ML20154F415

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Environ Qualification Enforcement Conference Rept on 880812. Major Areas Discussed:Concerns About Environ Qualification Continental Cable & Containment high-range Radiation Monitors & Wiring Inside Limitorque motor-operated Valves
ML20154F415
Person / Time
Site: Beaver Valley
Issue date: 09/01/1988
From: Durr J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20154F412 List:
References
EA-88-178, NUDOCS 8809190384
Download: ML20154F415 (50)
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e U.S. NUCLEAR REGULATORY COMMISSION REGION I Meeting No. EA- 88-178 Docket No. 50-334 License No. OPR-66 Licensee: Ouguesne Light Company 4 TIN: Mr. J. O. Sieber, Vice President, Nuclear Group, P.O. Box 4 Beaver Valley Power Station Unit No: 1 Shipping Port PA-15077 Facility Name: Beaver Valley Power Station Unit No: 1 Conference At: NRC Region I, King Of Prussia, Pennsylvania Conference Date: August 12, 1988 w

Approved by: '

1 fQ jg/pff P. Durr, Chief Engineering Branch 9b/f

/ (ate Conference: Environmental Qualification (EQ) enforcement conference held to discuss the significance of concerns about the environmental qualification of continental cable, containment High Range Radiation Monitors and wiring inside Limitorque motor operated valves.

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1. Conference Attendees Duquesne Light Company J. D. Sieber, Vice President, Nuclear Group J. O. Crockett, Gen. Manager, Corporate Nuclear Services K. D. Grada, Manager, Nuclear Safety N. R. Tonet, Manager, Nuclear Engineering F. A. Oberlitner, Equipment Qualification Supervisor W. Laughlin, Senior Engineer Schneider Engineers J. Arener, Manager J. A. Murphy, Vice President D. M. Suhan, Equipment Qualification Engineer NRC J. P. Ourr, Chief, Engineering Branch C. J. Anderson Chief, Plant Systems Section Peter S. Tam, NRR, Project Manager D. F. Limiroth, Project Engineer P. R. Wilson, Reactor Engineer P. H. Bissett, Senior Operations, Engineer T. Koshy, lead Reactor Engineer S. H. Horwitz, Public Affairs
2. Conference Scope The enforcement conference considered the following potential EQ violations Continental Cable (50-334/86-12-1)
  • Containment High Range Radiation Monitor (50-334/86-12-3)
  • Wiring inside Limitorque Motor Operated Valves (50-334/88-21-02)

The scope of the discussions included:

  • Safety significance of each violation, number of deficiencies and number of systems and components affected
  • Specific and underlying cause of each violstion
  • Actions takun or planned to correct the individual violations to ensure overall compliance

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3. Licensec Present.ation The licensee presented their position on the EQ issues of concern. The licensee presentation is outlined in their handout which is provided as Attachment A to this document.
4. Conclusion The NRC staff stated that the lictnsee's information would be corsidered in determinfng appropriate enforcement actions. The licensee will be notified of NRC's proposed actions in the near future.

1 ATTACHMENT A DUQUESNE I,IGitT COMPANT ,

RANDOVT MATERIAL '

4 for NUC12AR REGULATORY C000(154I006 Beaver Valley freer Station Unit 1 '

Riectrical Equipment Qualification L

J FEFORCEMENT CON N i

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August 12, 1988 i 1

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C_0ffrEffl d Introduction

  • Overview of EQ Program Continental Cable Issue
  • Containment High Range Radiation Monitor Issue

' Limitorque Valve Actuator Status

  • Continuing EQ Progrus
  • Summary / Conclusions Appendices A. Overcll DLC Electrical Equipment Qualification Program Synopsis B. Chronological Evolution of Continental Cable Qualification Program l C. Chronological Evolution of Containment High Range Radiation Monitor Qualification Program i

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  • O NRC ENFORCEMENT CONFERENCE August 12, 1988 Introductory Remarks - N. R. Tonet, P.E., Manager Nuclear Engineering Department Nearly ten years have elapsed since the initial NRC Bulletin on Environmental Qualification was issued. Duquesne Light Company has been fully committed and aggressively involved in the implementation of an Environmental Qualification Program that is in compliance with the NRC program identified in 1979 up through today's 10CFR50.49 requirements. Throughout this period we have provided eight responses to the NRC, all of which identify our commitment and continuing effort to upgrade our EQ status through various replacement, testing, analysis and investigative techniques. Ve believe that our approach has been fully consistent with and in recognition of the importance of this topic to the NRC and to the indes ry.

To date, our attention has been focused on safety-related harsh area electrical equipment that is necessary to bring the plant to a safe hot shutdown condition. This necessitated the initiation of a significant number of design changes which are itemized on Table A (SLIDE). Prior to November 30, 1985, 15 major aesign change packages (DCPs) vere implement d as a result of equipment being upgraded to NOREG 0588 Cat. I requirements and to meet NRC regulatory requirements such as NUREG 0737. (SLIDE) DCP 351 alone resulted in replacement of 36 transmitters, 54 limit svitches, 39 solenoid valves, 6 vide ranga RTDs, 2 valve operators, installed 48 conduit seals and il Raychen I splices on instrument circuits required for hot shutdovn.

In addition, significant effort vas placed on qualification testing of I Continental Cable, Harathon and Buchanan terminal blocks, conduit seals, motors, etc.

I (SLIDE) Various consultants have been retained to review our E0 program and supplement DLC staffing. Examples of this include an independent reviev of our 79-01 B submittal by EDS Nuclear, a Continental instrument cable analysis by Eco-Tech, and Design Change support by Stone and Vebster for Unit 1 (Stone and Vebster was also the BV-2 EQ Engineer). Our primary consulting support for Unit I has been 'Nrough the firm of Schneider Engineers, who have sssisted our personnel in ths ,,verall EQ r ogram including pteparation of EQ files, aging assessments, master E0 list development, and training.

From an industry perspective, DLC has been a member of the Nuclear Utility Group on Equipment Qualification, and as a member of EPRI has participated in various E0 and maintenance related seminars. Ve are also represented on the IEEE vorking group 3. 3 on Maintenance Good Practices. Various in-house seminars vere conducted on our E0 program.

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Our Environmental Qualification program is fully comprehensive with

( consideration of equipment aging, maintenance assessment packages to identify EQ requirements, personnel training, qualified spare parts procurement, configuration mar,agement , and procedure reviev as elements of a very strong program. In prior audits by the NRC our program vas recognized as above

( average on a relative basis in the tanner in which it has achieved program compliance. Our recent BV-2 E0 audit resulted in zero findings. It is a program that we all take pride in sharing.

