ML20215C682

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Audit of Environ Qualification of Safety-Related Electrical Equipment for Clinton Power Station, Informal Rept
ML20215C682
Person / Time
Site: Clinton, 05000000
Issue date: 05/31/1985
From: Beahm D, Fehringer J, Trojovsky M
EG&G IDAHO, INC.
To:
NRC
Shared Package
ML20215C578 List:
References
CON-FIN-A-6415, FOIA-86-367 EGG-EA-6829, NUDOCS 8610100402
Download: ML20215C682 (55)
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Text

EGG-EA-6829

'o MAY 1985 4-AUDIT OF THE ENVIRONMENTAL QUALIFICATION OF SAFETY-RELATED ELECTRICAL EQUIPMENT FOR THE CLINTON POWER STATION D. M. Beahm J. M. Fehringer M. Trojovsky 1

Idaho National Engineering Laboratory Informal Report Operated by the U.S. Department of Energy l

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i' Prepared for the U.S. NUCLEAR REGULATORY COMMISSION Under DOE Contract No. DE-AC07-761D01570 g FIN No. A6415 E 6 g G idano 8610100402 861006 PDR FOIA CONNOR86-367 PDR -

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DISCLAIMER This report was prepared as an account of work sponsored by an agency of the United States Government. Neither the United States Government nor any agency thereof, or any of their employees, makes any warranty, expressed or implied, or assumes any legal liability or responsibility for any third party's use, of any information, apparatus, product or process disclosed in this report or represents that its use by such t$ird party would not infringe privately owned rights.

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t EGG-EA-6829 AUDIT OF THE ENVIRONMENTAL QUALIFICATION OF SAFETY-RELATED ELECTRICAL EQUIPMENT FOR THE CLINTON POWER STATION Oocket No. 50-461 D. M. Beahm J. M. Fehringer M. Trojovsky Published May 1985 NRC Licensing Support Section Engineering Analysis Division EG&G Idaho, Inc.

Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Under DOE Contract No. DE-AC07-76ID01570 FIN No. A6415 1

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t I-ABSTRACT The Clinton Power Station was audited to determine the environmental qualification of safety related electrical equipment. Results of the audit

.; are summarized in this report.

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NRC FIN No. A6415--Equipment Qualification Case Reviews i

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SUMMARY

An audit of the environmental qualification of safety-related electrical equipment for the Clinton Power Station was conducted by a team comprised of representatives of the NRC Licensing Support Section of EG&G Idaho, Inc.. and the Nuclear Regulatory Commission (NRC) staff.

Qualification deficiencies for individual equipment items found during the pre-audit review are provided in Appendix A. Summaries of the central file reviews are provided in Appendix B. As a result of the audit it was concluded that when the Clinton Power Station resolves the concerns noted in this report, their qualification program will be complete and in accordance with 10 CFR 50.49.

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-t FOREWORD This report is supplied as part of the " Equipment Qualification Case Reviews" being conducted for the U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Division of Engineering, Equipment Qualification Branch by EG&G Idaho, Inc., NRC Licensing Support Section.

The U.S. Nuclear Regulatory Commission funded the work under the authorization, B&R 20-19-40-41-2.

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'O 1 i CONTENTS ABSTRACT .............................................................. 11

SUMMARY

............................................................... iii FOREWORD .............................................................. iv

1. INTRODUCTION ..................................................... 1
2. BACKGROUND ....................................................... 2
3. PURPOSE .......................................................... 3
4. SCOPE ............................................................ 4
5. EVALUATION ....................................................... 5
6. CONCLUSIONS ...................................................... 15
7. REFERENCES ....................................................... 16 APPENDIX A--PRE-AUDIT REVIEW OF THE CLINTON POWER STATION UNIT 1 ENVIRONMENTAL QUALIFICATION PROGRAM .............................. 17 APPENDIX B--SUMMARIES OF CENTRAL FILE REVIEWS . . . . . . . . . . . . . . . . . . . . . . . . . 36 v

