ML20107B113

Withdraws Extension Request for Category 3 & 4 Schedular Requirements of 10CFR50.49 for safety-related Electrical Penetration Subassemblies.Qualification Established. Extension Until 851130 for Categories 1 & 2 Requested

ML20107B113
Person / Time
Site:	Fort Calhoun
Issue date:	02/14/1985
From:	Andrews R OMAHA PUBLIC POWER DISTRICT
To:	Harold Denton Office of Nuclear Reactor Regulation
References
LIC-85-003, LIC-85-3, NUDOCS 8502200237
Download: ML20107B113 (17)

Text

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Omaha Public Power District 1623 Harney Omaha, Nebraska 68102 402/536-4000 February 14, 1985 LIC-85-003 l Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, DC 20555

References:

(1) Docket No. 50-285 (2) Letter OPPD (R. L. Andrews) to NRC (Mr. Harold R. Denton) dated July 3, 1984

Dear Mr. Denton:

Environmental Qualification of Safety Related Electrical Equipment at Fort Calhoun Station Request for Extension In Reference 2, the Omaha Public Power District, holder of Facility Operating License DPR-40, requested an extension of the schedular requirements of 10 CFR 50.49 for safety-related electrical penetration subassemblies at Fort Calhoun Station. This request included a Justification for Continued Operation (JCO).

Reference 2 identified four (4) categories of electrical penetration subassem-blies. Those categories are: (1) those penetration subassemblies which are currently under administrative control; (2) those penetration subassemblies which do not perform an accident mitigation function after a LB-LOCA; (3) those penetration subassemblies which were modified prior to returning to power operation; and (4) those penetration subassemblies which would complete their post-accident function prior to experiencing environmental stresses suf-ficient to induce failure.

Since submittal of Reference 2, our review of Categories (3) and (4) has been l

completed and the District believes qualification has been established. An extension for Categories (3) and (4) is no longer required and the request is hereby withdrawn. The District's basis for establishing qualification and/or 1

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LIC-85-003 Page 2 justification for continued operation of each category of penetration subassem-bly is included in Attachment A. Attachment A is a revised and more detailed version of the Technical Discussion which accompanied Reference 2. For the reasons detailed in Attachment A, the time extension until November 30, 1985 requested in Reference 2 is still required for Categories (1) and (2). Separ-ate JCOs for these two categories have been prepared at the request of your staff and can be found in Attachments B and C, respectively.

Sinc ly,

< !W-R. L. Andrews Division Manager Nuclear Production RLA/DJM/dao Attachments cc: LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W.

Washington,-DC 20036 Mr. E. G. Tourigny, NRC Project Manager Mr. L. A. Yandell, NRC Senior Resident Inspector

t Attachment A Technical Discussion of Environmental Qualification Testing of Electrical Penetrations The Fort Calhoun Station containment electrical penetration system provides a dual function of transmitting electric power and instrument signals via insu-lated conductors, and at the same time sealing the conductors to provide con-

~tainment integrity (refer to Fort Calhoun Station Unit No.1 USAR Section 5.9.3 for a description of the penetrations). . This function is accomplished by the use of subassemblies which are inserted in a penetration canister.

Each subassembly is made up of a stainless steel tube-(sheath) through which a lead wire, or wires (depending on the type) are run and sealed at both ends. The penetration system subassembly types are multiconductor low volt-age -(600V), single conductor low voltage, medium voltage (4160V), coaxial, triaxial, and thermocouple lead wires. The subassemblies under discussion are the multi-conductor low voltage (120V and 480V single and three phase power, A.C. control, D.C. control, and instrumentation) and/or thermocouple configurations. These particular multiconductor penetrations use FEP teflon as the lead wire insulation, and TFE teflon as the seal material in the sub-assembly.