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L Ve have in the past and vill continue in the future to promote upgrades in our equipment and systems as state-of-the-art technology aJvances. This aggressiveness may have been part of our problem with the recent Reg. Guid"

( 1.97 field inspection results which found unidentified viring in Limitorque motor operators. Qualification of the components prior to identifying them on r our master list vould have prevented this issue from arising in the way that it L did.

r Since ve are continuing to work vith the NRC on our compliance to Reg.

[ Guide 1.97, ve vill provide field valkdovns and qualification reviews prior to adding these items to the E0 Master List in the future, f For those few times vhere E0 problems have been identified, our approach L has been thorough and timely in our opinion. The rerults of thir approach is such that after all is said and done with today's problem summary, ve can say r with confidence that the plant is qualified to the best of our knowledge with L those fev exceptions which ve have defined in our E0 inspections and which vill be dispositioned at the next opportunity. (Justification for continued operation have been developed for these exceptions). That is not to say that

" ve are finished, but only to identify that ve have met the intent of our program and that our future plans are in place to continually upgrade equipment, personnel, procedures or training.

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( Statement of Violation

[ Qualification of Continental Silicone Rubber insulated cable not esta-

' blished for operation at elevated (LOCA) temperatures.

Licensee Position Regarding Existence of Violation

( DLC concurs that IR data was not obtained during the 340'F temperature excursion. This is not a significant violation subject to enforcement action under the EQ Enforcement Policy, due to the fact that cable quali-(

fication (functionality) had been established. Therefore, there was no safety significance associated with this item.

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r License Position Regarding Whether Enforcement Action Should Be Taken Under the EQ Enforcement Policy j s neA The two requirements for consideration in accordance with Generic Letter 88-07 deal with safety significance, and "clearly should have known"

( criterion.

DLC maintains that there is no safety significance as it applies to the Continental Wire and Cable (CWC) instrumentation cables at BVPS-1. The r cables are utilized in all class 1E instrumentation circuits within the containment. The qualification files support functionality of the cable at y elevated temperatures. From the original 79-018 submittal DLC was con-L vinced of the cables functionality at all temperatures due to the original vendor test. All retest results confirmed the qualification status.

[ Original qualification was established using IR readings taken after the post-LOCA temperature spike coupled with functionality testing that enveloped OLC's MSLB conditions.

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The question of "clearly should have known" does not apply tc the questions

{ of IR readings at MSLB temperatures fo- the CWC. In response to IE Bulletin 79-01B OLC noted to the hRC that Franklin Institute Research

Laboratory report F-C2936 did not envelope the BVPS-1 postulated chemical spray composition and post accident radiation values inside the cranewall of the containment. In the 79-01B submittal DLC comitted to re-testing the cable to satisfy the radiation and chemical spray issues or replacement based on the results of the re-test. The comments from the NRC in TER C5257-490 dated September 10, 1982 for the Continental Wire and Cable, included the tw. coments that the provided Franklin test report did not envelope the required radiation and chemical spray. The NRC added that preaging performed had not beea evaluated to determine the lualified life of the cable. The TER of September,1982 and the corresponding SER of December, 1982 raised no questions of operability or cable functionality in class 1E instrumentation loops. To meet the commitments made to re-test in the submittal, a test was conducted. Prior to the re-test DLC had evaluated the impact of a MSLB inside containment. Due to the increase in temperature peak and the absence of any chle operability concerns by DLC.

or the NRC; the re-test consisted of a test run at the higher MS. B .

temperature with the cable functionality being monitored continuously (voltage and current). This re-test was completed in August, 1984.

ihe NRC via IE Notice 84-47, June 15, 1984 notified the industry of testing performed at Sandia National Lab on terminal blocks under accider.t simu-lation. The Sandia Report was issued September,1984 as NUREG/CR 3691.

DLC had completed the re-test previous to this report and therefore replaced terminal blocks in class 1E instrumentation circuits within the containment with qualified splices in December, 1984.

Prior to the issuance of NUREG/CR 3691, DLC and the industry were convinced the primary contributor to instrument loop inaccuracies was the sensors themselves. These concerns were addressed in the qualification testing of the sensing devices. Upon receipt of the Sandia results, terminal blocks

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identified as a significant contributor to instrument loop inac-were

[ curacies. DLC responded to these results by eliminating terminal blocks in the class 1E instrumentation loops within the containment. These circuits r were wslked down to assure the proper application of the splicing L materials.

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The program of 10CFR50.49 audits were comenced in late 1984. The results

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of these and audits performed in 1985 indicated that more focus on instru-

[ ment loop accuracies was required. OLC re-investigated their positions on this topic in a couple of methods. Wyle Labs were contacted to determine the precision of the test components utilized during the re-test in an attempt to calculate maximum leakage currents during the MSLB simulation.

Wyle was unable to provide data that would allow the calculations to be

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OLC committed to utilizing analytical methods coupled to the available test

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data to demonstrate minimal error contribution of the cable system to the instrument loop. To accomplish this OLC utilized testing performed on other SR insulated cables that had been qualified to utilize IR readings taken at the MSLB temperature excursions. The IR results were consistent

" within the same order of magnitude and therefore DLC concluded the CWC would continue to demonstrate in an acceptable manner at the MSLB temper-7 L atures. These results were discussed with the NRC during the audit and also submitted in written form post-audit.

Following the June,1986 audit, OLC comissioned a broader study of SR insulated cable IR readings at elevated temperatures. This review con-

[ cluded SR insulated cable would have IR readings in the same order of p magnitude at MSLB temperatures.

L g The recording of cable IR readings during the MSLB peak temperature has E been an evolving process which OLC has ' addressed through its various stages. The brief period of time the cable is exposed to the MSLB peak L temperature coupled with the thermal inertia of the insulation balanced with the IR trends of SR ir,ulated cable as a family fully supports OLC's contention that the CWC provided to BVPS-1 is fully qualified and offers no

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significant safety concern. Throughout the various submittals and reviews (TER, SER) no coments were aired as to cable accuracy or a doubt as to the cable's ability to perform its safety function, u

( Other Considerations F DLC did report test 6eficiencies to the NRC with its79-018 submittals.

