ML20214N491

Advises That Continued Operation of Facility Until Scheduled Refueling Outage (First Part of Sept 1986) Acceptable,Per 860722 Telcon & Re Limitorque Motor Operators

ML20214N491
Person / Time
Site:	Arkansas Nuclear
Issue date:	11/26/1986
From:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Campbell G ARKANSAS POWER & LIGHT CO.
References
NUDOCS 8612030652
Download: ML20214N491 (2)

Text

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NOV 2 61986-In Reply Refer To:

Dockets: 50-313 Arkansas Power & Light Company ATTN: Mr. Gene Campbell .

Vice President, Nuclear Operations- -

P. O. Box 551 Little Rock, Arkansas 72203 Gentlemen:

This refers to the telephone call between the NRC staff and members of your staff conducted on July 22, 1986, and to your July 31, 1986, letter (0CAN078613) providing specific evaluations and additional clarifications regarding the environmental goalibcations of Limitorque valve actuators and justifications for continued oper.ition for AN0-1.

The telephone call and your lette.r provided the response to specific NRC questions as appropriate including the basis for:

assuming a one-minute operating time on certain valves; addressing redundant containment isolation valves outside the containment in a mild environment; ensuring that valves aid not have unacceptable failure modes due to interlocks with other components; providing further confidence that newer Limitorque vintage operators contain acceptable internal wiring, by inspecting similar valves on ANO-2; confirming that ANO-1 refueling shutdown was scheduled for, the first part of September 1986; and addressing specific and comprehensive Ncident scenarios and valve accessibility.

Based on the information provided to the NRC staff regarding the Limitorque motor operators on July 22, 1986, it was concluded that the continued operation of ANO-1 until the scheduled refueling outage (first part of September 1986) was acceptable.

DHunt cs RIreldnd TWesterman / JGagliardo GViss ng son 11/h0/86 11/p/86 11/pf/86 f 11/2c/86 11/p/86 /86 3

8612030652 861126 ' 'Y DR ADOCK 05000313 /

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Arkansas Power & Light Company We have no further questions regarding the matter at this time and plan to further review your actions during subsequent inspections.

Sincerely, "on. s.;,ncd by:

u E. . aLL" J. E. Gagliardo, Chief ,

Reactor Projects Branch cc:

J. M. Levine, Director Site Nuclear Operations -

Arkansas Nuclear One P. 0. Box 608 Russellville, Arkansas 72801 Arkansas Radiation Control Program Director bcc to DMB (IE31) bcc distrib. by RIV:

RPB RRI R. D. Martin, RA R&SPB Section Chief (RPB/B) D. Weiss, LFMB (AR-2015)

RIV DRSP RSB MIS System RSTS Operator RSB R. Ireland T. Westerman G. Vissing, NRR R. Wilson, IE

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ARKANSAS POWER & LIGHT COMPANY FIRST COMMERCIAL BUILDING /P G. BOX 551/tlTTLE ROCK, ARKANSAS 72203/IS01) 371-7901 July 31, 1986 T. GENE CAMPBELL Vice Presicent .

Nuclear Operations

' ^

OCAN078613

%]@@I J Mr. Robert D. Martin ' AUb i ? 12 i d' I, ,

Regional Administrator I U. S. Nuclear Regulatory Commission ~

Region IV _

e 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011

SUBJECT:

Arkansas Nuclear One - Units 1 & 2 Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6 Environmental Qualification of Limitorque Valve Actuators - Justifications for Continued Operation ,

Dear Mr. Martin:

During the NRC special audit / inspection of AP&L's Environmental Qualification (EQ) program for ANO held July 14-18, 1986, a number of concerns regarding Limitorque operators were expressed by audit team members. A number of discussions, telephone calls, and additional information submittals subsequently occurred which were considered sufficient to alleviate the principle concern regarding continued operation of Unit 1. One July 22, an additional telephone call was arranged between members of the AP&L staff, NRC Region, I&E (Washington), and NRR staffs to amplify or clarify previous discussions and submittals concerning the Limitorque issues.

The purpose of this letter is to document the results of the telephone call and respond to some specific questions as requested by NRC. As discussed, the previous package (provided during the inspection) of justifications for continued operation (JC0's) for ANO-1 has'been revised to reflect specific NRC questions and to clean up minor errors, typo's, etc. The revision dated July 22, 1986 is the latest version as supplemented by information provided in this letter and is attached. The specific issues for which a written clarification was requested are addressed separately below.

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• , , July 31, 1986

1. One minute operating time - For those operators which perform their function immediately following initiation of an accident, (containment, isolation valves inside containment) completion of safety function was noted to be performed within one minute. After some discussion regarding the basis for one minute, it was agreed that any concerns were resolved by virtue of the presence of redundant outside containment isolation valves which perform their functions in a mild environment.

A detailed description of the containment isolation valves design is contained in the FSAR, Section 5.2.5.2.

2. Valve interlocks - It was requested that AP&L confirm that all valves addressed in the JCO's did not have unacceptable failure modes due to interlocks with other components. AP&L has re-reviewed all applicable circuits and has confirmed that no unacceptable failure modes can occur due to component interlock features.

3. EFW valves CV-2620, -2626 - While discussing the specific justification for these valves, it was pointed out that the valve actuators are of the newer Limitorque vintage which contain wiring with complete qualification documentation. In response to NRC's request, we specifically have reviewed the inspection results for several Unit 2 Limitorques purchased since 1980 and have confirmed the presence of readily identifiable and fully qualified internal wiring. Therefore, we have high confidence that these valves, purchased in the same time period, also contain the qualified wire as indicated by Limitorque.

Very truly yours, 4

J. Ted Enos, Manager Nuclear Engineering and Licensing JTE/CHT/sg Attachments

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ANO-1 LIMITORQUE VALVE ENVIRONMENTAL QUALIFICATION JUSTIFICATION FOR CONTINUED

, OPERATION TO END OF CYCLE 7 J

Reviewed By Sh Date' M ~/fz2l9(n -

Reviewed By / Date '

Yavl $ N m&la,w 7/22/h "

App [fved-PSC Q/ I 'Date' 7

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' EQUIPMENT ENVIRONMENTAL QUALIFICATION JUSTIFICATION FOR INTERIM OPERATION ANO-1 COMPONENT: Motor Operators TAG N0(S): CV-3812, CV-3813, CV-3821, CV-3822 1 MANUFACTURER AND MODEL NO: Limitorque SMB and SB Series SYSTEM - P&ID NO: Service Water /M-210 LOCATION: Upper South PPA (Room 46 - 335'), Upper North PPA (Room 79 -

360'), Access Area (Room 49 - 335'), General. Access Area (Room 4 -

317') '

• SAFETY FUNCTION:

These valves are normally closed and open to provide service water to the reactor building coolers and decay heat heat exchangers.

QUALIFICATION DISCREPANCY

Internal MOV wiring and terminal blocks have not been identified.

• JUSTIFICATION FOR INTERIM OPERATION:

These valves open on an E.S. signal at the onset of LOCA/HELB. They perform their safety function in a mild environment due to the fact l that they are

1) located outside containment (LOCA/MSLB), 2) not l required for an HELB outside containment, and 3) complete their function prior to the onset of radiation dose from the recirculation lines.

They are not required to be repositioned after recirculation has been initiated and no known failure mode associated with internal wiring or terminal block qualification can cause them to change position. Since the conductors necessary to initiate actuation of a motor operator (s) are not present in the motor operator limit switch compartment, no failure of in'ternal wiring or terminal blocks (short circuit, short to ground or hot shorts) can cause repositioning of the valves.

1 Revised 7/22/86 7

e Step 1 in the ESAS tab of procedure 1202.01 requires the verification of proper actuation. This step would normally be performed within a few minutes of any event which would expose these valves to any type of harsh environment. Recovery activities by the operator would not require the further operation of these valves. Subsequent erroneous indication or the lack of indication, would not cause the operator to take improper action (e.g., for an erroneous close indication the operator may attempt to open the valve; this would have no deleterious effect on the valve or valve operator).

Notwithstanding the above arguments, AP&L considers .these valves operable and qualified based on previous qualification testing performed by the manufacturer. We have examined internal wiring removed from similar devices on ANO-2 and have determined that the internal interconnecting wires were PVC in accordance with the CSA specifications as stated by Limitorque as being installed and received by AP&L. We fully expect the same type of wiring will be found in ANO-1 actuators. Limitorque has tested a variety of operator configurations over a long period of time as reported in B0058. The earlier tests undoubtedly included this type of internal wire.

Additional supporting qualification information on PVC wire insulation is provided in NEL-076-52.

A recent inventory walkdrwn of all Q and non-Q wire and cable identified only qualified SIS wire (Rockbestos Firewall) in stock.

AP&L only installed qualified SIS wire during maintenance activities on these devices. However, AP&L will be inspecting these operators during the upcoming refueling outage. Any internal parts whose qualification cannot be positively established will be replaced with qualified parts.

This justification is provided in accordance with 10CFR50.49 section (i), item (2) which permits partial type testing and additional data to support previous qualification testing.

2 Revised 7/22/86

EQUIPMENT ENVIRONMENTAL QUALIFICATION

, JUSTIFICATION FOR INTERIM OPERATION.

ANO-1 COMPONENT: Motor Operators TAG N0(S): CV-2400, CV-2401 i MANUFACTURER AND MODEL NO: Limitorque SMB Series 1

SYSTEM - P&ID N0: RB Spray and Core Flood /M-236

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LOCATION: Upper North Pipe Penetration Area, Room 79, Elevation 360'

• SAFETY FUNCTION: -

I These valves are normally closed and isolate the containment spray pump discharge from the spray headers. These devices receive engineering safeguards signals to open as required to mitigate a LOCA or MSLB inside containment.

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• QUALIFICATION DISCREPANCY:

Internal M0V wiring and terminal blocks have not been identified.

• JUSTIFICATION FOR INTERIM OPERATION:

These valves open in response to an E.S. signal at the onset of 1 LOCA/HELB. These devices perform their safety function in a mild environment due to the fact that they are: 1) located outside containment (LOCA/MSLB), 2) not required for an HELB outside l

containment, and 3) complete their function prior to the onset of radiation dose from the recirculation lines. .

} They are not required to be repositioned during the course of the accident and no known failure mode associated with internal wiring or i terminal blocks qualification can cause them to change position. Since  !

the conductors necessary to initiate actuation of a motor operator (s)  :

are not present in the motor operator limit switch compartment, no j failure of internal wiring or terminal blocks (short circuit, short to ground or hot shorts) can cause repositioning of the valves.

3 Revised 7/22/86

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Step 1 in the ESAS tab of procedure 1202.01 requires the verification of proper actuation. This step would normally be performed"within a few minutes of any event which would expose these valves to any type of i

harsh environment. Recovery activities by the operator would not require the further operation of these valves. Subsequent erroneous indication or the lack of indication, would not cause the operator to take improper action (e.g. , for an erroneous close indication the operator may attempt to open the valve; this would have no deleterious effect on the valve or valve operator).

• Notwithstanding the above arguments, AP&L considers these valves

! operable and qualified based on previous qualification testing performed by the manufacturer. We have examined internal wiring removed from similar devices on ANO-2 and have determined that the internal interconnecting wires were PVC in accordance with the CSA specifications as stated by Limitorque as being installed and received by AP&L. We fully expect the same type of wiring will be found in l ANO-1 actuators. Limitorque has tested a variety of operator configurations over a long period of time as reported in B0058. The

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earlier tests undoubtedly included this type of internal wire. ~

Additional supporting qualification information on PVC wire insulation is provided in NEL-076-52. -

A recent inventory walkdown of all Q and non-Q wire'and cable identified only qualified SIS wire (Rockbestos Firewall) in stock.

4 AP&L only installeo qualified SIS wire during maintenance activities on these devices. However, AP&L will be inspecting these operators during the upcoming refueling outage. Any internal parts whose qualification cannot be positively established will be replaced with qualified parts.

. This justification is provided in accordance with 10CFR50.49 section I

(i), item (2) which permits partial type testing and additional data to support previous qualification testing.