1 AUDIT OF THE ENVIRONMENTAL QUALIFICATION OF SAFETY-RELATED ELECTRICAL EQUIPMENT FOR THE CLINTON POWER STATION

1. INTRODUCTION Equipment which is used to perform a necessary safety function must be demonstrated to be capable of maintaining functional operability under all service conditions postulated to occur during its installed life for the time it is required to operate. This requirement, which is embodied in General Design Criteria 1 and 4 of Appendix A and Sections III, XI, and XVII of Appendix B to 10 CFR 50, is applicable to equipment located inside as well as outside containment. More detailed requirements and guidance relating to the methods and procedures for demonstrating this capability have been set forth in 10 CFR 50.49, " Environmental Qualification of

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Electric Equipment Important to Safety for Nuclear Power Plants," and NUREG-0588, " Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment." This NUREG supplements IEEE Standard 323-1974, and various NRC Regulatory Guides and industry standards.

On March 11-14, 1985, a team comprised of representatives of the NRC Licensing Support Section of EG&G Idaho, Inc., and the NRC staff conducted an audit of the environmental qualification of safety-related electrical equipment for the Clinton Power Station (CPS). The work effort consisted of: (a) a pre-audit review of the licensee's submittal (Reference 1),

(b) an audit of the licensee's central files for selected equipment items, and (c) an on-site visual inspection of the equipment items for which the central files were audited. Qualification deficiencies, as found while performing the pre-audit review, for individual equipment items are provided in Appendix A. Summaries of the central file reviews are provided in Appendix B.

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2. BACKGROUND
NUREG-0588 was issued in December 1979 to promote a more orderly and systematic implementation of equipment qualification programs by the industry and to provide guidance to the NRC staff for its use in ongoing licensing reviews. The positions contained in NUREG-0588 provide guidance on (1) how to establish environmental service conditions, (2) how to select methods which are considered appropriate for qualifying equipment in different areas of the plant, and (3) other specific topics such as margin, aging, and documentation.

i In February 1980 the NRC requested certain near term Operating License (OL) applicants to review and evaluate the environmental qualification documentation for each item of safety-related electrical equipment and to identify the degree to which their qualification programs comply with the staff positions discussed in NUREG-0588. IE Bulletin 79-01B " Environmental Qualification of Class 1E Equipment," issued January 14, 1980, and its

-supplements dated February 29, September 30, and October 24, 1980 established environmental qualification requirements for operating reactors. This bulletin and it's supplements were provided to OL applicants for consideration in their review. A final rule on environmental qualification of electrical equipment important to safety for

nuclear power plants became effective on February 22, 1983. This rule, Section 50.49 of 10 CFR Part 50, specifies the requirements to be met for demonstrating the environmental qualification of electrical equipment important to safety located in a harsh environment. In accordance with 10 CFR 50.49, the electrical equipment in the Clinton Power Station may be ~

qualified in accordance with the acceptance criteria specified in I

Category I of NUREG-0588.

  • The qualification requirements for mechanical equipment are principally contained in Appendices A and B of 10 CFR 50. The
qualification methods defined in NUREG-0588 can also be applied to mechanical equipment.

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3. PURPOSE The purpose of this report is to evaluate the adequacy of the Clinton

, Power Station's environmental qualification program for electrical equipment important to safety as defined in 10 CFR 50.49, and for safety-related mechanical equipment. A discussion of open items, as well as any unresolved issues, is provided in this report.

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4. SCOPE The scope of this report includes an evaluation of the completeness of the list of equipment to be qualified, the criteria which they must meet, the environments in which they must function, and an assessment of the qualification documentation for the equipment. The principal area of review was the qualification of safety-related equipment which must function in order to prevent or mitigate the consequences of a loss-of-coolant accident (LOCA) or high energy line break (HELB) inside or cutside of containment, while subjected to the harsh environments associated with these accidents. It is limited to electrical equipment important to safety within the scope of 10 CFR 50.49, and safety related 1 mechanical equipment.

