 her Date: M.I/M Independent Review: Date: N Approval: . - -

Date: f b,!b ,

(

v Steam Exposure A prototype of this component was subjected to 100% humidity for 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. In our engineering judgment, this test was more severe than the environment to which this component may be subjected during an accident.

Aging

~

Conditions of aging were evaluated using the Arrhenius technique. Based o'n the analysis, which considered all non-metallic materials within the switch, an estimated life in excess of 40 years was established. This calculation supports projected operability of the differential pressure switch beyond .

1986.

Pressure The service profile for the location of this device reaches a peak of 1.5 psig, whereas the test pressure reaches a maximum of 7" H2 O (14.95 psi).

The service profile is above 14.95 psia for approximately 2 seconds. Based on this fact and the weathertight construction of the instrument, in our engineering judgment no functional disparities will occur.

f

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A Page 185 ,

l BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment identification No. Ring Tongue Terminations (<4KV) Outside Containment TER No. N/A Sheet 1 of 2 ,

Preparer: kl.940uNb Date: Itk4 d d h

Date: l Independent Review:

Approval: [/L &', Date: N2b

~n -

EQUIPMENT TYPE: Ring Tongue Terminals MANUFACTURER: Various MODEL: Various According to Wyle Laboratories Corrective Action Report No. 47066-TER-1, the installed ring tongue terminals include both insulated and non-insulated models f rom a variety of manuf acturers. The insulation materials used on insulated models has not been specifically identified. The commonly used insulation materials for this application are nylon, PVC, PVF, and PVDF.

Justification for continued operation is required as specific qualification j tests do not exist.

• Uninsulated ring tongue terminals are not susceptible to degradation or environmentally induced failure at the levels of stress produced by the l

environments at the Pilgrim I plant. Failure of these interfaces is a function of installation configuration and terminal design.

Insulated ring tongue terminals are supplied with an insulating material covering the barrel of the terminals. This insulation is provided to prevent bare metal from protruding beyond the terminal block or connection to which it is fastened, thus reducing the hazard of shock to personnel and a possible shorting path between adjacent terminals and equipment. At the voltage levels of these terminations, the physical presence of any of the industry stand ard insulating materials is sufficient to perform this function.

l The environments wtich could cause significant insulation deterioration in

' the Pilgrim plant are temperature and radiation. Degradation induced by these environments takes the form of material softening, material esbrittlement, increased compression set, loss of elongation capability, or cracking when subjected to bending stresses or dynamic loads. None of these degradation mechanisms will impact the physical barrier insulation capability of the materials in their static termination application.

The justification discussed above has been substantiated by the application of numerous terminal lugs in nuclear equipment qualification tests. While these tests were not specifically designed to qualify the terminals and the models do not necessarily correlate with Pilgrim installed lugs, the tests

i Page 186 i l

i BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment identification No. Ring Tongue Terminations (<4KV) Outside Containment TER No. N/A Sheet 2 of 2 .

Preparer: bdM Date: 2#ffirq Independent Review: -

Date: 7 Approval: -.

1. f4mh

~g Date: 819 [f 4 demonstrate that in typical plant environments, neither insulated nor non-insulated terminal lugs constitute a significant potential failure mechanism. Samples of tests which included representative terminals as part of the test specimen or part of the test equipment are Wyle 45603-1, Wyle 45638, Franklin C5257, Wyle 43703, Wyle 44282, Wyle 44300, Franklin C5022.

Based on the above, continued operation with existing ring tongue terminals is justified.

9 1

Page 187 l BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. 51 S37, CXG, 23, 23A, S48, CO2, CO3, S19 S27 TER No. N/A Sheet 1 of 1 Preparer:

Date: 2 U Independent Review: bl. bM Date: N!24!8Y i I "Q Q Approval: C5 LC A D -- Date:  %/27/P4

\

V EQUIPMENT TYPE: Cable MANUFACTURER: Various MODEL: PE/PVC This equipment consists of polyethylene insulated polyvinylchloride jacketed cable (installed outside the drywell) provided by several manuf acturers.

• While no qualification documentation or testing history has been found for these specific cables, similarly constructed cable has been successfully

. subjected to sequential testing (proprietary TR #17513-1), which documents qualification of the insulation system to 1.63 x 108 rads gansna and a LOCA condition including temperatures up to 325'F. These conditions are more severe than the conditions at PNPS. ,

The generic materials which make up the insulation system have expected lives of greater than 1.4E4 years (PVC) and greater than 1.5E4 years (PE) in an ambient temperature of 105'F.