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EQUIPMENT ENVIRONMENTAL QUALIFICATION JUSTIFICATION FOR INTERIM OPERATION j ANO-1 l

COMPONENT: Motor Operators -

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TAG N0(S): CV-1400, CV-1401

• MANUFACTURER AND MODEL NO: Limitorque SMB Series -

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' SYSTEM - P&ID N0: Decay Heat Removal /M-232 ,

i LOCATION: Upper North Pipe Penetration Area, Room 79, Elevation 360'

• SAFETY FUNCTION:

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These valves are normally closed and isolate the decay heat removal -

heat exchanger from the RCS (LPI discharge). These devices receive l engineering safeguards signals to open as required to mitigate a LOCA inside containment.

• QUALIFICATION DISCREPANCY:

Internal MOV wiring or terminal blocks have not been identified.

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• JUSTIFICATION FOR INTERIM OPERATION:

i These valves open on an E.S. signal (low RCS pressure or high Reactor

! Building Pressure). These devices perform their safety function in a j '

mild environment due to the fact that they are: 1) located outside containment (LOCA), 2) not required for an HELB outside containment, and 3) complete their function prior to the onset of radiation dose from the recirculation lines.

They are not require'd to be repositioned during the course of the accident and no known failure mode associated with internal wiring or 1

' terminal blocks qualification can cause them to change position. Since the conductors necessary to initiate actuation of a motor operator (s)

, are not present in the motor operator limit' switch compartment, no failure of internal wiring or terminal blocks (short circuit, short to ground or hot shorts) can cause repositioning of the valves.

t 5 Revised 7/22/86

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Step 1 in the ESAS tab of procedure 1202.01 requires.the verification of proper actuation. This step would normally be performed within a few minutes of any event which would expose these valves to any type of harsh environment. Recovery activities by the oper,ator would not require the further operation of these valves. Subsequent erroneous indication or the lack of indication, would not cause the operator to take improper action (e.g., for an erroneous close indication the operator may attempt to open the valve; this would have no deleterious effect on the valve or valve operator).

Notwithstanding the above arguments, AP&L considers these valves operable and qualified based on previous qualification testing performed by the manufacturer. We have examined internal wiring i removed from similar devices on ANO-2 and have , determined that the

internal interconnecting wires were PVC in accordance with the CSA

,l specifications as stated by Limitorque as being installed and received by AP&L. We fully ~ expect the same type of wiring will be found in ANO-1 actuators. Limitorque has tested a variety of operator configurations over a long period of time'as reported in B0058. The earlier tests undoubtedly included this type of internal, wire.

Additional supporting qualification information on PVC' wire insulation ,

! is provided in NEL-076-52.

j A recent inventory walkdown of all Q and non-Q wire and cable 1 i identified only qualified SIS wire (Rockbestos Firegall) in stock.

AP&L only installed qualified SIS wire during maintenance a,ctivities on these devices. However, AP&L will be inspecting these operators during the upcoming refueling outage. Any internal parts whose qualification cannot be positively established will be replaced with qualified parts.

This justification is provided in accordance with 10CFR50.49 section (i), item (2) which permits partial type testing and additional data to support previous qualification testing.

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l 6 Revised 7/22/86

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EQUIPMENT ENVIRONMENTAL QUALIFICATION JUSTIFICATION FOR INTERIM OPERATION ANO-1 COMPONENT: Motor Operators TAG N0(S): CV-1219, CV-1220, CV-1227, CV-1228 MANUFACTURER AND MODEL N0: Limitorque SMB Series SYSTEM - P&ID NO: Makeup and Purification /M-231 LOCATION: Upper North Pipe Penetration Area, Room 79., Elevation 360'

• SAFETY FUNCTION:

These valves are normally closed and isolate the HPI Lines to loop A &

B from the HPI Pump discharge. These devices receive engineering safeguards signals to open as required to mitigate a LOCA or HELB inside containment.

QUALIFICATION DISCREPANCY:

Internal MOV wiring and terminal blocks have not been identified.

• JUSTIFICATION FOR INTERIM OPERATION:

These valves open on an E.S. signal (RCS low pressure or Reactor l Building High pressure). These devices perform their safety function in a mild environment due to the fact that they are: 1) located outside containment (LOCA/MSLB), 2) not required for an HELB affecting Room 79, and 3) complete their function prior to the onset of radiation dose from the recirculation lines.

They are not required to be repositioned during the course of the accident and no known failure mode associated with internal wiring qualification can cause them to change position. Since the conductors necessary to initiate actuation of a motor operator (s) are not present in the motor operator limit switch compartment, no failure of internal wiring or terminal blocks (short circuit, short to ground or hot shorts) can cause repositioning of the valves.

7 Revised 7/22/86

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Step 1 in the ESAS tab of procedure 1202.01 requires the verification of proper actuation. This step would normally be performed within a few minutes of any event which would expose these valves,Ao any type of ,

harsh environment. Recovery activities by the operator would not require the further operation of these valves. Subsequent erroneous indication or the lack of indication, would not cause the operator to take improper action-(e.g., for an erroneous close indication the operator may attempt to open the valve; this would have no deleterious effect on the valve or valve operator).

Notwithstanding the above arguments, AP&L considers these valves operable.and qualified based on previous qualification testing

, performed by the manufacturer. We have examined internal wiring -

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removed from similar devices on ANO-2 and have determined that the internal interconnecting wires were PVC in accordance with the CSA specifications as stated by Limitorque as being installed and received i

by AP&L. We fully expect the same type of wiring will be found in '

ANO-1 actuators. Limitorque has tested a variety of operator configurations over a long period of time as reported in B0058. The earlier tests undoubtedly included this type of internal wire.

Additional supporting qualification information on PVC wire insulation

is provided in NEL-076-52.

' i A recent inventory walkdown of all Q and non-Q wire and cable i identified only qualifie'd SIS wire (Rockbestos Firewall) in stock.

! AP&L only installed qualified SIS wire during maintenance activities on these devices. However, AP&L will be inspecting these operators during the upcoming refueling outage. Any internal parts whose qualification j cannot be positively established will be replaced with qualified parts.  ;

This justification is provided in accordance with 10CFR50.49 section (i), item (2) which permits partial type testing and additional data to j

support previous qualification testing.

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8 Revised 7/22/86

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I EQUIPMENT ENVIRONMENTAL QUALIFICATION JUSTIFICATION FOR INTERIM OPERATION ANO-1 COMPONENT: Motor Operators TAG N0(S): CV-1407, CV-1408 MANUFACTURER AND MODEL NO: Limitorque SMB Series SYSTEM - P&ID N0: Decay Heat Removal /M-232 i LOCATION: Room 57, Tank Room, Elevation 335' .

• SAFETY FUNCTION:

These valves are normally closed and isolate the Borated water storage tank from the suction of the HPI, LPI and Containment Spray pumps.

! These devices receive E.S. signals to open to initiate HPI, LPI and Containment Spray. They are closed by a remote manual signal at the 1 end of the injection phase and the start of the recirculation phase.

• QUALIFICATION DISCREPANCY:

I Internal MOV wiring and terminal blocks have not been identified.

!

• JUSTIFICATION FOR INTERIM OPERATION:

These devices are required to perform their safety function (open to supply Borated water to the pump suction) in response to automatic commands prior to the onset of any radiation dose from recirculation piping. They are closed by a remote manual signal at the start of l

recirculation before a harsh radiation environment exists. They are i

not required to be repositioned after the recirculation mode has been i

established. They are not exposed to an outside containment HELB for which they are required to operate.

l There is no known failure mode associated with internal wiring l qualification which could cause them to change position. Since the conductors necessary to initiate actuation of a motor operator (s) are not present in the motor operator limit switch compartment, no failure of internal wiring or terminal blocks (short circuit, short to ground j or hot shorts) can cause repositioning of the valves. _

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9 Revised 7/22/86

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Erroneous indication or the lack of indication, would not cause the operator to take improper action (e.g. , for an erroneous open indication the operator may attempt to close the valve; this would have no deleterous effect on the valve or valve operator). .

Notwithstanding the above arguments, AP&L considers these valves operable and qualified based on previous qualification testing

performed by the manufacturer. We have examined internal wiring removed from similar devices on ANO-2 and have determined that the internal interconnecting wires were PVC in accordance with the CSA specifications as stated by Limitorque as being installed and received by AP&L. We fully expect the same type of wiring will be found in ANO-1 actuators. Limitorque has tested a variety of operator configurations over a long period of time as reported in B0058. The earlier tests undoubtedly included this type of internal wire.

Additional supporting qualification information on PVC wire insulation is provided in NEL-076-52.

A recent inventory walkdown of all Q and non-Q wire and cable identified only qualified SIS wire (Rockbestos Firewall) in stock.

AP&L only installed qualified SIS wire during maintenance activ.ities on these devices. However, AP&L will be inspecting these operators during the upcoming refueling outage. Any internal parts whose qualification cannot be positively established will be replaced with qualified parts.

This justification is provided in accordance with 10CFR50.49 section (i), item (2) which permits partial type testing and additional data to support previous qualification testing.

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EQUIPMENT ENVIRONMENTAL QUALIFICATION JUSTIFICATION FOR INTERIM OPERATION -

ANO-1 COMPONENT: Motor Operators TAG N0(S): CV-1616, CV-1617 MANUFACTURER AND MODEL N0: Limitorque SMB Series .

SYSTEM - P&ID NO: Chemical Addition /M-233 LOCATION: Tank Room, Room 57, Elevation 335'

• SAFETY FUNCTION:

These valves are normally closed isolation valves which isolate the sodium hydroxide addition tank from the borated water supply to the containment spray pumps and LPI pumps. They are opened on an E.S.

signal. They are remote manually closed by the~ operator when the injection phase is ended and the recirculation phase is started.

+ QUALIFICATION DISCREPANCY:

Internal MOV wiring and terminal blocks have not been identified.

JUSTIFICATION FOR INTERIM OPERATION:

These devices are required to perform their safety function (open to add sodium hydroxide) in response to automatic commands prior to the onset of any radiation dose from recirculation piping. They are manually closed at the start of recirculation before a harsh radiation environment exists. They are not required to be repositioned after the recirculation mode has been established. They are not exposed to an outside containment HELB for which they are required to operate.

There is no known failure mode associated with internal wiring or terminal blocks qualification which could cause them to change position. Since the conductors necessary to initiate actuation of a motor operator (s) are not present in the motor operator limit switch

. compartment, no failure of internal wiring or terminal blocks (short circuit, short to ground or hot shorts) can cause repositioning of the ,

valves.

11 Revised 7/22/86

Erroneous indication or the lack of indication, would'not cause the operator to take improper action (e.g., for an erroneous open indication the operator may attempt to close the valve; this would have no deleterous effect on the valve or valve operator).

Notwithstanding the above arguments, AP&L considers'these valves operable and qualified based on previous qualification testing performed by the manufacturer. We have examined internal wiring removed from similar devices on ANO-2 and have determined that the internal interconnecting wires were PVC in accordance with the CSA specifications as stated by Limitorque as being installed and received by AP&L. We fully expect the same type of wiring will be found in ANO-1 actuators. Limitorque has tested a variety of operator

, configurations over a long period of time as reported.in B0058. The earlier tests undoubtedly included this type of internal wire.

Additional supporting qualification information on,PVC Wire insulation is provided in NEL-076-52.

A recent inventory walkaown of all Q and non-Q wire and cable identified only qualified SIS wire (Rockbestos Firewall) in stock.

AP&L only installed qualified SIS wire during maintenance activities on these devices. However, AP&L will be inspecting these operators during the upcoming refueling outage. Any internal parts whose qualification' cannot be positively established will be replaced with qualified parts.

This justification is provided in accordance with 10CFR50.49 section (i), item (2) which permits partial type testing and additional data to support previous qualification testing.

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w EQUIPMENT ENVIRONMENTAL QUALIFICATION JUSTIFICATION FOR INTERIM OPERATION ANO-1 COMPONENT: Motor Operators -

TAG N0(S): CV-1405, CV-1406 MANUFACTURER AND MODEL NO: Limitorque SMB Series SYSTEM - P&ID N0: Decay Heat Removal /M-232 LOCATION: Decay Heat Vaults (Rooms 11 and 13), Elevation 317' a

SAFETY FUNCTION:

These valves are normally closed and isolate the RB sump from the LPI pump suction. They are manually opened at the end of th'e injection phase and prior to initiation of the recirculation phase.

• QUALIFICATION DISCREPANCY:

Internal MOV wiring and terminal blocks have not been identified.