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5. EVALUATION The evaluation of the applicant's environmental qualification progran included an on-site examination of electrical equipment, audits of cualification documentation, and a review of the applicant's Final Safety Analysis Report (FSAR) for completeness and acceptability of systems and components, qualification methods, and accident environments. The criteria described in NUREG-0800, Rev. 2, Section 3.11 and NUREG-0588, Category I form the basis for the evaluation of the adequacy of the applicant's qualification program. Revision 1 of NUREG-0588 was utilized to clarify staff positions as required.

An audit of the applicant's qualification documentation on selected equipment and a visual-inspection of this equipment was performed by the staff on March 11-14, 1985. The audit consisted of a review of ten files

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(two by the NRC staff and eight by EG&G Idaho), containing equipment .

qualification documentation (this resulted in approximately 15 individual components). The staff's findings during the audit are di'scussed in detail in Section 5.4 of this Technical Evaluation Report (TER).

5.1 Completeness of Equipment Important to Safety -

The applicant was directed to (a) establish a list of systems and components that are required to prevent or mitigate a LOCA or a HELB and (b) identify components needed to perform the function of safety-related display instrumentation, post-accident sampling and monitoring, and-radiation monitoring. .

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Baseduponinformationintheapplicant'ssubmittal(Refe'r[e,nce1)and additionalinformationsupplied,thestaffhasverifiedand[determinedthat the systems included in the applicant's submittal are those req'uired to

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achieve or support: (a) emergency reactor shutdown, (b) containment isolation, (c) reactor core cooling, (d) containment heat removal; (e) core residual heat removal, and (f) prevention of significant release of radioactive material to the environment.

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5.2 Qualification Methods 5.2.1 Electrical Equipment in a Harsh Environment Detailed procedures for qualifying safety related electrical equipment in a harsh environment are defined in NUREG-0588. .The criteria in NUREG-0588 are also applicable to other equipment important to safety as defined in 10 CFR 50.49. Type testing of equipment in a sequence consisting of pre-aging (thermal, radiation, and mechanical), seismic and dynamic loading, and exposure to LOCA/HELB conditions (where applicable) is the preferred method of qualification. However, in a few cases the applicant has extrapolated partial test data to establish equipment qualification. Out of the equipment items reviewed during the on-site audit where this approach was used to qualify the equipment, only one equipment item was found where the analysis presented by the applicant was inadequate.

5.3 Service Conditions NUREG-0588 defines the methods to be utilized for determining the environmental conditions associated with loss-of-coolant accidents or high energy line breaks inside or cutside of containment. The analytical methods used by the applicant to postulate the environmental conditions following a LOCA/HELB have been reviewed and accepted by the U.S. NRC Containment Systems Branch. The qualification documentation has been reviewed to ensure that the qualification conditions envelop the conditions established by the applicant.

5.3.1 Temperature, Pressure, and Humidity Conditions Inside the Primary Containment The applicant provided the LOCA/HELB profiles used for equipment qualification. There are 25 harsh environmental zones located inside containment. The peak value resulting from these profiles are as follows:

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t Maximum Maximum Relative Temperature Pressure Humidity

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a Containment (Inside Drywell) 330 30" 100/ Steam LOCA/HELB

a. One zone, zone H-28, has higher peak parameters (355'F and 121 psig) postulated as a result of an accident. However, no components are located in this zone.

The above parameters were based on two assumptions: (1) the Clinton Cower Station (CPS) FSAR Tables 3.11-11 and 3.11-12, as referenced in CPS's FSAR Section 3.11.9, are correct for describing limiting conditions for zanes H-36, 39, 41, 42 and 45, during a HELB, and (2) the FSAR Section 6 PSIO diagrams, as referenced in CPS's FSAR Table 3.11-5, are not appropriate or incomplete for describing the limiting conditions during a HELB for the above zones.