Based on the above, it is judged that the PVC/PE cable installed is justified for continued use pending further testing or replacement.

i

BOSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION .

Equipreent Identification No. SYL82 SYL83 TER No. N/A Sheet 1 of 1 I Preparer:

• Date: I' Y Independent Review: AM Date: U Approval: d'7C' b - Date: 7 l'2AI R4

( \

w EQUIPMENT TYPE: Solenoid Valve MANUFACTURER: ASCO MODEL: HT8320A22 These solenoid valves control air operated valves that allow the SGTS to obtain a suction on the suppression pool. These valves are not required to operate post-P80C; therefore, they only need to be qualified for radiation.

The 40 year TID plus LOCA dose is 2.86 x 106 rads. The two materials of concern in this valve are the 8una-N elastomers and the acetal disc holder.

In EPRI Report NP-2129, " Radiation Effects on Organic Materials in Nuclear Plants" Buna-N is7listed as not reaching the 50% loss of elongation point until af ter 7 x 10 rads and acetal resins are listed as reaching the 50%

loss of tensile strength at 4 x 10 6 rads. Each of these doses is greater ~

than the combined 40 year TID plus accident dose. Therefore, no detrimental effects, due to radiation, are expected, and continued operation is justified.

l

.g-

~

COSTON EDISON COMPANY JUSTIFICATION FOR CONTINUED OPERATION Equipment Identification No. TIP Ball and Shear Valves Sheet 1 of 1 TER No. N/A

• I

• Date: T //8'/

Preparer:

hN-%" Date: --

/W/M r

Independent Review: y Date:  %(T7 I14 l Approval: Nth - - < \

% J EQUIPMENT TYPE: Containment Isolation Valves MANUFACTURER: Cor,solidated Controls MODEL 73110-2 (Ball)D3074-1 (Shear)

The The safety function of these valves is primary containment isolation.

only accident for which they mustThe provide this safety components are located function is a pipe outside break inside primary containment.

containment, and therefore, they must be qualified for radiation and aging only.

Continued operation with these components not qualified is justified because The ball they provide diverse means of isolating the affectedIn penetrat '

hrs. per 2 week period) and they do not require power to remain closed.

the unlikely event that a pipe break inside primary containment occurs with the TIP probes inside the drywell, diversity in the system provides assuranceTh that the penetrations will be isolated.

provide a signal to the Primary Containment Isolation display in the Main Control Room.

Should any of the ball valves spuriously open or be held open by a stuck probe under accident conditions, the operators can detect this and fire the shear valves which are poweren by 125;V DC, ensuring operability in case offsite power is lost.

Therefore, continued operation is justified, i

l 1

1 l

l

Page 190 l

I BOSTON EDISON COMPANY JUSTIFICATION FOR i CONTINUED OPERATION Equipment Identification No. SYL61 TER No. N/A Sheet 1 of 1 Preparer: k '

Date: E/27/77 Independent Review: Date: '

1 N U

U Approval: C : R C L h - -- a Date:  % /27/84 iT~

EQUIPMENT TYPE: Solenoid valve MANUFACTURER: ASCO MODEL: HT8320A107

~~

This solenoid valve is an AS.C0 HT8320A107. It is unknown if this valve will survive the radiation due to a LOCA; however, it is not required to operate post- accident. SYL61 controls the air supply to operate the cross-tie damper between Reactor Building Clean Exhaust and Refueling Floor Exhaust

. Ducts. This damper provides the isolation between safety-related and nonsafety-related exhaust ducts. If the SYL61 disc fails, the air supply to A0/N-138 will be vented and A0/N-138, which is normally closed, will fail open. If A0/N'138 fails open, when SGTS operates, a suction will be drawn on .

both the Reactor Building Clean Exhaust and the Refueling Floor Exhaust simultaneously.

If SYL61 fails such that air is continuously supplied to A0/N-138, A0/N-138 will remain shut. However, the Reactor Building Clean Exhaust and Refueling Floor Exhaust can both be ventilated through their own ducts and isolation valves (A0/N-100 and A0/N-101).

Therefore, continued operation is justified.

1

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