L OLC, based on their admission of testing deficiencies in chemical spray composition, and radiation exposure that did not envelope inside cranewall conditions retested the cable. As instrument loop concerns became known during 1984 and 1985 DLC continued to respond to these concerns. OLC has L an inplace EQ program that continues to review their position to issues as the industry is made aware of them (i.e., IEEE Standards Comittees, NUGEG,

[ Industry Advisors). OLC's measure of commitment to a dynamic EQ program is evidenced in the most recent testing performed on CWC. OLC was able to

[ locate surplus cable thac was procured and delivered with the original cable to remo"e any ocubt of similar ity to the installed instrumentation r cable. The testing performed on this original cable had IR readings 1

" were recorded during the MSLB peak. This data supports earlier silicone rubber material similarity analyses.

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DLC did respond to each parameter in the evolution of instr ument loop

[ accuracies as impacted by accident service and will continue to do so.

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Status 7 The installation of CWC SR insulated instrumentation cable at BVPS-1 is qualified.

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Statement of Violation Qualification of containment high range radiation monitor cable arrangement not established. Replaced with mineral insulated cable and qualified I coaxial containment penetration on February 20, 1988 and installed new containment electrical penetration. This is limited to the two HRRMs in containment, Licensee Position Regarding Existence of Violation The timing of the implementation deadline date for the post TMI modifi-cations and outage schedule of BVPS-1 caused the containment HRRM to be installed with a qualified containment penetration module consisting of a shielded, twisted instrumentation cable. OLC was unable to secure a qualifiable coaxial cable penetration during the outage window. The I existence of 60 inches of the twisted pair at the penetration was not considered to invalidate the operation of the HRRM system. The HHRH provides indication of radiation field densit; through eight orders of magnitude. The intent of the modification and the design of the device does not allow a precise reading to be taken due to the low level signal.

Licensee Position Regarding Whether Enforcement Action Should Be Taken Under The E0 Enforcement Policy DLC contends there is no significant safety violation in that the HRRM system configuration would have provided a relative indication of the radiation fiald during accident scenarios. The device would tend to read artificially high (> 10E6 rads) at the elevated temperatures associated l with LOCA or MSLB. The HRRM system providec '

.ull range capabilities in one device, but it is not solely relied upon by the operator to 'ictate plant recovery actions in the E0Ps. DLC was aware of the lack of precision of the detector but was also being responsive to the TM1 modifications deadlines with the technology and knowledge available in 1981.

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In addressing "clearly should have known" considerations DLC was awire of the difficulties to integrate the Victoreen HRRM into a complete s,/ stem.

Victoreen in their qualification test report had considerable difficulties wi.5 the coaxial cable interface. Other utilities experienced cabling I problems with coax cables, in particular moisture intrusion. DLC believed their installation of a segment of twisted pair cable did not shadow the operability of the installation to any greater extent than existed in the industry. During the time table pre-November, 1985 the industry was actively qualifying components, with the understanding that a collection of qualified components had a high probability of translating into a qualified system. The topic of total instrument loop accuracy was evolving during late 1984 and 1985. However, the qualified cabling available in that time period was unable to transmit the extremely low (10E-11 to 10E-6 aaps)

I signals concurrent with a simulated accident. In May, 1983, in responsu to the NRC EQ rulemaking, DLC submitted a revised EEQML listing the Victoieen HRRM.

Other Considerations DLC was aware of the technology problems of being able to ascertain sn unamplified pico ampere signal with conventional cabling during postulated accident scenarios. This problem is generic to the nuclear industry.

Continucus coaxial cable wH the preferred installation method, but the IR readings still left doubt ii to the reliability of being able to detect the I low signal levels. The various coaxial cables did not have a high success ratio during testing when the cables interfaced with a connector. The more vulnerable connector shell to cable cuter jacket interface usually allowed moisture intrusion which caused signal degradation. DLC considered their installation on a par with the industry. Other utilities and the NRC recognized the inability to obsain precise containment radiation readings using components and cable that was available.

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O I NUREG/CR 4728, February, 1988, reports the results of Sandia tests for synergistic effects of MSLB temperature combined with heat produced during exposure to radiation of a HRRM. Sandia concluded the detector passed the testing and the test anomalies observed were due to cabling and connector I problems. This reinforces the contention that the existing technology continues to experience problems with low level signal transmission during I simulated accident conditions.

Status DLC has installed a fully qualified cabling and containment penetration modification to enhance the HRRM system. The key f actors which increase reliability of this detection system are listed below:

g The Victoreen sponsored testing monitored a system status light during the E MSLB/LOCA simulation. The data tapes were lost in transit and therefore, the ability of the monitor to detect radiation with a measure of repeat-ability during a DBE cannot be assessed. DLC utilized testing on an identical monitor for another utility to demonstrate the ability to sense rediation during a DBE, This was accomplished by exposing the monitor to a known source during the DBE simulation and monitoring the output of the device.

DLC chose to investigate alternate cabling methnds other than a vapor-proof I raceway system. Utilizing an A-E to coordinate the research, design, and acceptance tescing, DLC has completed the installation of a hermetically sealed, stainiens steel sheathed, mineral-insulated triaxial cable. An additional benefit is only the connection to the Victoreen detector is exposed to the DBE environment. The second cable interface is in the cable vault exterior to the containment. DLC feeis this is a significant improvement in system configuration from the conventional installations.

The installation was installed in an expedient manner considering the magnitude of development, testing, engineering, procurement, and necessary construction labor for the DCP.

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( MAT-JUNE 1988 ACTIVITIES THE VIRE NUT ISSUE

Background

( On May 11, 1988 an NRC inspector found en U9 analysed vire nut instelled to MOV-SI-885B vhile inspecting H0V's equipped with dtral voltage mot 4r.? to determine the type of connectors used to splice moior vinding 1 cads. It L is believed that most dual voltage HOV's vtre equipped with Thomas & Betts (T & B) crimp type connectors. These have been separately tested by another utility and are being accepted by the NRC vhere the8r presence can r be confirmed. The vire nut found in MOV-SI-885B had not been similarly L tested and was not considered acceptable.

cause The vire nut in MOV-SI-885B had been installed by DLC maintenance under HVR 875974 on April 11, 1987 after a motor lead was smashed during the p Hini Outage EQ inspection. Vire nuts were also installed in NOV-SI-864A L during a mc. tor replacement under MVR 871661, Jan. 6, 1988.