5.3.2 Temperature, Pressure and Humidity Conditions Outside the Primary Containment The applicant has provided the temperature, pressure, and humidity vs.

time conditions associated with normal / abnormal operation and high energy line breaks outside containment with the exception of zone H-57.

5.3.3 Submergence

," The surge submergence level inside the drywell due to weir swell is either: (a) 740 ft-9 in., as found in CPS's FSAR Section 3, attachment A3.8, page 13a or (b) 743 ft-3 in. , as found on CPS's FSAR Figure 3.11-16.

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NOTE: CPS's FSAR Figure 3.11-16 (zone of application of weir swell impact, drag and fallback drag) has not been referenced properly in CPS's FSAR Section 3.11.9.18 (description of Zone H-16 bounding environmental conditions). This section mistakenly referenced Figure 3.11-10 which is an environmental zone map of the control building intermediate roof plan.

The steady state submergence level inside the drywell established by the applicant is the top of the weir wall which corresponds to an elevation of 735 ft-9 in.

The surge submergence level for the suppression pool due to the suppression pool swell phenomenon established by the applicant is 744 ft-5 in. The maximum froth line elevation for the suppression pool that Is achieved during pool swell is 761 ft-Sin.

After the pool swell and froth line peaks to the above elevations the water / froth mixture falls back to the normal pre-DBA elevation of 731 ft-5 in. The time it takes for the suppression pool to peak and return to its pre-DBA elevation is less than 5 seconds. During this time some of the water in the suppression pool is drawn back into the drywell, which in combination with the water content of the Reactor Pressure Vessel, creates the surge submergence level, or weir swell, inside the drywell.

The suppression pool and suppression pool make-up systems are designed not to allow water to enter the drywell from the suppression pool upon an i inadvertent actuation of the suppression pool make-up system during normal operations. The suppression pool make-up system was also designed to maintain a minimum of 2 ft of water coverage over the top of the top drywell vents during long-term post-accident conditions. This places the steady state submergence level of the suppression pool between 735 ft-9 in.

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t All safety-related equipment subjected to submergence and/or froth is or will be qualified for the time duration necessary for it to complete its safety function.

The effects of flooding on equipment located outside containment have been evaluated to assure that a safe shutdown can be achieved.

5.3.4 Containment Spray Demineralized water is used for centainment heat removal following a design basis accident. The time duration and spray loading established by the applicant to simulate the operation of the containment spray is one hour at one gpm per square foot. The location where equipment will be ubjected to containment spray has been established by the applicant to be inside the containment and outside the drywell, except equipment located in cubicles.

5.3.5 Aging The aging program requirements for cps electrical equipment are defined in Section 4, Category I of NUREG-0588. The degrading influences of temperature, radiation, vibration and mechanical stresses should be considered and included in the aging program. This requires the establishment of a qualified life and maintenance and replacement schedules based on the findings.

5.3.6 Radiation (Inside and Outside Containment)

The applicant has provided values for the radiation levels postulated to exist following a LOCA. The application and methodology employed by the applicant to determine these values are those methods found in NUREG-0588 and NUREG-0737, " Clarification of TMI Action Plan Requirements."

The maximum value specified for use inside the containment is 8

2 x 10 rads gamma. One zone, zone H-28, has a higher specified value of 5 x 109rads, however no components are located in this zone. The effects 9

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l of beta radiation on components located inside the containment have not been addressed by the applicant.

Outside containment, values ranging from 1 x 10 4rads gamma to 8

2 x 10 rads gamma, depending upon specific component location, have been specified for use in qualifying components. .

5.4 Environmental Qualification Audit An audit was conducted of the applicant's qualification documentation and installed equipment on March 11-14, 1985. Ten files (resulting in approximately 15 equipment items) were reviewed to determine if the test data and analysis in the files supported the qualification status determined by the applicant. The following general comments were made during the audit.