JUSTIFICATION FOR INTERIM OPERATION: #

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! These devices are required to perform their safety functions in '

response to manual commands prior to theLonset of any radiation dose from recirculation piping. They are not required to be repositioned after the recirculation mode has been established. They are not exposed to an outside containment HELB for which they are required to operate.

4 There is no known failure mode associated with internal wiring

~ qualification which could cause them to change position. Since the conductors necessary to initiate actuation of a motor operator (s) are not present in the motor operator limit switch compartment, no failure of internal wiring or terminal blocks (short circuit, short to ground

'or hot shorts) can cause repositioning of the valves.

e Erroneous indication or the lack of indication,.woul.d not cause the operator to take improper action (e.g., for a'n, erroneous open indication the operator may attempt to close the valve; this would have no deleterous effect on the valve or valve operator).

13 Revised 7/22/86 m

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Notwithstanding the above arguments, AP&L considers these valves ,

operable and qualified based on previous qualification testing performed by the manufacturer. We have examined internal wiring removed from similar devices on ANO-2 and have determined that the internal interconnecting wires were'PVC in accordance with the CSA specifications as stated by Limitorque as being installed and received by AP&L. We fully expect the same type of wiring will be found in ANO-1 actuators. Limitorque has tested a variety'of operator configurations over a long period of time as reported in B0058. The earlier tests undoubtedly included this type of internal wire.

Additional supporting qualification information on PVC wire insulation is provided in NEL-076-52.

A recent inventory walkdown of all Q and non-Q wire and cable identified only qualified SIS wire (Rockbestos Firewall) in stock.

AP&L only installed qualified SIS wire during maintenance activities on these devices. However, AP&L will be inspecting these operators during the upcoming refueling outage. Any internal parts 'whose qualification cannot be positively established will be replaced with qualified parts.

This justification is provided in accordance with 10CFR50.49 section (i), item (2) which permits partial type testing and additional data to support previous qualification testing.

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14 Revised 7/22/86

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i EQUIPMENT ENVIRONMENTAL QUALIFICATION JUSTIFICATION FOR INTERIM OPERATION '

AN0-1 COMPONENT: Motor Operator TAG N0(S): CV-1404 MANUFACTURER AND MODEL N0: Limitorque SMB Series i

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SYSTEM - P&ID NO: Decay Heat Removal /M-232 LOCATION: Upper North Pipe Penetration Area, Room 79, Elevation 360'

• SAFETY FUNCTION:

This valve is used to isolate the decay heat system from the RCS. It is manually opened for decay heat removal. It receives no E.S. signal and its only function is to remain closed during LOCA.

• QUALIFICATION DISCREPANCY: '

j Internal MOV wiring and terminal blocks have not been identified. ,

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• JUSTIFICATION FOR INTERIM OPERATION: i This valve is normally closed and would only be opened by the control room operator when the reactor coolant system is depressurized. This device is required to maintain position during a LOCK and has no known failure mode associated with internal wiring or terminal blocks qualification which could cause it to change position. Since the conductors necessary to initiate actuation of a motor operator (s) are not present in the motor operator limit switch compartment, no failure of internal wiring or terminal blocks (short circuit, short to ground or hot shorts) can cause repositioning of the valve. This valve is on the EQ list for R.G. 1.97 position indication only. The valve function i

is not required to be qualified.

Erroneous indication or the lack of indication, would not cause the

( operator to take improper action (e.g., for an erroneous open

indication the operator may attempt to close the valve; this would have j no deleterous effect on the valve or valve operator).

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15 Revised 7/22/86 r -__ -. - . _ .-_-r-.. ~ , , . - _ - . . ~. , , _ _ , _ - - , . . _ _ _ , _ _ . . ....- .-_--,--n. -,n~-....,ew~...

Notwi.thstanding the above arguments, AP'&L considers this valve operable l and qualified based on previous qualification testing performed by the manu facturer. We have examined internal wiring removed from similar devices on ANO-2 and have determined that the internal interconnecting wires were PVC in accordance with the CSA specifications as stated by ,

Limitorque as being installed and received by AP&L. We fully expect the same type of wiring will be found in ANO-1 actuators. Limitorque has tested a variety of operator configurations over a long period of time as reported in B0058. The earlier tests undoubtedly included this type of internal wire. Additional supporting qualification information on PVC wire insulation is provided in NEL-076-52.

A recent inventory walkdown of all Q and non-Q wire and cable identified only qualified SIS wire (Rockbestos Firewall) in stock.

AP&L only installed qualified SIS wire during maintenance activities on these devices. However, AP&L will be inspecting these operators during the upcoming refueling outage. Any internal parts whose qualification cannot be positively established will be replaced with quajified parts.

This justification is provided in accordance with 10CFR50.49 section (i), item (2) which permits partial type testing and additional data to support previous qualification testing.

l i

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1G Revised 7/22/86 l

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EQUIPMENT ENVIRONMENTAL QUALIFICATION ,

JUSTIFICATION FOR INTERIM OPERATION ANO-1 j COMPONENT: Motor Operator TAG N0(S): CV-3823 MANUFACTURER AND MODEL N0: Limitorque SMB Series d

SYSTEM - P&ID NO: Service Water /M-210 LOCATION: Access Area, Room 20, Elevation 335'

• SAFETY FUNCTION:

! This valve is normally closed and isolates the service water discharge from the emergency pond. It is operated manually in the event of loss of Lake Dardanelle.

• QUALIFICATION DISCREPANCY:

The specific internal wiring or terminal block for the Limitorque operator has not been identified.

• JUSTIFICATION FOR INTERIM OPERATION:

The maximum one year dose to the actuat' o r is 1.6 X 103 rads. This dose level has not been shown to affect any elastomeric material used as l

electrical wire insulation. Therefore, the device function's in i essentially a mild environment at any time during LOCA. This valve is i accessible for manual operation at any time post LOCA. It is only required to open in the event Lake Dardanelle is lost and the Emergency '

i Cooling Pond is required for Service Water.

This valve is required to maintain position during a LOCA or HELB and has no known failure mode associated with its internal wiring qualification which could cause it to change position. Since the conductors necessary to initiate actuation of.a' motor operator (s) are

' not present in the motor operator limit switch compartment, no failure of internal wiring or terminal blocks (short circuit, short to ground or hot shorts) can cause repositioning of the valves.

s

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17 Revised 7/22/86 l

i

e Erroneous indication or the lack of indication, would not cause the operator to take improper action (e.g. , for an erroneous open indication the operator may attempt to close the valve; this would have no deleterious effect on the valve or valve operator).

Notwithstanding the above arguments, AP&L considers these valves operable and qualified based on previous qualification testing performed by the manufacturer. We have examined internal wiring removed from similar devices on ANO-2 and have determined that the

, internal interconnecting wires were PVC in accordance with the CSA  !

specifications as stated by Limitorque as being installed and received i by AP&L. We fully expect the same type of wiring will be found in i ANO-1 actuators. Limitorque has tested a variety of operator

configurations over a long period of time as reported in B0058. The earlier tests undoubtedly included this type of internal wire.

Additional supporting qualification information on PVC wire insulation -

is provided in NEL-076-52. "

A recent inventory walkdown of all Q and non-Q wire and cable identified only qualified SIS wire (Rockbestos Firewall) in stock.

l AP&L only installed qualified SIS wire during maintenance activities on these devices. However, AP&L will be inspecting these operators during the upcoming refueling outage. Any internal parts whose qualification cannot be positively established 'will be replaced with qualified parts.

This justification is provided in accordance with 10CFR50.49 section (i), item (2) which permits partial type testing and additional data to -

support previous qualification testing.

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j 18 Revised 7/22/86 .

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EQUIPMENT ENVIRONMENTAL QUALIFICATION JUSTIFICATION FOR INTERIM OPERATION ANO-1 COMPONENT: Motor Operators TAG N0(S): CV-2613, CV-2663 MANUFACTURER AND MODEL N0: Limitorque SMB-000 SYSTEM - P&ID N0: Emergency Feedwater/M-202 LOCATION: Room 170, Elevation 404'

• SAFETY FUNCTION:

These devices open on an EFIC MSLI signal for a MSLB on either steam i generator.

• QUALIFICATION DISCREPANCY:

Internal MOV wiring and terminal blocks have not been identified.

• JUSTIFICATION FOR INTERIM OPERATION:

These devices are required to open for a MSLB inside or outside of containment to provide steam to the EFW turbine driver (K3). They complete their opening stroke in less than one minute following the HELB. They are not required to close since isolation of the EFW turbine can be accomplished manually using the trip and throttle valve located at K3 on EL 335'.

These devices were purchased and installed in 1982 and as such it is expected that qualified internal wiring and terminal blocks were furnished by Limitorque. Walkdovai of similar vintage actuators at other plants have not uncovero# the to problems. -

Additionally, since the op3r.1ar . mes are less than one minute, exposure to the harsh conditions io considered too short to induce failure in the internal wiring or terminal blocks. This is based on generic capabilities of the type of wire whose qualification was  ;

suspect. Also thermal lag within the limit switch compartment will '

limit HELB temperature effects during such a short operating time.

4 l

l 19 Revised 7/22/86

, . , e -- .,- -,, - _.- - - , ,

o .

The plant operators would not be misled by failure of the control circuits after opening as other indications of steam turbine operability are not affected by the postulated failure of the control circuit. Since the conductors necessary to initiate actuation of a motor operator (s) are not present in the motor operator limit switch compartment, no failure of internal wiring or terminal blocks (short

circuit, short to ground or hot shorts) can cause repositioning of the

! valves.

Notwithstanding the above arguments, AP&L considers these valvesi operable and qualified based on previous qualification testing performed by the manufacturer. We have examined internal wiring removed from similar devices on ANO-2 and have determined that the internal interconnecting wires were PVC in accordance with the CSA specifications as stated by Limitorque as being installed and received by AP&L. We fully expect the same type of wiring will be found in ANO-1 actuators. Limitorque has tested a variety of operator configurations over a long period of time as reported in 80058. The earlier tests undoubtedly included this type of internal wire.

Additional supporting qualification information on PVC wire insulation is provided in NEL-076-52.

' A recent inventory walkdown of all Q and non-Q wire and cable identified only qualified SIS wire (Rockbestos Firewall) in stock.

AP&L only installed qualified SIS wire during maintenance activities on

~

these devices. However, AP&L will be inspecting these operators during the upcoming refueling outage. Any internal parts whose qualification cannot be positively established will be replaced with qualified parts.

This justification is provided in accordance with 10CFR50.49 section (i), item (2) which permits partial type testing and additional data to support previous qualification testing.

1 i

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4 20 Revised 7/22/86

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EQUIPMENT ENVIRONMENTAL QUALIFICATION i

JUSTIFICATION FOR INTERIM OPERATION ANO-1 1

COMPONENT: Motor Operator TAG N0(S): CV-1301 I

MANUFACTURER AND MODEL NO: Limitorque SMB Series SYSTEM - P&ID N0: Limitorque SMB Series LOCATION: Makeup and Purification /M-231 f

. SAFETY FUNCTION:

This valve is normally open to provide a recirculation path for the makeup pump. This device receives engineering safeguards signals to close as required to mitigate a LOCA inside containment. i

• QUALIFICATION DISCREPANCY:

Internal MOV wiring or terminal blocks have not been identified.

e JUSTIFICATION FOR INTERIM OPERATION:

The valve is closed by an E.S. signal at the start of LOCA while the  !

environment is still mild. This device performs its safety function in j a mild environment due to the fact that it is: 1) located outside 3 containment (LOCA), 2) not required for an HELB outside containment, and 3) completes its function prior to the onset of radiation dose from i

the recirculation lines.

It is not required to be repositioned during the course of the accident and no known failure mode associated with internal wiring or terminal '

blocks qualification can cause it to change position. Since the

~

conductors necessary to initiate actuation of a motor operator (s)'are not present in the motor operator limit switch compartment, no failure of internal wiring or terminal blocks (short circuit, short to ground or hot shorts) can cause repositioning of the valves.

i i

l 21 Revised 7/22/86

I Step 1 in the ESAS tab of procedure 1202.01 requires the verification of proper actuation. 'This step would normally be performed within a '

few minutes of any event which would expose these valves to any type of harsh environment. Recovery activities by the operator would not require the further operation of these valves. Subsequent erroneous indication or the lack of indication, would not cause the operator to take improper action (e.g., for an erroneous open indication the operator may attempt'to close the valve; this would have no deleterious effect on the valve or valve operator).