, Corrective Action b

All of the vite nuts vere replaced with qualified Rayci.en splices. A reviev of MVR's did not indicate any other suspect repairs. In addition, 37 other N9V's equipped with dual voltage motora vere inspected between May 11, 1988 and June 11, 1988 and all af them had the approved T & B connectors installed.

F L Current Status

- Four MOV'a with dual voltage motors inside the containment have not been

{ inspected for vinding lead connectors.

Maintenance supervisors have been instructed to oerform a timely pos:

I maintenance review of EQ MVR's prior te turning the equipment over to OPS L to assure equipment has been properly repaired and restored to a qus11fied condition. In addition, we have committed to perform addit 19nal EQ

- training and to review our .aa in t enanc e precedures to assure that similar L problems do not reccur.

UNOR 88-47 vas issued on this topic which determined that it was not

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reportable based on 8700-JPO-(88-47) which was submitted to the NRC en May 20, 1988.

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INCOMPLETE REC. CUIDE 1.97 INSPECTIONS Background '_

On Hay 12, 1988 an URC inspector found an unloentifiable vire jumper in H0V-RV-105D vhile inspecting for motor vinding lead connectors. The question of unqualified vires was originally raised by IEIN 85-03 and was the subject of previous f ospections catried out under EH's 30056, s"0543, Gr.d 73602, as noted above. H0V-RV-1050 vas one of 31 MOV's added to the EEQHL to satisfy the requirements of Reg. Guide 1.97 and was listed on EH 73002 as requiring inspection.

Cause EH 73602 vas entitled "6R -

Limitorque Inspections" but was not explicit as to when the inspections had to be complete. Due to outage scheduling constraints only the five H0V's inside the containment vere inspected --

during 6-R including four Reg. Guide 1.97 E0 inspections and one terminal block inspection. The EEQML vas subsequently revised to add all 31 Rog.

Guide 1.97 HOV's vith the result that 27 uninspected H0V's appeared on the list.

Cot rective Action H0V-RV-105D vas reworked via MVR 882833. Inspection of the remaining EH 73602 H0V's was conducted between May 12 and June 11, 1988 during which 17 vere reworked, 6 vere found to have satisfactory vire auC 3 remain to be reworked as noted below.

Current Status Tr.ree H0V's which vere found to contair, unanalysed virs have not been reworked due to operational constraints, H0V-CH-308A, B. C. Ve submitted 8700-JCO-(68,*8; for there H0V's to the NBC on hay 20, 1988 along with a JC0 for MOV-FV-15fA, B, C which vere subsequently reworked. Ve submitted 8700-JCO-(88-48) on May 20, 1988 for H0V-RV-105D and the remaining EH 73602 MOV's which vere reworked. Ve ars also rqviewing our procedures regarding additions to the EE0HL to assure that all 3quipment listed is in a qualified condition prior to being included on the IIst.

UN0R 88-48 has been issued ca this topic vhich determined that it was not reportable,

l REINSPECTION OF PREVIOUSLT INSPECfEh HOV'S

, Background 1

L On Juae 6, 1988, while performing inspections of NOV's with dual voltage motors, unanalysed jumper vir63 vere f o'and in five HOV's that vere among '

the oelginal 42 h0V's on the EEQML and hed been inspected imder EN 63506 during 5-R.

7 Ve conducted c review of both the EH 63506 and EM 63456 L inspection activitiec to determine whether any more of them might also be suspect. The results of this review indicated that, in addition to the 5 MOV's noted above, 13 other HOV's merited reinspection. Twenty-four HOV's

{ trere determined not to requite reinspection for the following reasons

, 1. Inspection records and wire specimens remaed during earlier EQ inspections indicated proper revor;k (11 H0V's).

2. M0V's vere inspected for dual voltage motor connectors in June 1988 during which jumper vires vere riso being er-mined (4 H0V's).
3. Viring vas reinspected during inspection of field viring in Juno, 1988 (4 MOV's).

r L 4 Viring had been inspected during the BVP3-1 E0 audit and was found acceptable (2 M0V's).

5. H0V-SI-865A, B, C vere removed from the EEQML in June, 1988 (3 MOV's).

[ Cause

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i It turned out that each of the 5 deficient and 13 suspect H0V's had been inspected during 5-R under EM 30506 which vas the very first r'.und of MOV L EQ inspection activities. Interviews with persons involved in those inspections inoicated that, although the inspection checklist did not make such a distinction, it was interpreted to apply only to "vendor supplied" L jumper vires. It appears that they did not fully understand the scope of the inspection and thus excaip t ed certain vires from scrutiny. Persons performing subsequent inspectinns did not make this distinction resulting

[ in the proper replacement of any jumper vire that was not iden'.ified as W qualified, r Corrcctive Action I Between June 9 and June 11, 1988 vira in 'he 5 deficient HOV's vere

- replaced with qualified vire. The 13 suspect HOV's vere inspected vi S the result that 11 vere reworked and 2 vere found to be acceptable.

Current Status

' 8700-JP0-(88-57) vas prepared on this topic and UONR 88-57 vas issued which determined that it was not reportable.

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REINSPECTION OF iREVIOUSLT INSPECTED HOV'S (CONT'D)

FUTVRE ACTIONS A task force has been estabtished consisting of represcatatives from Maintenance, QC, e.nd NERU tb reviev existing programs and procedures affecting EQ N0V's. Topics urider reviev include

1. Procurement and stncling of spare parts.
2. Maintenance procedutes.
3. EEC:1L additions and deletions.
4. Training.
5. Post maintivance review of MRV's.
6. Development et a configuration control matrix for H0V's.

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TRAINING STATUS b

k. TRAINING FOR MAINTENANCE CRAFT AND SUPERVISION - THE HAS BEEN PREPARED AND HAS BEEN DISTRIBUTED FOR FINAL y

[ COMMENTS. TRAINING SE3SIONS HAVE BEEN 3CHEDULED AS FOLLONS: UNIT 1 - AUGUST 25, 1988 r UNIT 2 - AUGUST 16, 1988 L

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.. PROCEDURE RT/IEN - THE PROCEDURE REVIEN IS IN PROGRESS u AND NILL BE CO@LE'1ED BY AUGUST 31, 1988.

. INCREASED SUPMRVISORY BZVIEN OF MeiR' S - THIS NAS IMPLEMENTED VIA MEMO DATED MRY 20, 1938,

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. EQ TRAINING OF EQ INSPECTOPS SCHEDULED FOR (

AUGUST 17, 18, 1988.