1. The files were voluminous making it extremely difficult to find pertinent information in the various test reports, addendums, and other supporting documentation found in each file.
2. Pertinent information found in the applicant's files was found to be misleading or contradicting to information found in the applicant's FSAR. This section and Appendix B in this TER discusses where this was found while reviewing the files during the on-site audit regarding information such as qualification parameters and component classifications. While performing the pre-audit review of CPS's FSAR, traceability problems were noted between the applicant's master lists and summary tables. This was acknowledged by the applicant during the on-site audit and assured the staff that updating the FSAR to reflect what was in .

the central files was an ongoing project. Therefore, it is not j the intent of this section and Appendix B of this TER to address the traceability problems that exist in the applicant's EQ i

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s program. See Appendix A for the traceability problems that were noted while performing the pre-audit review of the applicant's FSAR.

3. Some of the equipment items that were reviewed were not installed at the time of the on-site audit and consequently not inspected during the plant walk down by the staff. The staff was assured by the applicant that proper procedures and checklists exist to ensure the proper installation and maintenance of equipment contained in their EQ program.

Comments on specific files are as follows:

1. Limitorque Motor Operator (CPS File Number EQ-CLOO9) o Conflicting data was noted between the applicant's files and FSAR Tables regarding susceptibility and qualification to submergence for these motor operators. FSAR Table 3.11-1, Amendment 31, indicated that ICC070 is subjected to submergence. The controlled copy of Table 3.11-1 indicated that this was to be changed to indicate that this component was not subjected to submergence. File EQ-CLOO9 does not demonstrate qualification for submergence as claimed in Table A Section F5.4 of the file. The applicant concurred with this and stated that this reference to submergence in Table A Section F5.4 will be deleted in the next revision to EQ-CLOO9.

. o The justification provided in the file for exclusion of thermal aging for the phenolic switch material is not adequate for the following reasons:

a. The arguments presented imply that since 40 years is small compared to the predicted life at 60 C, pre-aging can be excluded. No analysis is presented which 11

.s demonstrates that the 50% reduction to strength, which forms the basis for the predicted life, is acceptable for equipment operability.

b. Linearity of the extrapolation of predicted life is assunied without proof.
c. The maintenance sheets in the file indicate melamine and fibrite components in addition to durez (phenolic). These materials are not addressed in the aging analysis.
d. Aging of other components was not addressed.

Pertinent information given in a letter from Limitorque to the applicant regarding the thermal aging of these switches was not present in this file. This letter also references a test report addressing this concern that is not available at this time, and consequently has not been reviewed by the applicant nor the staff for its applicability to CPS's Limitorque motor operators.

2. Rockbestos cable (CPS File numbers EQ-CLO25 and EQ-CLO51) o No specific comment on this file.
3. Safety Relief Valve Monitoring System (cps File number EQ-CLO26) o This file contained qualification documentation for the SRVM System as a whole. This system is comprised of the .

following components:

a. BBN accelerometer
b. TEC charge converter with transient shield
c. Brand-Rex instrument cable
d. Raychem splice kit.

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s There are no specific comments on this file other than this system was not installed at the time of the on-site audit.

4. Rosemount transmitter (CPS File number EQ-CLO21) o The specified and demonstrated accuracies were found to be misleading in the applicant's files and FSAR Table 3.11-3.

The applicant concurred with this and stated that the next revision to the file and FSAR Table 3.11-3 will clarify this concern.

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5. Westinghouse switchgear and breaker (CPS File number EQ-CLO20) o There are no specific comments on this file, however, the applicant's FSAR Table 3.11-3 should be revised to show that the demonstrated temperature envelopes the extreme normal temperature of 104 F.
6. Weed RTD (CPS File number EQ-CLO28) o There are no specific comments other than none of these RTDs were completely installed at the time of the on-site audit.
7. Okonite instrument cable (CPS File numbers EQ-CLO57 and EQ-CLO58) o There are no specific comments on these files. However, the applicant's FSAR Tables 3.11-1 and 3.11-3 should be revised to show that the cable covered in EQ-CLO58 may be subjected to submergence and that Table 3.11-3 should be revised to show that it is qualified to submergence.