Because the D0R Guidelines for electrical equipment qualification recommended type testing of. equipment containing materials which are susceptible to radi-

-ation . damage, the District conducted an environnental qualification test of the low voltage multiconductor penetration subassenbly constructed using tef-lon. The sequential test procedure used IEEE 317-1976 and IEEE 323-1974 as a guide. Plant specific ' parameters were used to envelope the sequentially applied environmental stress parameters (aging, short circuit and short time-

- overload, seismic, radiation, and MSLB/LOCA, short circuit).

During the LOCA testing (following irradiation) the teflon lead wire insula-

-tion became brittle and cracked. The penetrations were no longer able to per-fonn their required electrical function.

Based on subsequent engineering evaluation and testing, the failure mechanism for the penetrations.has been detennined. . The- penetration FEP teflon lead wire insulation is weakened (the teflon chemical chain is broken) by radia-tion. After irradiation to the.720 hour0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> (long tenn operation) total inte-grated. dose, the heatup and subsequent cooldown of the penetrations resulted in a mechanical stress which, during cooldown,-caused the lead wire insula-tion. to crack resulting in electrical failure. This was confirmed when the failure was duplicated by the heatup and cooldown of lead wires without the presence of steam, pressure or spray.

The District.has reviewed the electrical equipment in the containment which

,must function after a design basis accident and has determined four classiff-

-cations of equipment:

1.: ' Equipment which can.be administrative 1y controlled.

2. . Equipment not required to function in the event of a large Break LOCA (LBLOCA). The equipment must function during either a Main Steam Line Break (MSLB), a Small Break LOCA ~(SBLOCA) or both.

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3. Equipment which is required to function during a large Break LOCA and has been modified to ensure operation.

4._ Equipment which completes its function prior to failure induced by a large Break LOCA.

The penetration subassemblies, their respective TER number, system, function and device are tabulated in the attached Tables 1-1, 1-2, 1-3 and 1-4.

The District believes that classifications 1 and 2 can be justified for con-tinued operation until a permanent resolution is achieved. Classification 1 is justified by use of administrative control while Classification 2 is just-ified by use of partial test data to support qualification.

1. Equipment which can be administrative 1y controlled.

The equipment listed in Table 1-1 is that equipment which will be admin-istratively controlled. These are all air-operated control valves with-in containment. If failure were to occur the air would be failed to the valves.

Additionally, any electrical shorting between the solenoid-operated valve and its position indication is not expected to cause valve reposi-tioning. Circuit design is such that shorting would result in either loss of position indication or indication that the valve was simultan-eously opened and closed.

The fail position is the same position as the accident position. The District believes continued safe operation is justified.

The administrative controls are currently in place as implemented by Operations Memorandum 84-06 and direct the failure of instrument air to containment in the event of improper or unreliable valve position indication. The penetration subassemblies are those listed in Table 1-1,- and required a deadline extension. They will be qualified by November 30, 1985. The JC0 is provided in Attachment B.

2. Equipment not required to function in the event of a Large Break LOCA (the equipment must function during either a MSLB, SBLOCA or both).

The District first reviewed the systems discussed below to ensure that their loss would not impact the mitigation of the consequences of a LBLOCA with these results:

Auxiliary Feedwater Provides no heat removal since steam generator U-tubes are emptied.

PORY & Safety Valve Position Indication

-RCS is depressurized, no flow could be expected.

Pressurizer Level and Pressurizer (Narrow Range)

The pressurizer is empty and pressure is below the narrow range.

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Reactor Head Vent The RCS is depressurized with cooling out of the break.

PORY and PORY Block Valyc The RCS is depressurized, flow out of the break is so great an open PORY line will not affect safety.

Steam Generator Reactor Trip Trip is accomplished by TMLP vi, low limit setpoint.

Narrow Range Sump The sump is flooded above these transmitters yielding no useful information.

To determine that safe continued operation can be justified with the re-quirement that the penetrations function during and following a SBLOCA and/or MSLB, the District reviewed the expected radiation dose, and known teflon material perfomance. The first step was to determine whe-ther the SBLOCA or MSLB should be used as the limiting case for radia-tion dose. The second step was to determine the expected dose level .