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C1 7 A SHOWN FOFi MOV-S!664A r SIMILAR FOR yt Ug SIMILAR FOR 1 o MCV-SIB 648 --42 - 42-- MOV-S18649 TOPEN --1

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SEE TABLE'D -O C-[ SEE TABLE'q o ,

l DET.'M' ,

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Ei!~E 7 O C l-~"~:

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~_ J1109 5 "l' 4 DE T'8 35A /-42 5]23g 3

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$ 99 - -

5 7 C J1109-4Q 0 i ~ t-~' 99 EV 1 J1109-6 5 E i~ 6T

/(4 2g Q 7~ , a l Li 32 g W CMPTR CMPTR 4

C i ~ h M7 CMPTR CMPTR L

PV S SPDS I i (Y6962D)(YD6962) t49 SPDS PVS ND6961)(Y6961D)

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gTYPICAL BV-1 MOTOR-OPERATED VALVE ELEMENTARY DIA.

I I

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[

TYPICAL BV-l LMS AT MOV WIRING DIAG.

I --  ;, - W - E5VO i

[ ' R-E5VR ROTOR *1 ROTOR *2 I '- B - E 5VXI 4 4, ._

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L a (VALVE SHOWN IN OPEN POSITION)

F

)

u

Current status of Program

(

F A task force was established after the recent Limitorque (May, 1988) issues L

consisting of representatives from engineering, maintenance, and quality control. Topics being reviewed by this task force:

1. Procurement and stocking of Spare Darts.
2. Review of Mainterance Procedures.
3. When equipment is added to the EEQML.
4. Training of maintenance, quality control and engineering.
5. Post maintenance reviews of MWR's.

l S. Engineering review of MWR's.

7. Development of configuration control matrix for MOV's.

F L Re:ent Q/A audits of BV-1 and BV-2 have revealed no major deficiencies with minor observations noted. The BV-1 audit identifies the need for better L documenting the training of craf t personnel to do Raychem Splices. In response to this finding, Raychem has recently conducted training for OLCo

[ inscructors to train craft personnel in order to c!ocument training completed, r

l

^

As a result of the BV-2 NRC audit, 'nspector Report No. 50-412/88200, OLCo

- has recently submitted procedure change ;equest to clarify EQ categories,

' completed the Q/A audit of the BV-2 EQ program, and scheduled training for

- Q/C inspectors (August 17,10,1988),

L A OCP has been initiated to replace the Gama Metrics junction box "0" ring L during the BV-2 first refueling cutage. The BV-2 maintenance asses: ment package (MAP) has been revised to cover inspecting a permanent sample of 10 operators every outage and a different set of 20 each outage. Accepthnce

[ criteria for surveillance tests is being reviewed. BV-1 is replacing f approximataly 16 Barton Transmitters during the 7th Refueling Outage since they ore approaching 10 years of service.

{

( Since 1985, eight design changes have been implemented related to equipn.nt upgrades. These include Reg. Guide 1.97 transmitters, MCC transformers.

Hydrogen recombiners, inadequate core cooling and installation of Conax

[ containment penetrations and Mineral Insulated cable for the BV-1 high p range radiation monitors.

L DLCo is continuing to take an active position with respect to EQ with the 7

L highest priority being safety.

r L

r L

u L

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L F

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f hQRELATEDDESIGN CAPITAL bHANGES AFTER 1985 COSTS c

f

$ 415,551 fCP-514-REPLACEOBSOLETETRANSMITTERS l

CP-564 - MCC CONTROL TRANSMITTERS $ 127,939 L

RECOMBINER $2,212,826 CP-621 - H2 1

$ 58,344 (CP-643-CONTAINMENTSUMPLEVELTRANSMITTER 1

CP-668 - INADEQUATE CORE COOLING OGM L

CP-690 - HI-TEMP MIRE REPLACEMENT $4,091,847 CP-800 - RM 219A, 2195 PENETRATION REPLACEMENT $ 681,438 CP-818 - ITT BARTON TRANSMITTER SUPPORTS O&M c

[ $7,587,945

s CONCLUSIONS In summary, DLCo believes the qualification of the Continental cable vas established prior to November 30, 1985 based upon IR readings taken betveen 200-150'F coupled with functionality testing that enveloped Boaver Valley Unit l's HSLB conditions. DLCo reported deficiencies of the original Franklin testing in the 79-01B submittal which resulted in a retest of the cable in 1984. Responding to NRC concerns of Insulation Resistance, DLCo commissioned an analysis be performed and retested the cable in 1987. The analysis and retest confirmed DLCo's position, the cable has alvays been qualified.

Performance data vas in the file as of November 30, 1985 based upon IR readings taken after the Post-LOCA spike coupled with functionality testing that enveloped DLCo's MSLB conditions.

I DLCo considers the qualification of the high range radiation monitoring systea to be as qualified as technology permitted as of November 30, 1985.

Vith D1;o's configuration any leakage current at the splice interface vould have had a positive effect on the output reading of the monitor, thus any error vould be conservative. As technology developed, DLCo took action in 1986 to replace the original cable configuration with a qualified mineral insulated cable with one connection inside containment. This configuration is qualified and is a significant improvement over conventional systems.

DLCo vill continue to take an active position with respect to EQ and vill take into account nev information and practices as the EQ arena continues to evolve.

I APPENDIX A Overall DLC Electrical Equipment Qualification Program Synopsis Summary of NRC Reporting

  • Summary of Previous Actions f

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l EQUIPMENT QUALIFICATION PROGRAM r

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L UMMARY OF NRC REPORTING l FOR BV-1 INITIAL 79-01B SUBMITTAL - DEC. 31, 1980 AMENDHENT 1 79-01B SUBMITTAL - OCT. 15, 1981 30 DAY RESPONSE 1982 NRC SER - JAN. 27, 1983 Lo 90 DAY RESPONSE 1982 NRC SER - MAR. 27, 1983 NRC OVERVIEW MEETING IN BETHESDA +- AP R . 5, 1984 (o

~o NRC DETAILED EQ AUDIT AT BVPS-1 - JUNE. 1986 s

-o NRC 1986 AUDIT ASSESSMENT /CLOSE-OUT - MAY. 1988 NRC EQ ENFORCEMENT CONFERENCE AUG 12, 1988 L

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BVPS-1 EQUIPMENT QUALIFICATION PROGRAM i