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8. GE-IRM and LPRM detectors and connectors (CPS File numbers EQ-CLO34A and 348) o There are no specific comments on these files. However, the applicant's FSAR Table 3.11-2 should be revised to indicate that these are classification type 3 components, instead of type 1.
9. Conax airlock electrical penetration (CPS File number EQ-CLO32) o There are no specific comments other than this equipment was not installed at the time of the on-site audit.
10. Conax MV, LV, and I&C electrical penetrations (CPS' File numbers EQ-CLO37, 38 and 39) o There are no specific comments on these files. However, the applicant's FSAR Table 3.11-3 should be revised to reflect that these components are qualified to spray by analysis.

5.5 Outstanding Equipment For safety-related items not having complete qualification documentation, the applicant has provided commitments for corrective action and schedules for completion. For items not expected to have full qualification, analyses will be performed in accordance with paragraph (1) of 10 CFR 50.49 to ensure that the plant can be operated safely pending completion of environmental qualification. These analyses must be submitted prior to granting of an operating license.

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6. CONCLUSION The Clinton Power Station program for the environmental qualification of electrical and mechanical equipment has been reviewed. The review has included the systems selected for qualification, the environmental conditions resulting from design basis accidents, the methods used for qualification and the documentation for specific items of equipment. The following items are outstanding and must be resolved prior to issuance of an operating license.
1. Additional information concerning surveillance techniques to be utilized for detecting age-related degradation of cables should be provided.
2. A formal commitment to Reg Guide 1.33 must be provided by the applicant.
3. Checklists for that equipment the staff could not inspect during the on-site audit should be provided by the applicant.
4. The outstanding items identified during the on-site audit by the staff must be resolved as described in Section 5.4.

Based on these considerations, it is concluded that satisfactory completion of the corrective actions identified herein will ensure conformance with the requirements of 10 CFR 50.49 and relevant parts of General Design Criteria 1 and 4 of Appendix A; Sections III, XI, and XVII of Appendix B,10 CFR 50; and the criteria specified in NUREG-0588.

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7. REFERENCES
1. Clinton Power Station Final Safety Analysis Report, Section 3.11, Amendment 31.
2. Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment, NUREG-0588.
3. IEEE Standard for Qualifying Class 1E Equipment for Nuclear Power Generating Stations, IEEE Std. 323-1974.
4. Code of Federal Regulations, Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants,10 CFR 50.49.
5. U.S. NRC Regulatory Guide 1.97, Revision 2, December 1980, Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident.
6. U.S. NRC Regulatory Guide 1.89, Revision 1, June 1984, Environmental Qualification of Certain Electrical Equipment Important to Safety for Nuclear Power Plants.

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4 APPENDIX A PRE-AUDIT REVIEW OF THE CLINTON POWER STATION UNIT 1 ENVIRONMENTAL QUALIFICATION PROGRAM 17

.o APPENDIX A PRE-AUDIT REVIEW OF THE CLINTON POWER STATION UNIT 1 ENVIRONMENTAL QUALIFICATION PROGRAM The Clinton Power Station (CPS) Environmental Qualification (EQ)

Program (as found in CPS's FSAR, Section 3.11, Amendment 31) submitted by Illinois Power Company (IPC) was reviewed to determine compliance with 10 CFR 50.49 and Ancillary Standards. It was found that IPC's methodology in achieving compliance to 10 CFR 50.49 was sound, however, the presentation of pertinent data was often times confusing, and at times showed that IPC failed to meet the requirements of 10 CFR 50.49. This pre-audit review indicated the following general areas of concern.

1. CPS's FSAR Table 3.11-5, Environmental Zone Summary Table, references notes that appear to have been deleted or changed.

For Zones H-36, 39, 41, and 45, PSID response figures are referenced for temperature and pressure bounding parameters.

Zone H-57 references temperature response figures for location areas not found in Zone H-57.