Notwithstanding the above arguments, AP&L considers these valves operable and qualified based on previous qualification testing performed by the manufacturer. We have examined internal wiring removed from similar devices on ANO-2 and have determined that the internal interconnecting wires were PVC in accordance with the CSA specifications as stated by Limitorque as being installed and received

' by AP&L.- We fully expect the same type of wiring will be found in ANO-1 actuators. Limitorque has tested a variety of operator configurations over a long period of time as reported in B0058. The earlier test"s undoubtedly included this type of internal wire.

Additional supporting qualification information on PVC wire insulation is provided in NEL-076-52.

A recent inventory walkdown of all Q and non-Q wire and cable  ;

identified only qualified SIS wire (Rockbestos Firewall) in stock. '

AP&L only installed qualified SIS wire during maintenance activities on these devices. However, AP&L will be inspecting these operators during the upcoming refueling outage. Any internal parts whose qualification cannot be positively established will be replaced with qualified parts.

This justification is provided in accordance with 10CFR50.49 section (i), item (2) which permits partial type testing and additional data to s pport previous qualification testing.

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22 Revised 7/22/86

EQUIPMENT ENVIRONMENTAL QUALIFICATION JUSTIFICATION FOR INTERIM OPERATION ANO-1 COMPONENT: Motor Operator TAG N0(S): CV-1206 i

MANUFACTURER AND MODEL N0: Limitorque SMB Series SYSTEM - P&ID N0: Makeup and Purification /M-231 i

LOCATION: Upper North Pipe Penetration Area, Room 79, Elevation 360'

• SAFETY FUNCTION:

This valve is normally open and is located in the supply to the reactor cooling pump seals. It is not automatically closed for LOCA or HELB.

It can be operated locally or from the control room.

• QUALIFICATION DISCREPANCY:

Internal MOV wiring and terminal blocks have not been identified.

• JUSTIFICATION FOR INTERIM OPERATION:

This device has no active safety function for LOCA or HELB. It will close automatically when total seal injection flow falls below setpoint for any reason and it will not reopen except in response to an operator  ;

command.

The plant operator may choose to isolate (close) this valve anytime during the injection phase of a LOCA or he may take no action in which case it will close automatically when HPI is secured at the start of the recirculation phase. 3 Thus this valve will function either automatically or remote manually in a mild environment due to the fact that it is: 1) located outside

containment (LOCA), 2) not required for an HELB outside containment,

and 3) complete their function prior to the onset of radiation dose l

, from the recirculation lines.

l i 23 Revised 7/22/86 4

It is not required to be repositioned during the course of the accident and no known failure mode associated with internal wiring qualification can cause it to change position. Since the conductors necessary to initiate actuation of a motor operator (s) are not present in the motor operator limit switch compartment, no failure of internal wiring or terminal blocks (short circuit, short to ground or hot. shorts) can cause repositioning of the valves.

Erroneous indication or the lack of indication, would not cause the operator to take improper action (e.g. for an erroneous open indication the operator may attempt to close the valve; this would have no deleterious effect on the valve or valve operator).

1 Notwithstanding the above arguments, AP&L considers this valve operable l and qualified-based on previous qualification testing performed by the

manufacturer. We have examined internal wiring removed from similar ,

devices on ANO-2 and have determined that the internal interconnecting l wires were PVC in accordance with the CSA specifications as stated by Limitorque as being installed and received by AP&L. We fully expect

, the same type of wiring will be found in ANO-1 actuators. Limitorque l has tested a variety of operator configurations over a long period of j time as reported in B0058. The earlier tests undoubtedly included this type of internal wire. Additional supporting qualification information on PVC wire insulation is provided in NEL-076-52.

f A recent inventory walkdown of all Q and non-Q wire and cable identified only qualified SIS wire (Rockbestos Firewall) in stock.

AP&L only installed qualified SIS wire during maintenance activities on these devices. However, AP&L will be inspecting these operators during the upcoming refueling outage. Any internal parts whose qualification cannot be positively established will be replaced with qualified parts.

This justification is provided in accordance with 10CFR50.49 section (i), item (2) which permits partial type testing and additional data to support previous qualification testing.

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' l 24 Revised 7/22/86 I i

EQUIPMENT ENVIRONMENTAL QUALIFICATION JUSTIFICATION FOR INTERIM OPERATION ANO-1 COMPONENT: Motor Operators TAG N0(S): CV-1221, CV-1234, CV-1274 MANUFACTURER AND MODEL N0: Limitorque SMB Series SYSTEM - P&ID N0: Makeup and Purification /M-231 LOCATION: Upper North Pipe Penetration Area, Room 79, Elevation 360'

• SAFETY FUNCTION:

These valves are normally open and receive an E.S. signal to isolate /close as required to mitigate a LOCA inside containment.

+

QUALIFICATION DISCREPANCY:

Internal MOV wiring or terminal blocks have not been identified.

• JUSTIFICATION FOR INTERIM OPERATION:

These valves close on an E.S. signal at the start of a LOCA while the environment is still mild. These devices perform their safety function in a mild environment due to the fact that they are: 1) located outside containment (LOCA), 2) not required for an HELB outside containment, and 3) complete their function prior to the onset of radiation dose from the recirculation lines.

They are not required to be repositioned during the course of the accident and no known failure mode associated with internal wiring or terminal blocks qualification can cause them to change position. Since

^

the conductors necessary to initiate actuation of a motor operator (s)

, are not present in the motor operator limit switch compartment, no failure of internal wiring or terminal blocks (short circuit, short to ground or hot shorts) can cause repositioning of the valves.

l l

25 Revised 7/22/86 l

l l

Step 1 in the ESAS tab of procedure 1202.01 requires the verification of proper actuation. This step would normally be performed within a few minutes of any event which would expose these valves to any type of harsh environment. Recovery activities by the operator would not require the further operation of these valves. Subsequent erroneous

, indication or the lack of indication, would not cause the operator to take improper action (e.g., for an erroneous open indication the operator may attempt to close the valve; this would have no deleterious effect on the valve or valve operator).

Notwithstanding the above arguments, AP&L considers these valves operable and qualified based on previous qualification testing performed by the manufacturer. We have examined internal wiring t removed from similar devices on ANO-2 and have determined that the internal interconnecting wires were PVC in accordance with the CSA specifications as stated by Limitorque as being installed and received

, by AP&L. We fully expect the same type of wiring will be found in

] ANO-1 actuators. Limitorque has tested a variety of operator j configurations over a long period of time as reported in B0058. The

l earlier tests undoubtedly included this type of internal wire.

l Additional supporting qualification information on PVC wire insulation 4

is provided in NEL-076-52.

j A recent inventory walkdown of all Q and non-Q wire and cable identified only qualified SIS wire'(Rockbastos Firewall) in stock.

AP&L only installed qualified SIS wire during maintenance activities on these devices. However, AP&L will be inspecting these operators during the upcoming refueling outage. Any internal parts whose qualification cannot be positively established will be replaced with qualified parts.

This justification is provided in accordance with 10CFR50.49 section (i), item (2) which permits partial type testing and additional data to support previous qualification testing.

4

26 Revised 7/22/86

, . . , , , - , . . ,,-..n - . . - , - . . , - . . - - . - - - - - , . . , , _ . , , . , , . , , - . ,, , , - . . - . - - - - . . . ,

EQUIPMENT ENVIRONMENTAL QUALIFICATION JUSTIFICATION FOR INTERIM OPERATION ANO-1 COMPONENT: Motor Operators TAG N0(S): CV-2620, CV-2626 MANUFACTURER AND MODEL N0: Limitorque SMB-000, SMB-00 SYSTEM - P&ID N0: Emergency Feedwater/M-204 LOCATION: Room 46, Elevation 335'

• SAFETY FUNCTION:

These devices are normally open and close to isolate EFW from a depressurized steam generator following a main feedwater line break or main steam line break in response to a MSLI signal from EFIC.

• QUALIFICATION DISCREPANCY:

Internal MOV wiring or terminal blocks have not been identified.

JUSTIFICATION FOR INTERIM OPERATION:

For all MSLB's and inside containment MFWLB's these devices perform their safety function in a mild environment. For a MFWLB upstream of the MFW check valves (FW-7A, FW-78) steam generator isolation is accomplished by the MFW chack valves and no EFW isolation is required.

For breaks between the MFW check valves and their associated containment penetrations, a steam environment results during which the valve feeding the affected steam generator should be closed.

Once closed they are not required to reopen and no credible failure associated with internal wiring or terminal blocks can cause a closed motor operator to open inadvertently.

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27 Revised 7/22/86

Additionally the plant operators would not be mislead by failure of control circuits after closing as other indications of successful isolation and other qualified isolation means are not adversely affected by the environment or the postulated control circuit failure.

Specifically flow may be terminated through either valve by closing its redundant upstream isolation valve (not motor operated) or tripping its associated EFW pump. Confirmation of cessation of flow is accomplished by environmentally qualified valve position for the former and/or environmentally qualified loop flow indication for either method.

No known failure mode associated with internal wiring or terminal blocks can cause an open motor operator to close inadvertently. Since the conductors necessary to initiate actuation of a motor operator (s) are not present in the motor operator limit switch compartment, no failure of internal wiring or terminal blocks (short circuit, short to ground or hot shorts) can cause repositioning of the valves.

These devices were purchased in 1982 and installed in 1984.

• Information from Limitorque indicates that qualified internal wiring and terminal blocks were furnished by Limitorque. During this period, AP&L has only used qualified rockbestos SIS wire for rewiring of Limitorque control circuits. This environment is due to a postulated critical crack which results in a 214 F 0.7 PSIG small steam environment. The size of the break is such that manual action is, required to isolate it and no automatic trip of RPS or EFIC is expected. Therefore these valves are considered capable of performing their safety function.

Notwithstanding the above arguments, AP&L considers these valves operable and qualified based on previous qualification testing performed by the manufacturer. We have examined internal wiring removed from similar devices on ANO-2 and have determined that the internal interconnecting wires were PVC in accordance with the CSA specifications as stated by Limitorque as being installed and received by AP&L. We fully expect the same type of wiring will be found in ANO-1 actuators. Limitorque has tested a variety of operator configurations over a long period of time as reported in B0058. The earlier tests undoubtedly included this type of internal wire.

Additional supporting qualification information on PVC wi.'e insulation i; provided in NEL-076-52.

A recent inventory walkdown of all Q and non-Q wire and cable identified only qualified SIS wire (Rockbestos Firewall) in stock.

AP&L only installed qualified SIS wire during maintenance activities on these devices. However, AP&L will be inspecting these operators during the upcoming refueling outage. Any internal parts whose qualification cannot be positively established will be replaced with qualified parts.

This justification is provided in accordance with 10CFR50.49 section (i), item (2) which permits partial type testing and additional data to support previous qualification testing.

28 Revised 7/22/86 I

EQUIPMENT ENVIRONMENTAL QUALIFICATION JUSTIFICATION FOR INTERIM OPERATION ANO-1 COMPONENT: Motor Operators TAG N0(S): CV-2627, CV-2670 MANUFACTURER AND MODEL NO: Limitorque SMB-000, SMB-00 SYSTEM - P&ID NO: Emergency Feedwater/M-204 LOCATION: Room 79, Elevation 354

+ SAFETY FUNCTION:

These devices are normally open and close to isolate EFW from a depressurized steam generator following a main feedwater line break or main steam line break.

QUALIFICATION DISCREPANCY:

Internal MOV wiring or terminal blocks have not been identified.

JUSTIFICATION FOR INTERIM OPERATION:

The only harsh steam environment to which these devices are exposed is an RCS letdown line break. The valves are normally open and are not required to isolate the steam generators by closing for a letdown line break.

The unly harsh radiatlun environment to which these valves are exposed results from LOCA recirculation. These devices are normally open and are not required to isolate the steam generators by closing for a LOCA.

Therefore, these devices are normally open and are not required to close except in a mild environment. No known failure mode associated with internal wiring or terminal blocks can cause an open motor operator to close inadvertently. Since the conductors necessary to initiate actuation of a motor operator (s) are not present in the motor operator limit switch compartment, no failure of internal wiring or terminal blocks (short circuit, short to ground or hot shorts) can cause repositioning of the valves, i I

29 Revised 7/22/86

Erroneous indication or the lack of indication, would not cause the operator to take improper action (e.g. , for an erroneous close indication the operator may attempt to open the valve; this would have no deleterous effect on the valve or valve operator).