. . ~ ,=-

i ITEMS REPLACED;_

!l FISCHER S FORTER TRANSHITTER I GEWS LEVEL TRANSMITTERS lI

!I WASON-NEILAN LEVEL TRANSMITTER SOSTMA,W RTD' S UNHOLTT.-DICKIE CHARGE - AMP FLOW DETECTORS NAMCO 2400X LIMIT SWITCHES Il l g TRINITY RTD'S  :

ASCC HP-8320 SOLENOID VALVES l

ASCO LB-831654 SOLENOID VALVES '

I ASCO LB 31924 SOLENOID VALVES I f I  ;

i i

I  !

l BVPS-1 EQUIPMENT QUALli~ J:.aTION PROGRAM E

I ITEMS RETESTED:

I VIKING PENETRATION BUCHANAN TERMINAL BLOCK CONTINENTAL CABLE I

g ITEMS TESTEDL kAYCHEM SEALING KIT RAYCHEM CABLE INSULAT"ON REPAIR KIT ,

CROUSE HIND 3 CONDUIT SEAL FITTING l RAYCHEM CABLE SLEEVES I ITEM ANALYSED:

LOUIS ALLIS MOTOR I

j EQ RELATED DESIGN CHANGE CAPITAL PACKAGES PRIOR TO 1985 COSTS

[

DCP-180 - Diesel Gen. Circuit Sequencing OEM

(

DCP-204 - Uninterruptible Power Supply OEM r

L Systems

' DCP-248 - Feedwater Control Valve OEM Modification r

DCP-292 - Acoustical Valve Monitoring $ 180,334 DCP-293 - Subcooling Monitoring System OEM j

DCP-294 - Hydrogen Monitoring System $ 3,861,297 DCP-295 - Reactor Coolant Gas Vent $ 2,293,737 r

- DCP-297 - Containment Pressure Monitoring  ?

DCP-298 - Sump Level Indication System OsM

- DCP-303 - Radiation Monitoring System O&M DCP-320 - Post Accident Sampling System $ 6,042,094 DCP-333 - heactor Vessel Level $11,256,174 J Indicating System DCP-337 - Diesel Gen. 1& 2 Auto Load Or.M

~

Seq. Timers DCP-351 - Replacement of Qualified $ 6,881 s

L EquiP ment r DCP-408 - Automatic Isolation of $ 6,398,085 L Auxilic.ry Steam & St.am Generator Blowdown Valves Min. $36,903,327

- - _ _ - - - _ ~ _ _ _ . _ __ _ _ _ ._ _ ___.____ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ ___ _

[

OUTSIDE SUPPORT L

b

[ ORGANIZATION PROGRAM

[

Ecotech _e Continental Cable Material Traceability Analysis EDS Nuclear e Independent Review of

[ (Now Impell 79-01B Program Corp.) e Motor Analysis r

Forwell and Hendricks e Equipment Testing Schneider Engineers e EQ Files e EQ Training e Aging Assessments e Maintenance Assessment

~

Packages Stone & Webster e 79-01B Submittal Engineering Corp. e Test Plan

- e NUREG 737 Equipment Wyle Laboratories e Equipment Testing L

Wootinghouse o 79-OiB Submittal e Motor Aging Assessment

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APPENDIX B r

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Chronological Evolution of Continental Cable Qualification Program Status

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Continental Cable Environmental Qualification Program Nuclear Industry Time Frame OLC Qualification Activity Evolution

! 1970 Original Continental Cable Test at Initial type testing conducted Freklin Research Center F C2935. concurrent with the development C' les were continuously energized of IEEE-323, 1971.

th 600V,12 to 14 amperes applied oJring preconditionir;, steam expo- IEEE-383, 1974 basically stated

,ure, and post LOCA periods. Di- that the cable should pass a electric measurements made after 5-minute voltage withstand approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> following the test underwater following high temperature peak test. It was radiation exposure, operated concluded that leakage currents did under rated voltage and load not reveal any breakdown of the while simultaneously exposed to insulation. LOCA conditions within the specified electrical param-eters, and pass a voltage withstand test under water for the post-LOCA simulation test.

1978 Initial response to IE Bulletin Qualification testing pro-78-08 (May 31, 1978) progran grams well underway in NT0L identified Continental Cable. plants, with a few licensed

- to meet IEEE-323-1974 1979 Response to IE Bulletin 79-01 (Feb. 8, 1979) program and 00R Guidelines included the preparation of SCEW sheets.

~

1980 o First detailed submittal to NRC of 00R Guidelines in Section

- the cable's qualification status as 5.2.5 state that components a result of the NRC's IE Bulletin should be nonnally energized 79-018 (January 14, 1980) and during the tests and should CLI-80-21 (May 23, 1980 - 00R & be representative of actual operating conditions. Failure NUREG 0588). IE Bulletin 79-01B

- included the 00R Guidelines and criteria should include NUREG 0588. instrument accuracy require-

[ ments based on the maximum error assumed in the plant safety analysis

[

~

2103.1.7/200CM1 1

t Continental Cable Environmental Qualification Program Nuclear Industry Time Frame DLC Qualification Activity Evolution o DLC prepared detailed qualifica-p tion file on the cable, addressing

[

qualification testing and ability to satisfy NRC requirements. A SCEW sheet checklist and status

[

worktheet were transmitted to the

- NRC as summary information as part of the formal submittal required r by the NRC of all harsh area equip-L ment requiring environmental quali-fication. This DLC submittal

~

pointed out that the chemical i spray and radiation testing per-formed in 1970 on the Continental Cable had not completely enveloped

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the BVPS-1 plant's service condi-

- tions and that OLC was in the process of determining if further

- qualification testing was appro-priate.

~

o A meeting was held in Bethesda

~

with the NRC resulting with the requirement that additional infor-

~

mation would be provided by DLC.

- This additional information in the form of a revised transmittal was

- sent to the NRC on Dec. 31, 1980.

- 1981 o NRC issued Safety Evaluation Report (TER) (.'une 23,1981).

~

o OLC transm ttal (October 15,1981) i

- a response to the TER along with a complete revision to the previous IE 79-01B transmittal.