The final step was to evaluate the performance of FEP tefion lead wires when subjected to the expected radiation dose.

To determine the limiting case, the District reviewed USAR Sections 14.12 - MSLB and 14.15 - LOCA (including Small Break LOCA). The Dis-trict concluded that the SBLOCA would be the most limiting case. The electrical penetrations are shielded from the RCS by the biological shield and MSLB calculations indicate total RCS leakage of 491 lbm from the primary to the secondary. This is equal to the amount of RCS leak-age expected in the containment atmosphere while the SBLOCA calcula-tions indicate a 8,500 lbm/sec RCS flow into the containment. The lim-iting case is, therefore, considered to be the SBLOCA.

The District then evaluated the expected SBLOCA dose. Since computer programs to quantitatively detemine dose are not readily available, the District compared the fuel clad oxidation indicated in USAR Section 14.15 with the assumption used in the NUREG-0588 source term discus-sion. This comparison chowed a peak clad oxidation of <2.10% versus 10% to 80% fuel damage indicated in NUREG-0588. The District judges that the total integrated dose would be reduced from the dose calcu-lated using the NUREG-0588 source tenn by a factor of at least 10 which is equivalent to a TID of approximately 1.36x10 6R for 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br />.

A review of FEP teflon performance made using EPRI Report NP-2129 indicates acceptable material perfomance for this projected TID.

Background radiation dose until November 30, 1985, is expected to be less than 1% of the qualification dose and is not considered to be a significant factor.

It should be noted that this is believed to be conservative since fail-ure requires an accumulated radiation dose followed by a temperature 3

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+ transient. Since the temperature transient begins with a TID of 0 (nor-mal background TID is not significant) and is reduced to near ambient within the first hours of the accident, the necessary failure parame-ters are not believed to exist.

I The District believes this justified and continues to justify safe con-tinued operation. A deadline extension is required for those penetra-tions listed in Table 1-2. The JC0 is provided in Attachment C.

7 The District considers Classifications 3 and 4 to be qualified under 10 CFR 50.49 and the DOR Guidelines (applicable to the Fort Calhoun Station). The t following discussion is to provide a brief outline of the basis by which the District judges Classifications 3 and 4 to be qualified.

s 3.. Equipment' which is required to function in the event of a Large Break LOCA and has been modified to insure operation.

l- The District determined that qualification could be established only by insuring that teflon . insulation did not act as the primary insulation for the lead wires exposed to the containment atmosphere. To accomp-lish' this the lead wires were sleeved with LBLOCA qualified Raychem heat shrink and the applicable wires at the sleeve to feedthrough seal interface were coated with RTV (LBLOCA qualified) between the stainless steel sheath and the Raychem sleeve.

- The' District believes that the only area requiring review in this de-sign was the RTV-teflon seal-teflon lead wire interface. It is the District's belief that since both the RTV and sleeving are LBLOCA qualified and that the application of each is correct as indicated by the manufacturer, the equipment can be considered qualified.

. All_ conductors:of a subassembly were not sleeved. The District, there-

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fore, reviewed the potential for moisture leakage down the unsleeved conductors and across'the seal face to the teflon sleeve conductors

-causing either a short or a ground. 'The District believes this is not an. area of concern. The District believes that the- potential leakage-path is very small, and that there will be no differential pressure o present to force moisture into the interface.- This is aided by the physical 1 separation at the seal face which increases any potential

. tracking path distance.

L A time extension of the deadline for the equipment covered in Table 1-3

is not necessary and is not requested.

4. Equipment which completes its function prior to a failure induced by a LBLOCA.

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,, Qualification of the items listed in Table 1-4 is determined by the l failure mechanism. A radiation dose must accumulate sufficiently to damage the teflon and must be followed by a temperature transient.