Notwithstanding the above arguments, AP&L considers these valves operable and qualified based on previous qualification testing performed by the manufacturer. We have examined internal wiring removed from similar devices on ANO-2 and have determined that the internal interconnecting wires were PVC in accordance with the CSA specifications as stated by Limitorque as being installed and received by AP&L. We fully expect the same type of wiring will be found in ANO-1 actuators. Limitorque has tested a variety of operator configurations over a long period of time as reported in B0058. The earlier tests undoubtedly included this type of internal wire.

Additional supporting qualification information on PVC wire insulation is provided in NEL-076-52.

A recent inventory walkdown of all Q and non-Q wire and cable identified only qualified SIS wire (Rockbestos Firewall) in stock.

AP&L only installed qualified SIS wire during maintenance activities on these devices. However, AP&L will be inspecting these operators during the upcoming refueling outage. Any internal parts whose qualification cannot be positively established will be replaced with qualified parts.

This justification is provided in accordance with 10CFR50.49 section (i), item (2) which permits partial type testing and additional data to support previous qualification testing.

)

1 30 Revised 7/22/86

)

I I

EQUIPMENT ENVIRONMENTAL QUALIFICATION JUSTIFICATION FOR INTERIM OPERATION I ANO-1 d

I COMPONENT: Motor Operators TAG N0(S): CV-2617, CV-2667 4

MANUFACTURER AND MODEL N0: Limitorque SMB-000 l

SYSTEM - P&ID N0: Steam Generator Secondary /M-206 l LOCATION: Room 170, Elevator 404 i

I

• SAFETY FUNCTION:

These devices are normally open and are manually closed to isolate the contaminated steam generator in a tube leak scenario. t I

• QUALIFICATION DISCREPANCY:

l Internal MOV wiring or terminal blocks have not been identified.

4

• JUSTIFICATION FOR INTERIM OPERATION:

i Since the addition of downstream check valves MS-271 and MS-272 which isolate a depressurized steam generator from the EFW turbine supply,

these devices are not required to close in a harsh environment.

) These devices are used to isolate a contaminated steam generator in a

! tube leak scenario in order to minimize releases to atmosphere through I the EFW turbine exhaust and unnecessary contamination of downstream l piping and equipment. This is a manual function and is not performed '

l.

in a harsh environment.

1 Therefore, these devices are normally open and are not required to-  !

) close except in a mild environment. No known failure mode associated I

with internal wiring can cause an open motor operator to close j inadvertently. Since the conductors necessary to initiate actuation of

a motor operator (s) are not present in the motor operator limit switch compartment, no failure of internal wiring or terminal blocks (short I circuit, short to ground or hot shorts) can cause repositioning of the j valves.

31 Revised 7/22/86 i

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Erroneous indication or the lack of indication, would not cause the operator to take improper action (e.g. , for an erroneous close indication the operator may attempt to open the valve; this would have no deleterous effect on the valve or valve operator).

Notwithstanding the above arguments, AP&L considers these valves operable and qualified based on previous qualification testing performed by the manufacturer. We have examined internal wiring removed from similar devices on ANO-2 and have determined that the internal interconnecting wires were PVC in accordance with the CSA specifications as stated by Limitorque as being installed and received by AP&L. We fully expect the same type of wiring will be found in ANO-1 actuators. Limitorque has tested a variety of operator configurations over a long period of time as reported in B0058. The earlier tests undoubtedly included this type of internal wire.

Additional supporting qualification information on PVC wire insulation is provided in NEL-076-52.

A recent inventory walkdown of all Q and non-Q wire and cable identified only qualified SIS wire (Rockbestos Firewall) in stock.

AP&L only installed qualified SIS wire during maintenance activities on these devices. However, AP&L will be inspecting these operators during the upcoming refueling outage. Any internal parts whose qualification cannot be positively established will be replaced with qualified parts.

This justification is provided in accordance with 10CFR50.49 section

, (i), item (2) which permits partial type testing and additional data to support previous qualification testing.

32 Revised 7/22/86

"4 EQUIPMENT ENVIRONMENTAL QUALIFICATION JUSTIFICATION FOR INTERIM OPERATION ANO-1 COMPONENT: Motor Operators TAG N0(S): CV-1214, CV-1216 MANUFACTURER AND MODEL N0: Limitorque SMB Series SYSTEM - P&ID NO: Makeup and Purification /M-231 LOCATION: Reactor Building

• SAFETY FUNCTION:

These valves are the Letdown Cooler Discharge Isolation Valves. They are normally open and receive engineering safeguards (ES) signals to close (i.e., isolate containment) as required.

• QUALIFICATION DISCREPANCY:

Internal MOV wiring or terminal blocks have not been identified.

• JUSTIFICATION FOR INTERIM OPERATION:

These devices are required only to provide a containment isolation safety function and are not required to reopen for any other safety-related function. Initiation signals are based upon either low RCS pressure or high reactor building pressure, indicative of LOCA or steam line breaks inside containment. Because the devices' actual required operating times are approximately one minute, the actual exposure to harsh conditions is considered too short to induce failure.

This is based on several considerations such as generic wiring inherent capabilities (irrespective of specific insulation formulation), thermal lag within limit switch compartment, etc. Since the conductors necessary to initiate actuation of a motor operator (s) are not present in the motor operator limit switch compartment, no failure of internal wiring or terminal blocks (short circuit, short to ground or hot shorts) can cause repositioning of the valves.

33 Revised 7/22/86

1 In the event of an ES actuation these isolation valves will receive a close signal. Step 1 in the ESAS tab of procedure 1202.01 requires the verification of proper actuation. This step would normally be performed within a few minutes of any event which would expose these valves to any type of harsh environment. Recovery activities by the operator would not require the further operation of these valves.

Subsequent erroneous indication or the lack of indication, would not cause the operator to take improper action (e.g., for an erroneous open indication the operator may attempt to close the valve; this would have no deleterious effect on the valve or valve operator).

Notwithstanding the above arguments, AP&L considers these valves operable and qualified based on previous qualification testing performed by the manufacturer. We have examined internal wiring removed from similar devices on ANO-2 and have determined that the internal interconnecting wires were PVC in accordance with the CSA specifications as stated by Limiterque as being installed and received by AP&L. We fully expect the same type of wiring will be found in ANO-1 actuators. Limitorque has tested a variety of operator configurations over a long period of time as reported in 80058. The earlier tests undoubtedly included this type of internal wire.

Additional supporting qualification information on PVC wire insulation is provided in NEL-076-52. )

A recent inventory walkdown of all Q and non-Q wire and cable identified only qualified SIS wire (Rockbestos Firewall) in stock.

AP&L only installed qualified SIS wire during maintenance activities on these devices. However, AP&L will be inspecting these operators during the upcoming refueling outage. Any internal parts whose qualification cannot be positively established will be replaced with qualified parts.

This justification is provided in accordance with 10CFR50.49 section (i), item (2) which permits partial type testing and additional data to support previous qualification testing.

34 Revised 7/22/86

1  !

EQUIPMENT ENVIRONMENTAL QUALIFICATION JUSTIFICATION FOR INTERIM OPERATION ANO-1 COMPONENT: Motor Operators l TAG N0(S): CV-1053, CV-1054 MANUFACTURER AND MODEL NO: Limitorque SMB Series 1

SYSTEM - P&ID NO: Reactor Coolant /M-230

} LOCATION: Reactor Building

• SAFETY FUNCTION:

These devices are the RC Quench Tank and Quench Tank Sample Isolation j i Valves. They are rormally closed and receive engineering safeguards <

(ES) signals to close (i.e., isolate containment) as required.

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• QUALIFICATION DISCREPANCY:

l l j Internal MOV wiring or terminal blocks have not been identified.

i

• JUSTIFICATION FOR INTERIM OPERATION:

These devices are required only to provide a containment isolation safety function and are not required to reopen for any other i safety related function. Initiation signals are based upon either low i

! RCS pressure or high reactor building pressure, indicative of LOCA or

{ steam line breaks inside containment. Because the devices' actual i required operating times are approximately one minute, the actual i

exposure to harsh conditions is considered too short to induce failure

' in the internal wiring. This is based on several considerations such as generic wiring, inherent capabilities (irrespective of specific i insulation formulation), thermal lag within limit switch compartment, I etc. . Since the conductors necessary to initiate actuation of a motor j operator (s) are not present in the motor operator limit switch j

compartment, no failure of internal wiring or terminal blocks (short j circuit, short to ground or hot shorts) can cause repositioning of the

! valves.

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35 Revised 7/22/86 t.

k In the event of an ES actuation these isolation m .es will receive a close signal. Step 1 in the ESAS tab of procedure 1202.01 requires the verification of proper actuation. This step would normally be performed within a few minutes of any event which would expose these valves to any type of harsh environment. Recovery activities by the operator would not require the further operation of these valves.

Subsequent erroneous indication or the lack of indication, would not cause the operator to take improper action (e.g., for an erroneous open indication the operator may attempt to close the valve; this would have no deleterious effect on the valve or valve operator). Additionally, there is a redundant qualified isolation valve in series outside containment.

Notwithstanding the above arguments, AP&L considers these valves operable and qualified based on previous qualification testing performed by the manufacturer. We have examined internal wiring removed from similar devices on ANO-2 and have determined that the internal interconnecting wires were PVC in accordance with the CSA specifications as stated by Limitorque as being installed and received by AP&L. We fully expect the same type of wiring will be found in ANO-1 actuators. Limitorque has tested a variety of operator configurations over a long period of time as reported in B0058. The earlier tests undoubtedly included this type of internal wire.

Additional supporting qualification information on PVC wire insulation is provided in NEL-076-52.

A recent inventory walkdown of all Q and non-Q wire and cable identified only qualified SIS wire (Rockbestos Firewall) in stock.

AP&L only installed qualified SIS wire during maintenance activities on these devices. However, AP&L will be inspecting these operators during the upcoming refueling outage. Any internal parts whose qualification cannot be positively established will be replaced with qualified parts.

This justification is provided in accordance with 10CFR50.49 section (i), item (2) which permits partial type testing and additional data to support previous qualification testing.

36 Revised 7/22/86

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EQUIPMENT ENVIRONMENTAL QUALIFICATION JUSTIFICATION FOR INTERIM OPERATION l

] ANO-1 l

j COMPONENT: Motor Operators - Sampling Lines I

i j TAG N0(S): CV-1820, CV-1826 i

{ MANUFACTURER AND MODEL N0: Limitorque SMB Series SYSTEM - P&ID N0: M-237, Sampling i LOCATION: Reactor Building i

j

• SAFETY FUNCTION:

I i

These valves are the Steam Generator Sample Isolation Valves. They are i required to isolate sampling lines which penetrate containment. They j are normally closed. They may be reopened for sampling purposes at a later time following the accident, i

1

• QUALIFICATION DISCREPANCY:

i J

! Internal MOV wiring or terminal blocks have not been identified.

I l

• JUSTIFICATION FOR INTERIM OPERATION:

h j These devices are normally closed during power operation and would, j therefore, be in their required position (provided sampling was not in

progress) at the initiation of an accident. The sampling function is i not considered essential; therefore, any postulated failure of internal

! wiring would not compromise the devices safety function. Since the conductors necessary to initiate actuation of a motor operator (s) are not present in the motor operator limit switch compartment, no failure of internal wiring or terminal blocks (short circuit, short to ground

)1 or hot shorts) can cause repositioning of the valves.

J Erroneous indication or the lack of indication, would not cause the

operator to take improper action (e.g. , for an erroneous open indication the operator may attempt to close the valve; this would have no deleterous effect on the valve or valve operator).

) 37 Revised 7/22/86 i

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a s Notwithstanding the above arguments, AP&L considers these valves operable and qualified based on previous qualification testing performed by the manufacturer. We have examined internal wiring removed from similar devices on ANO-2 and have determined that the internal interconnecting wires were PVC in accordance with the CSA specifications as stated by Limitorque as being installed and received by AP&L. We fully expect the same type of wiring will be found in ANO-1 actuators. Limitorque has tested a variety of operator configurations over a long period of time as reported in B0058. The earlier tests undoubtedly included this type of internal wire.