1982 o NRC issued Safety Evaluation Report r

(December 16,1988)

L 2103.1.7/2000M1 2

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Continental Cable Environmental Qualification Program Nuclear Industry Time Frame DLC Qualification Activity Evolution 1982 DLC responded to the NRC's Technical Evaluation Report addressing concerns

[ related to chemical spray and radi-ation. The evaluation was based on the 284*F North Anna temperature

( profile and as depicted by Attach-ment 1 the NRC review of the cable denoted no deficiency with the

[ following test sequence or with cable functionality:

Irradiation

[

- Temperature / Humidity Test

- LOCA Simulation

- Megger and Dielectric Test

{

where it was clear that the dielec-tric was measured after the peak

[ LOCA temperature simulations. As a result of this NRC assessment.

DLC had made the decision to retest the cable to address only the two

{ qualification areas of radiation and chemical spray.

o DLC, based on its understanding

- of the 00R Guidelines require-L ments, as well as the findings of the NRC TER Continental cable assessment, understood

[ functional testing and accuracy to be focused on instruments per se and did not address p insulation resistance accordingly.

L 1983 &

[ 1984 Continued conducting e.1gineering review of file contentt and test report. Acknowledged that the test had to envelope a newly-defined MSLB

{ temperature profile of 350'F for BVPS-1 as well as satisfy the plant's p service condition for the radiation L- and chemical spray parameters.

f Continental Cable Environmental Qualification Program I

l Nuclear Industry t Time Frame DLC Qualification Activity Evolution

[

August 1985 Perfonned a successful test of

( Continental Cable at Wyle Laboratory to address the radiation and chemi-

[

cal spray concerns. Prepared summary L statement for file and completed assessment of Continental Cable

location. Insulation resistance readings at the peak temperature conditions were not taken during this test because the know" focus

[ to DLC at that time relative to cable performance was insulation breakdown and the cable's tested insulation resistance readings L from the 1970 Franklin test were considered to be of an exception-

- ally high amount, 53 Mohms, to preclude any concern, even though the IR readings were taken after its initial temperature spike. For the cable insulation to have been

~

unqualified for its use in instru-ment circuits at BVPS-1 would mean that the insulation resistance would have had to increase from less than 1 Mohm to 53 Mohms in a rela-

- tively short time frame as the temper ature dropped from 340*F to 150'F. NRC detailed EQ Inspection This large of a swing was considered Audit Program focused en by DLC to be highly unlikely and was, need to have insulation

~

therefore, qualified as a result of resistance data available

- the initial testing and the follow- especially for instrumenta-up testing. During the accident tion cable.

simulation testing, the cable's

_ current was measured and was to remain within specified level at an

- applied voltage level.

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W 2103.1.7/2000M1 4

O Continental Cable Environmental Oualification Program Nuclear Industry Time Frame JLC Qualification Activity Evolution June 1986 NRC detailed audit of BVPS-1 I environmental qualification program raised the question of lack of cable insulation resistance readings not being available during the MSLB temperature peak period.

OLC commented that the I Continental cable's silicone rubber insulation had very good physical characteristics (including insulation resistance) in high temperature environments as referenced by other quoted testing conducted on silicone I rubber. DLC continued to take the position that the Continental cable was qualified and cocinitted to determine if further analysis could provide the appropriate linkage *.o other I testing of similar silicone rubber compounds.

1987 DLC addressed the cable insula-tion resistance issue that was raised during the 1986 audit by retesting again the Continental E cable. The insulation resis l tance measured had a minimum I value of 6.6 E6 ohms during the two high temperature dwells, test connection anomalies not withstanding.

I I

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! I 2103.1.7/2000M1 5

4.Lj Frankhn Re earen Centcr NRC Contract No. NRC-03 79-118 FRC Project No. C5257 Page 4 c,v.s.on a F+aa.an lescssie FAC Assignment N .13 5b r,em a9 he Snesis PNa . Ps 19103 (215) 448-10no FRC Task No. f 2)

EQUIPMENT ENVIRONMENTAL QUALIFICATION REVIEW OF EQUIPMENT ITEM NO. 22-DEFICIENCY I HRC REQUIRDtENTS WITH SECTICH REFERENCE (dor /0 5 8 8-I/0 5 a s-II)

LICENSEE SUBMITTAL QUALIFICATICH DCCUMENTATICH (X OR NOTE SC.)

Acceptance criteria  !  !  !

/ Not Stated g

( 5. 2. 5/ 2. 2.1/ 2. 2.1) !8/

Accuracy ( 5. 2. 5/-/-) Not Applicable Numoet of Specimens  !  !  !

. . 2- .

Test Instruments Calibrated . j .g Saf ety Funceton ( Active /  !  !

! .I 15 Applicable g Passive) (-/ 2.1. 3/ 2.1. 3 )  !  !.

Te st Duration (5.2.1/-/-) / 32 Hours Accident Duration (Envir. j p,, g q h .fNot Applicable Above Normal) (5.2.1/-/-) .

Required Fanction Time  ! 4gg . Not Applicable Test Sequence (General)  !  !  !

V/ Irradiation  ;

I k ( 5. 2. 3/ 2. 'J .1/ 2. 3.1)  !. //,h  !

. Temperature / Humidity Test i er n actric Test a I - 3 1/

1. Representative Sample  !  !  !
2. Baseline Data  !  !  !
3. Performance Extremes  !  !  !
4. Tner:nal Aging  !  !  !

F  !

5. Radiation Aging  !  !
6. Wear Ag tng  !  !  !
7. Vibration / Seismic  !  !
8. DBE Exposure
9. Post-DBE Exposure  !  !  !
10. I.aspection  !  !  !

Aging (5.2.4, 7.0/4.0/4.0)

Ther:nal Aging / Basis

![A

! 151*T, 100%RH/ 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> f [

Ma te rial Ag inq Evaluation (7.0/-/-)

! Not Stated M/

Materials Susceptible  !  !

Not Stated (The r:nal) (5.2.4, 7.0/-/-)  ! d7  !  !

i  ! '

Radiat ton Ag ing , Type  ! M Not Stated '

o ATTACHMENT 1

3.

I I

APPENDIX C l

Chronological Evolution of l Victoreen Containment liigh Range l Radiation Monitor Qualification Program Status l

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1 - - . - _ _ _ - _. . _ ________ - _ - - - _ _ _ - . . . _ . - _ _ -

Victoreen Radiation Monitor Qualification Program I

Nuclear Industry Time Frame DLC Qualification Activity Evolution NUREG 737 TIM action item, containment high range radiation monitor system, was required to be installed by 1/1/82.

Regulatory Guide 1.97, Rev. 2 permitted the high range I radiation monitor to be within a factor of 2 of any given reading.

1980 High range radiation monitor procurement specification prepared by OLC. Victoreen qualification testing was underway.