Testing with a 720 hour0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> total dose indicated failure after 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> using the District's test profile. Equipment in this category must complete its function 31.45 seconds into a LBLOCA. The District

, believes this margin coupled with the actual time to achieve a damaging

' dose is adequate to prove qualification, a 4 s

4 The District has ~ conducted a survey of background dose to the assem-blies inside containment. The 40 year background dose is expected to just reach the threshold of the TFE seal and is expected to be well below the FEP insulation threshold. No problem should be encountered.

A time extension deadline for the equipment covered in Table 1-4 is not necessary and is not requested.

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Attachment B Justification for Continued Operation Equipment Which Can Be Administratively Controlled 10 CFR 50.49(i) provides guidance concerning those items which should be con-sidered in development of a justification for continued operation until that time when equipment qualification can be established. The justification should include consideration of the following items:

(1) Accomplishing the safety function by some designated alternative if the principal equipment has not been demonstrated to be fully qualified:

District's Position The District is not justifying continued operation under this section.

4 (2) The validity of partial test data in support of the original qualifica-tion:

District's Position:

The District is not justifying continued operation under this section.

(3) Limited use of administrative controls over equipment that has not been demonstrated to be fully qualified:

District's Position:

Administrative controls were established for the equipment listed in Table 1-1 where the failure of electrical equipment has the potential for providing the operator with misleading information. It is expected that solenoid-operated valves will fail in their accident positions.

For any indication to the contrary, the operators are instructed to fail the instrument air to containment, thus ensuring the valve is positioned in its accident position.

See the Technical Discussion.

(4) Completion of the safety function prior to exposure to the accident environment resulting from a design basis event and ensuring that the subsequent failure of the equipment does not degrade any safety func-tion or mislead the operator:

District's Position:

The District is not justifying continued operation under this section.

(5) No significant degradation of any safety function or misleading informa-tion to the operator as a result of failure of equipment under the acci-dent environment rasulting from a design basis event:

District's Position:

The District believes that there will be no degradation in the safety function. The administrative controls ensure that the safety functions are accomplished.

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There is no expected problem with misleading information. The admints-trative controls point out the potential problem and provide definitive action to be taken so that exact equipment status is assured.

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Attachment C Justification for Continued Operat' ion Penetrations Not Required To Function For Large Break LOCA (Qualified for Small Break LOCA and Main Steam Line Break) 10 CFR 50.49(i) provides guidance concerning those items which should be con-sidered in development of a justification for continued operation until that time when equipment qualification can be established. The justification should include consideration of the following items:

(1) Accomplishing the safety function by some designated alternative if the principal equipment has not been demonstrated to be fully qualified:

District's Position The District is not justifying continued operation under this section.

(2) The validity of partial test data in support of the original qualifica-tion:

District's Position:

The District has partial test data in which it can be demonstrated that the penetration subassemblies listed in Table 1-2 will remain functional for a LOCA event excluding radiation exposure. Other test data indicates that the penetration subassemblies are not degraded by aging. The District used judgement to establish the expected radiation dose for the SBLOCA and MSLB. By analysis the District judged that the expected dose was sufficiently low to not degrade the teflon to a degree which would induce failure. The analysis is based on known characteristics of tefl on. See the Technical Discussion for further detail regarding the radiation analysis.

(3) Limited use of administrative controls over equipment that has not been demonstrated to be fully qualified:

District's Position:

The District is not justifying continued operation under this section.

(4) Completion of the safety function prior to exposure to the accident envi-ronment resulting fron a design basis event and ensuring that the subse-quent failure of the equipment does not degrade any safety function or mislead the operator:

District's Position:

The District is not justifying continued operation under this section.

(5) No significant degradation of any safety function or misleading informa-tion to the operator as a result of failure of equipment under the acci-dent environment resulting from a design basis event:

District's Position:

Since the equipment does not nitigate the consequences of a LBLOCA, no degradation of a safety function is expected. The equipment is expected 1

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to fulfill its safety function under those accident conditions for which it is required to operate.