Additional supporting qualification information on PVC wire insulation

• is provided in NEL-076-52.

A recent inventory walkdown of all Q and non-Q wire and cable identified only qualified SIS wire (Rockbestos Firewall) in stock.

AP&L only installed qualified SIS wire during maintenance activities on-these devices. However, ~AP&L will be inspecting these operators during the upcoming refueling outage. Any internal parts whose qualification cannot be positively established will be replaced with qualified parts.

This justification is provided in accordance with 10CFR50.49 section (i), item (2) which permits partial type testing and additional data to support previous qualification testing.

38 Revised 7/22/86

EQUIPMENT ENVIRONMENTAL QUALIFICATION JUSTIFICATION FOR INTERIM OPERATION ANO-1 COMPONENT: Motor Operators - Sampling Lines TAG N0(S): CV-1814, CV-1816 MANUFACTURER AND MODEL NO: Limitorque SMB Series SYSTEM - P&ID NO: M-237, Sampling LOCATION: Reactor Building

• SAFETY FUNCTION:

l These valves are the pressuri'zer gas and liquid space sample isolation valves They are required to isolate sampling lines which penetrate containment. They are normally closed. PASS provides for post accident sampling. . There should be no need for the valves to be reopened for sampling purposes time following an accident.

QUALIFICATION DISCREPANCY:

Internal MOV wiriig or terminal blocks have not been identified.

t JUSTIFICATION FOR INTERIM OPERATION:

These devices are normally closed (unless sampling is in progress) during power operation and would, therefore, be in their required position at the initiation of an accident. The sampling function is not considered essential; therefore, any postulated failure of internal wiring would not compromise the devices safety function. Since the conductors necessary to initiate actuation of a motor operator (s) are not present in the motor operator limit switch compartment, no failure of internal wiring or terminal blocks (short circuit, short to ground or hot shorts) can cause repositioning of the valves.

Erroneous indication or the lack of indication, would not cause the operator to take improper action (e.g. , for an erroneous open l indication the operator may attempt to close the valve; this would have no deleterous effect on the valve or valve operator).

09 Revised 7/27/86

e Notwithstanding the above arguments, AP&L considers these valves operable and qualified based on previous qualification testing performed by the manufacturer. We have examined internal wiring removed from similar devices on ANO-2 and have determined that the internal interconnecting wires were PVC in accordance with the CSA specifications as stated by Limitorque as being installed and received by AP&L. We fully expect the same type of wiring will be found in ANO-1 actuators. Limitorque has tested a variety of operator configurations over a long period of time as reported in B0058. The earlier tests undoubtedly included this type of internal wire.

Additional supporting qualification information on PVC wire insulation is provided in NEL-076-52.

A recent inventory walkdown of all Q and non-Q wire and cable identified only qualified SIS wire (Rockbestos Firewall) in stock.

AP&L only installed qualified SIS wire during maintenance activities on

~

these devices. However, AP&L will be inspecting these operators during the upcoming refueling outage. Any internal parts whose qualification cannot be positively established will be replaced with qualified parts.

This justification is provided in accordance with 10CFR50.49 section (i), item (2) which permits partial type testing and additional data to support previous qualification testing.

40 Revised 7/22/86

. N O

• EQUIPMENTENVIRONMENTALQUALfFICATION JUSTIFICATION FOR INTERIM OPERATION ANO-1 COMPONENT: Core Flood Tank Isolation Valve Motor Operators TAG N0(S): CV-2415, CV-2419 MANUFACTURER AND MODEL NO: Limitorque SMB Series SYSTEM - P&ID N0: M-236 Core Flood I LOCATION: Reactor Building

• SAFETY FUNCTION:

CV-2415 and CV-2419 are required to be open to ensure core flood capabilities following the full spectrum of LOCAs.

e QUALIFICATION DISCREPANCY:

Internal M0V wiring or terminal blocks have not been identified.

'4 en

• JUSTIFICATION FOR INTERIM OPERATION:

CV-2415 and CV-2419 are ensured in their safe position by administrative controls, alarms, and interlocks. Therefore, failure of internal wiring could not jeopardize their required function to be open (power is removed from tha valves during normal operation).

• The only operator action required per 1202.01 is the closure of CV-2415 and CV-2419 following core flood tank discharge. Per B&W analysis in support of the E0P development this step is not required to comply with the Safety Analysis; however, their closure is recommended. Position indication is provided independent of the motor operator.

Notwithstanding the above arguments, AP&L considers these valves operable and qualified based on previous qualification testing performed by the manufacturer. We have examined internal wiring removed from similar devices on ANO-2 and have determined that the internal interconnecting wires were PVC in accordance with the CSA 41 Revised 7/22/86

" specifications as stated by Limitorque as being installed and received

, .by AP&L. We fully expect the same type of wiring will be found in ANO-1 actuators. Limitorque has tested a variety of operator configurations over a long period of time as reported in B0058. The earlier tests undoubtedly included this type of internal wire.

Additional supporting qualification information on PVC wire insulation is provided in NEL-076-52. .

A recent inventory walkdown of all Q and non-Q wire and cable identified only qualified SIS wire (Rockbestos Firewall) in stock.

AP&L only installed qualified SIS wire during maintenance activities on these devices. However, AP&L will be inspecting these operators during the upcoming refueling outage. Any internal parts whose qualification cannot be positively established will be replaced with qualified parts.

This justification is provided in accordance with 10CFR50.49 section (i), item (2) which permits partial type testing and additional data to support previous qualification testing.

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i 42 Revised 7/22/86 l

EQUIPMENT ENVIRONMENTAL QUALIFICATION ,

JUSTIFICATION FOR INTERIM OPERATION ANO-1 COMPONENT: Core Flood Tank Drain Valve Motor Operators TAG N0(S): CV-2416, CV-2418 MANUFACTURER AND MODEL NO: Limitorque SMB Series SYSTEM - P&ID NO: M-236 Core Flood LOCATION: Reactor Building. .

• -SAFETY FUNCTION:

CV-2416 and CV-2418 are on drain lines which provide containment isolation and are required to be closed. *

• QUALIFICATION DISCREPANCY:

Internal MOV wiring or terminal blocks have not been identified.

• JUSTIFICATION FOR INTERIM OPERATION:

CV-2416 and CV-2418 are normally closed during power operation and are not required to be opened subsequent to an accident. These devices are on the list because of the desire to have position indication available (Regulatory Guide 1.97 variables). Since tne conductors necessary to initiate actuation of a motor operator (s) are not present in the motor operator limit switch compartment, no failure of internal wiring or terminal blocks (short circuit, short to ground or hot shorts) can cause repositioning of the valves.

Erroneous indication or the lack of indication, would not cause the operator to take improper action (e.g., for an erroneous open indication the operator may attempt to close the valve; this would have  ;

no deleterous effect on the valve or valve operator). j 43 Revised 7/22/86

4 t

Notwithstanding the above arguments, AP&L considers these valves

operable and qualified based on previous qualification testing performed by the manufacturer. We have examined internal wiring i removed from similar devices on ANO-2 and have determined that the internal interconnecting wires were PVC in accordance with the CSA specifications as stated by Limitorque as being installed and received by AP&L. We fully expect the same type of wiring will be found in

} ANO-1 actuators. Limitorque has tested a variety of operator configurations over a long period of time as reported in B0058. The earlier tests undoubtedly included this type of internal wire.

Additional supporting qualification information on PVC wire insulation j is provided in NEL-076-52.

I A recent inventory walkdown of all Q and non-Q wire and cable identified only qualified SIS wire (Rockbestos Firewall) in stock.

AP&L only installed qualified SIS wire during maintenance activities on j these devices. However, AP&L will be inspecting these operators during the upcoming refueling outage. Any internal parts whose qualification

cannot be positively established will be replaced with qualified parts.

This justification is provided in accordance with 10CFR50.49 section (i), item (2) which permits partial type testing and additional data to support previous qualification testing.

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44 Revised 7/22/86 i

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y ,m .,&. .-w.w.-------,--,-..m, , , , ,, . . - - - , . . . ~ - - - , ym,, , _ - , . - , - + . , - - ,e.% --w.qmm--g= .,,-,-w-my-

EQUIPMENT ENVIRONMENTAL QUALIFICATION JUSTIFICATION FOR INTERIM OPERATION ANO-1 COMPONENT: R8 Coolers Backdraft Damper MOVs TAG N0(S): CV-7470, CV-7471, CV-7472, CV-7473 MANUFACTURER AND MODEL NO: Limitorque SM8 Series SYSTEM - P&ID N0: M-261 LOCATION: Reactor Building

• SAFETY FUNCTION:

These devices are locked open during plant operation.

-l QUALIFICATION DISCREPANCY:

Internal MOV wiring or terminal blocks have not been identified.

JUSTIFICATION FOR INTERIM OPERATION:

These f10Vs were recently purchased and installed (after 1980) and l should, therefore, contain qualified Rockbestos internal wiring.

These valves are de energized, locked open', and maintained in this '

position by administrative controls (category 'E' locked valve list).

Position indication is not considered essential. Since the conductors necessary to initiate actuation of a motor operator (s) are not present in the motor operator limit switch compartment, no failure of internal wiring or terminal blocks (short circuit, short to ground or hot shorts) can cause repositioning of the valves.

Erroneous indication or the lack of indication, would not cause the operator to take improper action (e.g. , for an erroneous open I indication the operator may attempt to close the valve; this would have no deleterous effect on the valve or valve operator).

45 Revised 7/22/86

4 Notwithstanding the above arguments, AP&L considers these valves

operable and qualified based on previous qualification testing performed by the manufacturer. We have examined internal wiring

' removed from similar devices on ANO-2 and have determined that the internal interconnecting wires were PVC in accordance with the CSA

, specifications-as stated by Limitorque as being installed and received by AP&L. We fully expect the same type of wiring will be found in ANO-1 actuators. Limitorque has tested a variety of operator configurations over a long period of time as reported in B0058. The earlier tests undoubtedly included this type of internal wire.

Additional supporting qualification information on PVC wire insulation

! is provided in NEL-076-52.

r A recent inventory walkdown of all Q and non-Q wire and cable identified only qualified SIS wire (Rockbestos Firewall) in stock.

AP&L only installed qualified SIS wire during maintenance activities on j these devices. However, AP&L will be inspecting these operators during the upcoming refueling outage. Any internal parts whose qualification cannot be positively established will be replaced with qualified parts.

This justification is provided in accordance with 10CFR50.49 section (i), item (2) which permits partial type testing and additional data to

support previous qualification testing.

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46 Revised 7/22/86

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EQUIPMENT ENVIRONMENTAL QUALIFICATION JUSTIFICATION FOR INTERIM OPERATION ANO-1 COMPONENT: Hydrogen Purge System Motor Operators TAG N0(S): CV-7444, CV-7446, CV-7448, CV-7450 MANUFACTURER AND MODEL NO: Limitorque SMB Series SYSTEM - P&ID NO: M-261, Containment HVAC t

LOCATION: Reactor Building

• SAFETY FUNCTION:

These valves are the RB Hydrogen Purge System Air Inlet and Outlet isolation valves. In the event of a LOCA, they are opened as needed for sampling or hydrogen purge operations.

• QUALIFICATION DISCREPANCY:

Internal MOV wiring or terminal blocks have not been identified.

• JUSTIFICATION FOR INTERIM OPERATION:

CV-7444, CV-7448 and CV-7450 are normally closed; CV-7446 is normally open, but receives an ES signal (Channel 3) to close as required.

CV-7446 will be reopened after the initiation of ES to permit sampling.

The valve will be maintained in the open position throughout the accident for Hydrogen sampling. Containment isolation is maintained by the redundant outboard isolation valves which are located in a mild environment. Since the conductors necessary to initiate actuation of a motor operator (s) are not present in the motor operator limit switch compartment, no failure of internal wiring or termina,1 blocks (s'hort circuit, short to ground or hot shorts) can cause repositioning of the valves.

47 Revised 7/22/86 -

,~ . .