1981 Purchase order issued. Quali-fication testing completed but report was not irrmediately I issued. System designers were concentrating on potential noise and capacitive inter-ference.

1982 Radiation detector system installed. Manufacturer's I manual specified t 36% of input radiation system accuracy accumulative at meter and 28%

of input radiation system accuracy analog output.

Decision to install a majority of the cable as coax wire and I utilize an existing instrument penetration was made.

1983 Victoreen qualification test report was made available. OLC Evaluators recognized that the unit was subjected to harsh service conditions but did not monitor a radiation source simultaneously.

1984 Testing completed for an identical unit at Indian Point 2 qualified I the radiation monitor for harsh service condition while actually 2103.1.7/2000M1

g. -

Victoreen Radiation Monitor Qualification Program Nuclear Industry I Time Frame DLC Qualification Activity Evolution 1985 DLC evaluated the high range I radiation monitor for revised MSLB peak temperature.

1986 NRC EQ audit raised the issue of potentially high leakage current existing during design basis event conditions where I the twisted shielded pair cable was installed. DLC believed that the shielded twisted pair I arrangement was not a signifi-cant concern because its length of run of previously tested Brand Rex cable was relatively I short and that coaxial cables had indeed been installed for almost all of the cable run l inside the containment. Separate DLC EQ files had qualified the Brand Rex instrument cable, the I Viking penetration, and the Raychem splice. At this point in time, DLC was convinced that the components in the as-config-I ured system were similar enough to what had been qualified to represent a qualified radiation I monitor system, however, the amount of inaccuracy that could be incurred was not appropriately addressed.

DLC decided to install mineral insulated triaxial cable from I the radiation monitor on through the electrical penetration to improve the system's reliability I and accuracy.

1988 Mineral insulated triaxial cable I system installation was completed during the sixth refueling outage.

I 2103.1.7/2000M1

7 D

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safety Persooctive - Himh Ranne Radiation Monitors The qualification deficiency of the BV1 HRRM would have caused the monitors to respond up-scale to a HELB regardless of whether there was a degraded core condition or not. This was due solely to the fact that the applied voltage of SOOV in conjunction with the reduced insulation resistance of the cable would have acted to provide cufficient current output to effectively shunt the current output of the detector.

The detectors current output starts at 10~11 amps and spans 7 decades.

Although this review is geared towards the anticipated detector responso, the conclusion would similarly apply to a low or divorgent reading betwoon the IIRRMs . My review will cover operator diagnostics and mitigation of a HELB and subsequent use of the information for event classification and providing protective action recommendations.

ICmo rgency Proceduro E-O is ontored on four conditiones IOc trip SIS or conditions dictating a nood for thoso ESF circuits to actuate.

a

- e t

g The initial operator monitoring of the High-Range Radiation Monitors (HRRM) is procedurally required on step 24 of E-O which is entered on a reactor trip or safety injection. Stop 24 requires the operator to check if the RCS is intact 'oy monitoring if the containment radiation is consistent with pre-event values and also checking that containment pressure and sump level aru connistent with pre-event valuos. If any of those three indications indicates a positive response, then the operator is directed to E-1 for a loss of reactor or secondary coolant.

Stop 4 of E-1 has the operator determine if the fault is in the reactor coolant system s e secondary system by monitoring for a depressurized steam generator or any steam generator pressure decreasing in an uncontrollad manner. If either of those conditions exist, the operator then transitions to E-2 for faultod steam generator isolation; otherwise, the l

l operator romains in E-1 for a loss of coolant accident.

Thorofore, an inadequate re sp oras e from the HRRP1 wouJd not, in itself, mislead the operator during the diagnostic or mitigation phases of the LOCA.

Tho instrument rouponse of the IIR9M is used, however, in defining adverso containment conditions in tho Emorgency Operating Procedures. Thuno criteria aro3 3

. o 9

1

- containment pressuro > 5 psig or containment radiation > 10 5 gjgg or integrated containment radiation > 10 0 R When any of these conditions exist, then the operator is given more restrictive instrumentation limits, for control purposes, to account for the instrument errors associated with a hostile containment environment.

The indication from the HRRM is also used in the cito Emergency Preparedness Plan for event classification and providing offsite protective action recommendations. These procedures, however, state that individual radiation monitor readings are to be treated as symptoms, rather than definite evidence, that a significant release has occurred. Protective action recommendations are based on an overall asaosament of plant conditions and n21 on any single 4ndication. As an example, the protective action rec onimund atio n procedure requires an assessment of the following parameters to determine if actual or inmninent core damage is expecteds

- RCS nample compared to pru-accident data RVLIS indicates that core was uncovered

t i

s ,6 9

4.

- ECCS equipment ctatun II 2 coracontration in containment

- RM-219A,B (IIRRM )

RM-zol The RM-201 and RM-2O2 radiation monitorn aro capablo of providing bac1 cup information to that provided by RM-219A,D by uno of a correction factor.

Conclunion Sinco tho defi.ciencion annociated with tho IIRRM would not affect oporator rosponno during a LOCA, or the nubnoquent mitigation ac t: ion n in minimi ssing tho coloano, clannification of the ovent, or providing a propor protmetivo action recommendation, tho equipsiont doficiency in not connidorod nafoty nignificant.

Sinco alternativo monitoring wan availablo during the period that tho technical npocificationn woro in offoct, the technical re cluiremo n t u of tho liconno woro l

fulfullod. Rocont tonting of the Gonoral Atomic IIRRM o u tst b l i nito d that gonoric innuon enmnin with tho (1s ta l i f i e n t i o n s of ti to n o monitorn at low nignal lovoln dtto to l onica go ctarrantu or an1vanic action in the conxini colinoctionn or cablon. Thoroforo, the Rog.

GuLdo 1.97 necuency roctuiromonto for the rayn tom i

', /

/

1:

y ( cie tec to r , cable, connections) cannot be met at lower done raten for any conunerc ially available system.

Re f e re nc e sL Hev. 2 OM 53A E-O, E-1, E-2 EPP I-1 Issue 8 Rev. 3 Pgm. 13-2O EPP/IP i+ . 1 Ismue 8 Rev. O Pgs. .L7-23 BVPS-RCM 2.12 Issue 2 Pg. 8 NUREG / CR- t+7 2 8 Feb. 1988 gauinment Qualification Espfparch Test of a Hinh-Ranne Radiation Monitor J

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