Since the equipment does not have to function during a LBLOCA, infonna-tion provided will not mislead the operator, nor detract from the informa-tion and functions provided in the emergency procedures.

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s Table 1-1 Equipment Administratively Controlled Penetration TER Device (s)

I.D. No. No. System Function Fed C9-17 99 CVCS Cont. Isolation & ntrol TCV-202 C9-1 99 CYCS Cont. Isolation Control HCV-241 C9-10 99 CCW Cont. Isolation Control HCV-425A C9-10 99 CCW Cont. Isolation Control HCV-425C C9-10 99 CCW Cont. Isolation Control HCV-438A C9-11 99 CCW Cont. Isolation Control HCV-438C C9-11 99 CCW Cont. Isolation Control HCV-467A C9-11 99 CCW Cont. Isolation Control HCV-467C C9-7 99 Cont. Cooling & Air Control HCV-724A Filter Unit Dampers C9-7 99 Cont. Cooling & Air Control HCV-724B Filter Unit Dampers B2-6 99 Cont. Cooling & Air Control HCV-725A Filter Unit Dampers B2-6 99 Cont. Cooling & Air Control HCV-725B Filter Unit Dampers C9-7 99 Cont. Purge Isolation Control PCV-742A C9-8 99 Cont. Purge Isolation Control PCV-742C C9-8 99 Cont. Rad. Monitor Iso. Control PCV-742E C9-8 99 Cont. Rad. Monitor Iso. Control PCV-742G C9-17 99 Cont. Vent. Isolation Control HCV-746A C9-17 99 H2 Purge Isolation Control HCV-881 C9-18 99 H2 Purge Isolation Control HCV-882 C9-18 99 H2 Purge Sample Iso. Control HCV-883A C9-18 99 H2 Purge Sample Iso. Control HCV-884A B2-9 99 N2 Isolation Control HCV-2603B B2-9 99 N2 Isolation Control HCV-26048 C9-9 99 Sample Isolation Control HCV-2504A C9-9 99 Sample Isolation Control HCV-2506A C9-9 99 Sampie Isolation Control HCV-2507A C9-12 99 SG Blowdown Isolation Control HCV-1387A C9-13 99 SG Blowdown Isolation Control HCV-1388A

Table 1-2 Equipment Not Required to Function in the Event of a Large Break LOCA Penetration TER Device (s)

I.D. No. No. System Function Fed A11-7 99 Auxiliary Feedwater Instrumentation A/LT-911 A/LT-912 A/PT-913 A11-8 99 Auxiliary Feedwater Instrumentation A/PT-914 A4-8 99 Auxiliary Feedwater Instrumentation B/LT-911 B/LT-912 B/PT-913 A4-9 99 Auxiliary Feedwater Instrumentation B/PT-914 DS-7 99 Auxiliary Fecdwater Instrumentation C/LT-911 C/LT-912 C/PT-913 DS-8 99 Auxiliary Feedwater Instrumentation C/PT-914 D10-5 99 Auxiliary Feedwater Instrumentation D/LT-911 D/PT-913 D10-6 99 Auxiliary Feedwater Instrumentation D/LT-912 D/PT-914 C9-13 99 Auxiliary Feedwater Instrumentation HCV-1107A C9-16 99 Auxiliary Feedwater Instrumentation HCV-1108A D5-6 99 PORY & Safety Position Instrumentation YM-102-1 YM-141 A4-8 99 PORY & Safety Position Instrumentation YM-102-2 YM-142 B5-1 99 Press. Level & Press. Instrumentation PT-103X LT-101X 2 99 Press. Level & Press. Instrumentation PT-103Y LT-101Y E2-9 99 Reactor Head Vent Control HCV-176 HCV-178 E2-10 99 Reactor Head Vent Control HCV-181 E9-7 99 Reactor Head Vent Control HCV-177 E9-8 99 Reactor Head Vent Control HCV-179 E9-9 99 Reactor Head Vent Control HCV-180 El-3 99 PORY & PORY Block Valve Power PCV-102-1 HCV-150