1 In the event of an ES actuation these isolation valves will receive a close signal. Erroneous indication or the lack of indication, would not cause the operator to take improper action (e.g. , for an erroneous open indication the operator may attempt to close the valve; this would have no deleterous effect on the valve or valve operator). Should-indication of valve position be lost and these valves be required to function, the operators could verify their actuation by flow indication, hydrogen concentration trends, and radiation monitor readings in the purge path. '

Notwithstanding the above arguments, AP&L considers these valves operable and qualified based on previous qualification testing performed by the manufacturer. We have examined internal wiring removed from similar devices on ANO-2 and have determined that the internal interconnecting wires were PVC in accordance with the CSA specifications as stated by Limitorque as being installed and received 1

by AP&L. We fully expect the same type of wiring will be found in I ANO-1 actuators. Limitorque has tested a variety of operator j configurations over a long period of time as reported in B0058. The earlier tests undoubtedly included this type of internal wire.

Additional supporting qualification information on PVC wire insulation

• is provided in NEL-076-52.

I A recent inventory walkdown of all Q and non-Q wire and cable i identified only qualified SIS wire (Rockbestos Firewall) in stock.

'. AP&L only installed qualified SIS wire during maintenance activities on these devices. However, AP&L will be inspecting these operators during

! the upcoming refueling outage. Any internal parts whose qualification cannot be positively established will be replaced with qualified parts.

This justification is provided in accordance with 10CFR50.49 section

! (i), item (2) which permits partial type testing and additional da'ta to 1

support previous qualification testing.

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48 Revised 7/22/86

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

EQUIPMENT ENVIRONMENTAL QUALIFICATION JUSTIFICATION FOR INTERIM OPERATION ANO-1 COMPONENT: Motor Operators TAG N0(S): CV-1270, CV-1271, CV-1272, CV-1273 MANUFACTURER AND MODEL NO: Limitorque SMB Series SYSTEM - P&ID NO: Makeup and Purification /M-231 LOCATION: Reactor Building

• SAFETY FUNCTION:

These valves are the RCP Seal Bleedoff Isolation Valves. They are normally open and they receive engineering safeguards signals to close (i.e isolation s containment) as required.

QUALIFICATION DISCREPANCY:

Internal MOV wiring or terminal blocks have not been identified.

JUSTIFICATION FOR INTERIM OPERATION:

These devices are required only to provide a containment isolation safety function and are not required to open for any other safety-related function. Initiation signals are based upon either low RCS pressure or high reactor building pressure, indicative of LOCA or steam line breaks inside containment. Because the devices' actual required operating times are approximately one minute, the actual exposure to harsh conditions is considered too short to induce failure in the internal wiring. This is based on several considerations such as generic wiring, inherent capabilities (irrespective of specific insulation formulation), thermal lag within limit switch compartment, etc. Since the conductors necessary to initiate actuation of a motor operator (s) are not present in the mota: operator limit switch compartment, no failure of internal wiring or terminal blocks (short circuit, short to ground or hot shorts) can cause repositioning of the valves.

49 Revised 7/22/86

In the event of an ES actuation these isolation valves will receive a 4

close. signal. Step 1 in the ESAS tab of procedure 1202.01 requires the verification ~of proper actuation. This step would normally be performed within a few minutes of any event which would expose these valves to any type of harsh environment. Recovery activities by the operator would not require the further operation of these valves.

Subsequent erroneous indication or the . lack of indication, would not cause the operator to take improper action.(e.g., for an erroneous open indication the operator may attempt to close the valve; this would have no deleterious effect on the valve or valve operator).

i Notwithstanding the above arguments, AP&L considers these valves operable and qualified based on previous qualification testing performed by the manufacturer. We have examined internal wiring removed from similar devices on ANO-2 and have determined that the internal interconnecting wires were PVC in accordance with the CSA specifications as stated by Limitorque as being installed and received by AP&L. We fully expect the same type of wiring will be found in ANO-1 actuators. Limitorque has tested a variety of operator configurations over a long period of time as reported in B0058. The earlier tests undoubtedly included this type of internal wire.

Additional supporting qualification information on PVC wire insulation is provided in NEL-076-52.

A recent inventory walkdown of all Q and non-Q wire and cable identified only qualified SIS wire (Rockbestos Firewall) in stock.

AP&L only installed qualified SIS wire during maintenance activities on these devices. However, AP&L will be inspecting these operators during the upcoming refueling outage. Any internal parts whose qualification cannot be positively established will be replaced with qualified parts.

This justification is provided in accordance with 10CFR50.49 section (i), item (2) which permits partial type testing and additional data to support previous qualification testing.

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l 50 Revised 7/22/86

EQUIPMENT ENVIRONMENTAL QUALIFICATION JUSTIFICATION FOR INTERIM OPERATION I

ANO-1 COMPONENT: Motor Operators ,

TAG N0(S): CV-2215, CV-2221 MANUFACTURER AND MODEL N0: Limitorque SMB Series SYSTEM - P&ID NO: Reactor Coolant /M-230 LOCATION: Reactor Building 4 SAFETY FUNCTION: These valves are the Letdown Cooler Isolation and CRD/RCP Cooling Water Isolation Valves. These devices are normally open and receive engineering safeguards ES signals to close (i.e.

isolate containment) as required.

• QUALIFICATION DISCREPANCY: Internal MOV wiring or terminal blocks have not been identified.

• JUSTIFICATION FOR INTFRIM OPERATION: These devices are required only to provide a containment isolation safety function and are not required to reopen for any other safety-related function. Initiation signals are based upon either low RCS pressure or high reactor building .

pressure, indicative of LOCA or steam line breaks inside containment.

Because the devices' actual required operating times are approximately one minute, the actual exposure to harsh conditions is considered too short to induce failure in the internal wiring. This is based on

- ~

' several considerations such as generic wiring, inherent capabilities (irrespective of specific insulation formulation), thermal lag within limit switch compartment, etc.

Since the conductors necessary to initiate actuation of a motor operator (s) are not present in the motor operator limit switch compartment, no failure of internal wiring or termin91 blocks (short circuit, short to ground or hot shorts) can cause repositioning of the valves.

51 Revised 7/22/86

4 In the event of an ES actuation these isolation valves will receive a close signal. Step 1 in the ESAS tab of procedure 1202.01 requires the verification of proper actuation. This step would normally be performed within a few minutes of any event which would expose these valves to any type of harsn environment. Recovery activities by the operator would not require the further operation of these valves.

Subsequent erroneous indication or the lack of indication, would not cause the operator to take improper action (e.g., for an erroneous close indication the operator may attempt to open the valve; this would have no deleterious effect on the valve or valve operator).

Additionally, there is a redundant qualified isolation valve in series outside containment.

Notwithstanding the above arguments, AP&L considers these valves operable and qualified based on previous qualification testing performed by the manufacturer. We have examined internal wiring

' removed from similar devices on ANO-2 and have determined that the internal interconnecting wires were PVC in accordance with the CSA specifications as stated by Limitorque as being installed and received by AP&L. We fully expect the same type of wiring will be found in ANO-1 actuators. Limitorque has tested a variety of operator configurations over a long period of time as reported in B0058. The earlier tests undoubtedly included this type of internal wire.

Additional supporting qualification information on PVC wire insulation is provided in NEL-076-52.

A recent inventory walkdown of all Q and non-Q wire and cable identified only qualified SIS wire (Rockbestos Firewall) in stock.

AP&L only installed qualified SIS wire during maintenance activities on these devices. However, AP&L will be inspecting these operators during the upcoming refueling outage. Any internal parts whose qualification cannot be positively established will be replaced with qualified parts.

This justification is provided in accordance with 10CFR50.49 section (i), item (2) which permits partial type testing and additional data to support previous qualification testing.

l 52 Revised 7/22/86 .<

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EQUIPMENT ENVIRONMENTAL QUALIFICATION JUSTIFICATION FOR INTERIM OPERATION ANO-1 COMPONENT: Motor Operator TAG N0(S): CV-4803 MANUFACTURER AND MODEL NO: Limitorque SMB Series SYSTEM - P&ID NO: Gaseous Radioactive Waste /M-215 LOCATION: Reactor Building SAFETY FUNCTION: This valve is the RB Vent Header Isolation Valve. It is normally closed and receives an engineering safeguards signal to close (i.e., isolate containment) as required.

QUALIFICATION DISCREPANCY: Internal MOV wiring or terminal blocks have not been identified.

JUSTIFICATION FOR INTERIM OPERATION: This device is required only to provide a containment isolation safety function and is not required to reopen for any other safety-related function. Initiation signals are j

based upon either low RCS pressure or high reactor building pressure, indicative of LOCA or steam line breaks inside containment. Because the device's actual required operating times are approximately one I minute, the actual exposure to harsh conditions is considered too short to induce failure in the internal wiring. This is based on several considerations such as generic wiring, inherent capabilities (irrespective of specific insulation formulation), thermal lag within limit switch compartment, etc.

Since the conductors necessary to initiate actuation of a motor operator (s) are not present in the motor operator-limit switch compartment, no failure of internal wiring or terminal blocks (short

% circuit, short to ground or hot shorts) can cause repositioning of the .

valve. I 53 Revised 7/22/86

In the event of an ES actuation this isolation valve will receive a close signal. Step 1 in the ESAS tab of procedure 1202.01 requires the verification of proper actuation. This step would normally be performed within a few minutes of any event which would expose this valve to any type of harsh environment. Recovery activities by the t operator would not require the further operation of this valve.

Subsequent erroneous indication or the lack of indication, would not cause the operator to take improper action (e.g., for an erroneous close indication the operator may attempt to open the valve; this would have no deleterious effect on the valve or valve operator).

Additionally, there is a redundant qualified isolation valve in series outside containment.

Notwithstanding the above arguments, AP&L considers this valve operable I and qualified based on previous qualification testing performed by the manufacturer. We have examined internal wiring removed from similar devices on ANO-2 and have determined that the internal interconnecting wires were PVC in accordance with the CSA specifications as stated by' Limitorque as being installed and received by AP&L. We fully expect the same type of wiring will be found in ANO-1 actuators. Limitorque has tested a variety of operator configurations over a long period of time as reported in B0058. The earlier tests undoubtedly included this type of internal wire. Additional supporting qualification information on PVC wire insulation is provided in NEL-076-52.

A recent inventory walkdown of all Q and non-Q wire and cable identified only qualified SIS wire (Rockbestos Firewall) in stock.

AP&L only installed qualified SIS wire during maintenance activities on these devices. However, AP&L will be inspecting these operators during the upcoming refueling outage. Any internal parts whose qualification cannot be positively established will be r'eplaced with qualified parts.

This justification is provided in accordance with 10CFR50.49 section (i), item (2) which permits partial type testing and additional data to support previous qualification testing.

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j 54 Revised 7/22/86 l l

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EQUIPMENT ENVIRONMENTAL QUALIFICATION JUSTIFICATION FOR INTERIM OPERATION ANO-1 COMPONENT: Motor Operator TAG N0(S): CV-6205 MANUFACTURER AND MODEL N0: Limitorque SMB Series SYSTEM - P&ID N0: Chilled Water /M-222 LOCATION: Reactor Building

• SAFETY FUNCTION: This valve is the isolation valve for the chilled water to the RB Coolers. It is normally open and receives an engineering signal to close (i.e., isolate containment) as required.

• QUALIFICATION DISCREPANCY: Internal MOV wiring or terminal blocks have not been identified.

• JUSTIFICATION FOR INTERIM OPERATION: This device is required only to provide a containment isolation safety function and is not required to reopen for any other safety-related function. Initiation signals are based upon either low RCS pressure or high reactor building pressure, indicative of LOCA or steam line breaks inside containment. Because the device's actual required operating time is approximately one I minute, the actual exposure to harsh conditions is considered too short to induce failure in the internal wiring. This is based on several considerations such as generic wiring, inherent capabilities (irrespective of specific insulation formulation), thermal lag within limit switch compartment, etc. .-

Since the conductors necessary to initiate actuation of a motor operator (s) are not present in the motor operator limit switch compartment, no failure of internal wiring or terminal blocks (short circuit, short to ground or hot shorts) can cause repositioning of the valve. I 55 Revised 7/22/86.

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In the event of an ES actuation this isolation valve will receive a close signal. Step 1 in the ESAS tab of procedure 1202.01 requires the verification of proper actuation. This step would normally be performed within a few minutes of any event which would expose this valve to any type of harsh environment. Recovery activities by the operator would not require the further operation of this valve.

Subsequent erroneous indication or the lack of indication, would not cause the operator to take improper action (e.g. , for an erroneous close indication the operator may attempt to open the valve; this would have no deleterious effect on the valve or valve operator).