Penetration TER Device (s)

I.D. No. No. System Function Fed E2-8 99 PORY Block Valve Control HCV-150 E2-7 99 PORY Control PCV-102-1 B1-3 99 PORY & PORY Block Valve Power PCV-102-2 HCV-151 B2-10 99 PORY & PORY Block Valve Control PCV-102-2 HCV-151 A11-4 99 S/G Reactor Trip Instrumentation A/LT-901 A/PT-902 A/LT-904 A/PT-905 A4-3 99 S/G Reactor Trip Instrumentation B/LT-901 B/PT-902 A4-4 99 S/G Reactor Trip Instrumentation B/LT-904 B/PT-905 D5-3 99 S/G Reactor Trip Instrumentation C/LT-901 C/PT-902 05-4 99 S/G Reactor Trip Instrumentation D/LT-901 D/PT-902 D10-3 99 S/G Reactor Trip Instrumentation D/LT-901 D/PT-902 D10-4 99 S/G Reactor Trip Instrumentation D/LT-904 D/PT-905 DS-7 99 Narrow Range Cont. Sump Instrumentation LT-599 D10-5 99 Narrow Range Cont. Sump Instrumentation LT-600 4

Table 1-3 Penetrations Hodt fied Penetration TER Device (s)

I.D. No. No. System Function Fed C9-1 99 Long Term Core Cooling Control HCV-238 B2-1 99 Long Tenn Core Cooling Control HCV-239 C9-1 99 Long Term Core Cooling Control HCV-240 E9-7/8 99 Long Tenn Core Cooling Control HCV-247 E2-6/7 99 Long Term Core Cooling Control HCV-248 E9-9 99 Long Tenn Core Cooling Control HCV-249 82-1 99 H2 Sampling Control HCV-8208 C9-5 99 H2 Sampli ng Control HCV-820C C9-5 99 H2 Sampling Control HCV-820D C9-5 99 H2 Sampling Control HCV-820E C9-14 99 H2 Sampling Control HCV-820F C9-19 99 H2 Sampling Control HCV-820G C9-19 99 H2 Sampling Control HCV-820H B2-7 99 H2 Sampling Control HCV-821B C9-16 99 Charcoal Filter Spray Control HCV-864 B2-9 99 Charcoal Filter Spray Control HCV-865 B2-11 99 H2 Sampling Control HCV-883C B2-11 99 H2 Sampling Control HCV-883D B2-11 99 H2 Sampling Control HCV-883E B2-11 99 H2 Sampli ng Control HCV-883F B2-11 99 H2 Sampling Control HCV-883G B2-11 99 H2 Sampling Control HCV-883H A4-5 99 Wide Range RCS Pressure Instrumentation PT-105 D5-6 99 Wide Range RCS Pressure Instrumentation PT-115 A4-5 99 HPSI Flow Instrumentation FT-313 A11-3 99 HPSI Flow Instrumentation FT-316 DS-2 99 HPSI Flow Instrumentation FT-319 D10-4 99 HPSI Flow Instrumentation FT-322 A11-5 99 LPSI Flow Instrunentation FT-328 A4-5 99 LPSI Flow Instrumentation FT-330 DS-5 99 LPSI Flow Instrumentation FT-332 D10-1 99 LPSI Flow Instrumentation FT-334 C6-1 99 HPSI Loop Injection 480V Power HCV-311 C9-2 99 HPSI Loop Injection Control C9-15 99 HPSI Loop Injection Space Heater Power E6-1 99 HPSI Loop Injection 480V Power HCV-312 E9-1 99 HPSI Loop Injection Control E9-6 99 HPSI Loop Injection Space Heater Power El-2 99 HPSI Loop Injection 480V Power HCV-314 E2-2 99 HPSI Loop Injection Control E2-6 99 HPSI Loop Injection Space Heater Power B1-2 99 HPSI Loop Injection 480V Power HCV-315 B2-3 99 HPSI loop Injection Control B2-8 99 HPSI Loop Injection Space Heater Power El-1 99 HPSI Loop Injection 480V Power HCV-317