Additionally, there is a redundant qualified isolation valve in series outside containment.

Notwithstanding the above arguments, AP&L considers this valve operable l and qualified based on previous qualification testing performed by the manufacturer. We have examined internal wiring removed 'from similar devices on ANO-2 and have determined that the internal interconnecting wires were PVC in accordance with the CSA specifications as stated by Limitorque as being installed and received by AP&L. We fully expect the same type of wiring will be found in ANO-1 actuators. Limitorque has tested a variety of operator configurations over a long period of time as reported in B0058. The earlier tests undoubtedly included this type of internal wire. Additional supporting qualification information on PVC wire insulation is provided in NEL-076-52.

A recent inventory walkdown of all Q and non-Q wire and cable identified only qualified SIS wire (Rockbestos Firewall) in stock.

AP&L only installed qualified SIS wire during maintenance activities on these deyices. However, AP&L will be inspecting these operators during the upcoming refueling outage. Any internal parts whose qualification cannot be positively established will be replaced with qualified parts.

This justification is provided in accordance with 10CFR50.49 section (i), item (2) which permits partial type testing and additional data to support previous qualification testing.

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56 Revised 7/22/86 .

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. o EQUIPMENT ENVIRONMENTAL QUALIFICATION JUSTIFICATION FOR INTERIM OPERATION ANO-1 COMPONENT: Motor Operator TAG N0(S): CV-7453 MANUFACTURER AND MODEL NO: Limitorque SMB Series SYSTEM - P&ID N0: HVAC Reactor Building /M-261 LOCATION: Reactor Building

• SAFETY FUNCTION: This valve is the Air Particulate Monitoring System Isolation Valve. It is normally open and receives an engineering-safeguards signal to close (i.e., isolate containment) as required.

QUALIFICATION DISCREPANCY: Internal MOV wiring or terminal blocks have not been identified.

• JUSTIFICATION FOR INTERIM OPERATION: This device is required only to l provide a containment isolation safety function and are not required to reopen for any other safety-related function. Initiation signals are based upon either low RCS pressure or high reactor building pressure, indicative of LOCA or steam line breaks inside containment. Because the device's actual required operating time is approximately one l minute, the actual exposure to harsh conditions is considered too short to induce failure in the internal wiring. This is based on several considerations such as generic wiring, inherent capabilities (irrespective of specific insulation formulation), thermal lag within limit switch compartment, etc.

Since the conductors necessary to initiate actuation of a motor operator (s) are not present in the motor operator limit switch compartment, no failure of internal wiring or terminal blocks (short circuit, short to ground or hot shorts) can cause repositioning of the valve. t i

57 Revised 7/22/86 L

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In the event of an ES actuation this isolation valve will receive a i close signal. Step 1 in the ESAS tab of procedure 1202.01 requires the verification of proper actuation. This step would normally be performed within a few minutes of any event which would expose this valve to any type of. harsh environment. Recovery activities by the operator would not require the further operation of this valve.

Subsequent erroneous indication or the lack of indication, would not cause the operator to take improper action (e.g., for an erroneous close indication the operator may attempt to open the valve; this would have no deleterious effect on the valve or valve operator).

Additionally, there is a redundant qualified isolation valve in series outside containment.

Notwithstanding the above ar0uments, AP&L considers this valve operable ]

and qualified based on previous qualification testing performed by the

, manufacturer. We have examined internal wiring removed from similar <

devices on ANO-2 and have determined that the internal interconnecting wires were PVC in accordance with the CSA specifications as stated by Limitorque as being installed and received by AP&L. We fully expect the same type of wiring will be found in ANO-1 actuators. Limitorque has tested a variety of operator configurations over a long period of j time as reported in B0058. The earlier tests undoubtedly included this type of internal wire. Additional supporting qualification information on PVC wire insulation is provided in NEL-076-52.

, A recent inventory walkdown of all Q and non-Q wire and cable identified only qualified SIS wire (Rockbestos Firewall) in stock.

AP&L only installed qualified SIS wire during maintenance activities on these devices. However, AP&L will be inspecting these operators during  ;

{

the upcoming refueling outage. Any internal parts whose qualification '

cannot be positively established will be replaced with qualified parts.

! This justification is provided in accordance with 10CFR50.49 section 4

(i), item (2) which permits partial type testing and additional data to support previous qualification testing.

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58 Revised 7/22/86 i t

t EQUIPMENT ENVIRONMENTAL QUALIFICATION JUSTIFICATION FOR INTERIM OPERATION ANO-1 COMPONENT: Pressurizer Block Valve MOV TAG N0(S): CV-1000 MANUFACTURER AND MODEL NO: Limitorque SMB Series SYSTEM - P&ID N0: Reactor Coolant, M-230 LOCATION: Reactor Building

• SAFETY FUNCTION: This valve is normally closed and is not required to change position for LOCA or HELB inside containment. Upon manual actuation by control room operators, this device is used to isolate the PORV should it fail open.

• QUALIFICATION DISCREPANCY: Internal MOV wiring or terminal blocks have not been identified.

• JUSTIFICATION FOR INTERIM OPERATION: Even though the actuator is credited for isolating a failed open PORV, ANO-1 has been analyzed for a full spectrum of loss of coolant accidents. The stuck-open PORV is enveloped by the existing accident analysis, therefore, failure to isolate due to internal wiring failure is within the design basis of the plant.

In addition to the PORV Isolation Valve indication the operators also have available to them qualified acoustic monitor indications of leakage from the pressurizer. Should the Block Valve' position indication be lost this monitor would provide indication of potential leakage from the PORV and Block valve. Also available are Quench Tank Parameters and Tail Pipe Temperature.

• Since the conductors necessary to initiate actuation of a rastor l operator (s) are not present in the motor operator limit switch I compartment, no failure of internal wiring or terminal blocks (short circuit, short to ground or hot shorts) can cause repositioning of the valve.

59 Revised 7/22/86

Notwithstanding the above arguments, AP&L considers this valve operable l and qualified based on previous qualification testing performed by the manufacturer. We have examined internal wiring removed from similar devices on ANO-2 and have determined that the internal interconnecting wires were PVC in accordance with the CSA specifications as stated by Limitorque as being installed and received by AP&L. We fully expect the same type of wiring will be found in ANO-1 actuators. Limitorque has tested a variety of operator configurations over a long period of time as reported in B0058. The earlier tests undoubtedly included this type of internal wire. Additional supporting qualification information on PVC wire insulation is provided in NEL-076-52.

A recent inventory walkdown of all Q and non-Q wire and cable identified only qualified SIS wire (Rockbestos Firewall) in stock.

AP&L only installed qualified SIS wire during maintenance activities on this device. However, AP&L will be inspecting these operators auring the upcoming refueling outage. Any internal parts whose qualification cannot be positively established will be replaced with qualified parts.

This justification is provided in accordance with 10CFR50.49 section (i), item (2) which permits partial type testing and additional data to support previous qualification testing.

60 Revised 7/22/86

EQUIPMENT ENVIRONMENTAL QUALIFICATION JUSTIFICATION FOR INTERIM OPERATION ANO-1 COMPONENT: Motor Operators TAG N0(S): CV-7443, CV-7445, CV-7447, CV-7449, (CV-7451, CV-7452)*

• Not actually containment isolation valves. Safety function is to open for Hp purge operation.

MANUFACTURER AND MODEL NO: Limitorque SMB Series SYSTEM - P&ID N0: HVAC Reactor Building /M-261 LOCATION: Upper North and Lower South Pipe Penetration Areas (Rooms 79 and

46) Elevation 360' and 335'

• SAFETY FUNCTION: These valves are normally closed and are required for containment isolation. These valves e e also required to be open later in the accident for hydrogen purge operation.

• QUALIFICATION DISCREPANCY: Internal MOV wiring or terminal blocks have not been identified.

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• JUSTIFICATION FOR INTERIM OPERATION: These valves are normally closed.

They may be reopened within eleven (11) days after the initiation of ES to permit Hydrogen Purge Operation. These valves are continuously in a mild environment.

Since the conductors necessary to initiate actuation of a motor operator (s) are not present in the motor operator limit switch compartment, no failure of internal wiring or terminal blocks (short circuit, short to ground or hot shorts) can cause repositioning of the valves.

1 Erroneous indication or the lack of indication, would not cause the operator to take improper action (e.g., for an erroneous open )

indication the operator may attempt to close the valve; this would have l no deleterous effect on the valve or valve operator). Should indication of valve position be lost and these valves be required to function, the operators could verify their actuation by flow indication, hydrogen concentration trends, and radiation monitor readings in the purge path. l 61 Revised 7/22/86 l l

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V Notwithstanding the above arguments, AP&L considers these valves operable and qualified based on previous qualification testing performed by the manufacturer. We have examined internal wiring removed from similar devices on ANO-2 and have determined that the internal interconnecting wires were PVC in accordance with the CSA specifications as stated by Limitorque as being installed and received by AP&L. We fully expect the same type of wiring will be found in ANO-1 actuators. Limitorque has tested a variety of operator configurations over a long period of time as reported in B0058. The earlier tests undoubtedly included this type of internal wire.

Additional supporting qualification information on PVC wire insulation is provided in NEL-076-52.

A recent inventory walkdown of all Q and non-Q wire and cable identified only qualified SIS wire (Rockbestos Firewall) in stock.

AP&L only installed qualified SIS wire during maintenance activities on these devices. However, AP&L will be inspecting these operators during the upcoming refueling outage. Any internal parts whose qualification cannot be positively established will be replaced with qualified parts.

This justification is provided in accordance with 10CFR50.49 section (i), item (2) which permits partial type testing and additional data to support previous qualification testing.

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62 Revised 7/22/86

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EQUIPMENT ENVIRONMENTAL QUALIFICATION JUSTIFICATION FOR INTERIM OPERATION ANO-1 COMPONENT: Motor Operators TAG N0(S): CV-2630, CV-2680 l MANUFACTURER AND MODEL NO: Limitorque SB-4 P

SYSTEM - P&ID NO: Steam Generator Secondary /M-206 LOCATION: Elev. 354, Room 77

• SAFETY FUNCTION: These devices receive closure signals from EFIC MSLI to isolate MFW from a depressurized steam generator.

• QUALIFICATION DISCREPANCY: Internal MOV wiring and terminal blocks have not been identified.

• JUSTIFICATION FOR INTERIM OPERATION: These devices perform their function in a mild environment for all MSLB's and for MFWLB's inside containment. They are not required to mitigate outside containment MFWLB's. Mitigation of MFWLB's in Room 77 can be accomplished by components located outside the harsh environment caused by the break.

These are closure of the MFW block (CV-2675, CV-2625) valve, the low load block (CV-2674, CV-2624) and the start up control valve (CV-2673, CV-2623), all of which receive diesel backed power and control. Also mitigation may be achieved by tripping the MFW pumps and condensate pumps whose trip functions are powered and controlled by DC from the station batteries.

Therefore these devices perform their function in a mild environment or, other components are available, which are not exposed to the harsh environment in Room 77, to mitigate that particular HELB.

Additionally, the plant operators would not be mislead by failure of control circuits as other indications of successful MFW isolation to the affected steam Generator are available which are not adversely affected by the environment or the postulated control circuit failure.

63 Revised 7/22/86

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7 Notwithstanding the above arguments, AP&L considers these valves operable and qualified based on previous qualification testing performed by the manufacturer. We have examined internal wiring removed from similar devices on ANO-2 and have determined that the internal interconnecting wires were PVC in accordance with the CSA specifications as stated by Limitorque as being installed and received by AP&L. We fully expect the same type of wiring will be found in ANO-1 actuators. Limitorque has tested a variety of operator configurations over a long period of time as reported in B0058. The earlier tests undoubtedly included this type of internal wire.

Additional supporting qualification information on PVC wire insulation is provided in NEL-076-52.

A recent inventory walkdown of all Q and non-Q wire and cable identified only qualified SIS wire (Rockbestos Firewall) in stock.

AP&L only installed qualified SIS wire during maintenance activities on these devices. However, AP&L will be inspecting these operators during the upcoming refueling outage. Any internal parts whose qualification cannot be positively established will be replaced with qualified parts.

This justification is provided in accordance with 10CFR50.49 section (i), item (2) which permits partial type testing and additional data to support previous qualification testing.

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64 Revised 7/22/86

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