.E2-1 99 HPSI Loop Injection Control E2-6 99 HPSI Loop Injection Space Heater Power I . _ _ _ _ _ _ _ _ _ - _ _ .-

Penetration TER Device (s)

I.D. No. No. System Function Fed B1-1 99 HPSI Loop Injection 480V Power HCV-318 B2-2 99 HPSI Loop Injection Control B2-8 99 HPSI Loop Injection Space Heater Power C6-2 99 HPSI Loop Injection 480V Power HCV-320 C9-3 99 HPSI Loop Injection Control C9-5 99 HPSI Loop Injection Space Heater Power E6-2 99 HPSI Loop Injection 480V Power HCV-321 E9-2 99 HPSI Loop Injection Control E9-6 99 HPSI Loop Injection Space Heater Power C6-2 99 LPSI Loop Injection 480V Power HCV-327 C9-4 99 LPSI Loop Injection Control C9-14 99 LPSI Loop Injection Space Heater Power B1-2 99 LPSI Loop Injection 480V Power HCV-329 B2-4 99 LPSI Loop Injection Control B2-8 99 LPSI Loop Injection Space Heater Power El-2 99 LPSI Loop Injection 480V Power HCV-331 E2-3 99 LPSI Loop Injection Control E2-6 99 LPSI Loop Injection Space Heater Power E6-2 99 LPSI Loop Injection 480V Power HCV-333 E9-3 99 LPSI Loop Injection Control E9-6 - 99 LPSI toop Injection Space Heater Power DS-7 99 Wide Range Cont. Sump Instrumentation LT-387 010-5 99 Wide Range Cont. Sump Instrumentation LT-388 C8-8 99 Waste Disposal Control HCV-545

..t Table 1-4 Complete Function Prior to Failure Caused by Large Break LOCA Penetration TER Device (s)

I.D. No. No. System Function Fed A11-2 99 Pressurizer Pressure Instrumentation A/PT-102 Reactor Trip - ESF Initiation A4-2 99 Pressurizer Pressure Instrumentation B/PT-102 Reactor Trip - ESF Initiation D5-4 99 Pressurizer Pressure Instrumentation C/PT-102 Reactor Trip - ESF Initiation D10-4 99 Pressurizer Pressure Instrumentation D/PT-102 Reactor Trip - ESF Initiation C9-5 33 SI Tank Drain & Fill Control HCV-2916 E2 99 SI Tank Drain & Fill Control HCV-2956 B2-6 99 SI Tank Drain & Fill Control HCV-2936 E9-7 99 SI Tank Drain & Fill Control HCV-2976 E2-5 99 SI Check Leakoff Control PCV-2949

'B2-1 99 - SI Check Leakoff Control PCV-2929 C9-14 99 SI Check Leakoff Control PCV-2909 E9-5 99 SI Check Leakoff Control PCV-2969 B1-1 99 SI Tank Isolation Power HCV-2934 B2-5 99 SI Tank Isolation Control HCV-2934 El-1 99 SI Tank Isolation Power HCV-2954

.E2-4 99 -SI Tank Isolation Control HCV-2954 E6-1 99 SI Tank Isolation Power HCV-2974 E9-4 99 SI Tank Isolation Control HCV-2974 C6-1 99 SI Tank Isolation Power HCV-2914 C9-6 99 SI Tank Isolation Control HCV-2914 C7-6 99 Containment Isolation Power HCV-348 C8-2 99 Containment Isolation Control HCV-348 L-W