2. There were cases found in CPS's Qualification Summary Tables, FSAR Tables 3.11-3 and 3.11-4, where the components were considered qualified by IPC and demonstrated parameters did not envelope the specified parameters. For some of these cases no outstanding items were identified, nor, resolution given to correct these outstanding items.
3. Many of the items in CPS's Qualification Summary Tables, FSAR Tables 3.11-3 and 3.11-4, are not clear as to what parameters the components are qualified to.

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4. Many components were found to be identified in CPS's Master Lists, FSAR Tables 3.11-1 and 3.11-2, and not identified in CPS's Qualification Summary Tables, FSAR Tables 3.11-3 and 3.11-4. The opposite also occurred.
5. Components in CPS's master lists, FSAR Tables 3.11-1 and 3.11-4, had wrong or missing equipment classifications. Others had no Qualification Summary Table, FSAR Table 3.11-3 or 3.11-4, item referenced.
6. IPC did not show compliance to the following IEEE standards in CPS's FSAR:

o IEEE Std 334 o IEEE Std 382 o IEEE Std 383.

7. The effects of beta radiation on components was not addressed in CPS's FSAR Section 3.11.

A review of CPS's FSAR Tables 3.11-3 and 3.11-4 was performed in depth to assess the qualification status of CPS's Class IE electrical components located in a harsh environment. Table A-1 of this appendix shows the results of the review of CPS's FSAR Table 3.11-3 (BOP components).

Table A-2 of this appendix shows the results of the review of CPS's FSAR Table 3.11-4 (NSSS components).

This review points out many discrepancies found while reviewing CPS's l

FSAR Tables 3.11-3 and 3.11-4 which may or may not exist in CPS's EQ program. There is a time lapse that exists between the time the applicant's central files are updated to reflect changing requirements and j qualification status re-evaluations, and, the time it takes to update Clinton's FSAR Section 3.11 to reflect the above changes. Therefore, care should be taken in trying to draw any conclusions from this pre-audit review as to the actual state of CPS's EQ program in achieving compliance to 10 CFR 50.49.

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TABLE A-1 RESULTS OF THE REVIEW OF CPS's FSAR TABLE 3.11-3 BY ITEM NUMBER Item Number Component Description Deficiencies Found by the Reviewer

1. Westinghouse motor There is no operability time margin for (EQ-CLOO4) any of these motors.
2. Westinghouse motor There is no operability time margin (EQ-CL003) for any of these motors.
3. Gould molded case No discrepancies noted.

circuit breaker (EQ-CL002)

4. Rosemount transmitter Transmitters located in Zone H-12 were

( EQ-CLOOS) not identified in CPS's FSAR Table 3.11-3. Those transmitters located

in Zone H-26 have not been qualified to spray.
5. Okonite control and If any cable is required to operate power cable (EQ-CLOO6) submerged no attempt has been made to qualify this cable for submergence. Peak specified pressures and temperatures for cable located in Zones H-36, 39, 41, 42, 45, and 57 have not been supplied by IPC.
6. Okonite power cables If any cable or termination kits are and termination kits required to operate submerged no attempt (EQ-CLOO7) has been made to qualify these components for submergence. Peak specified pressures and temperatures for components

, located in Zones H-36, 39, 41, 42, 45, l and 57 have not been supplied by IPC.

7. Rockbestos control If any cable is required to operate cable (EQ-CLO51) submerged no attempt has been made to qualify this cable for submergence. Peak specified pressures and temperatures for cable located in Zones H-36, 39, 41, 42, 45, and 57 have not been supplied by IPC. There is no operability time margin
for this cable.

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8. ITE-Gould MCC and CPS's FSAR Table 3.11-3 identifies MCC's i hydrogen ignitor located in Zone H-31 that could not be control panel found by the reviewer in CPS's FSAR (EQ-CLO14) Table 3.11-1. The MCC's located in Zones H-31 and 51 do not have an operability i

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TABLE A-1 (continued)

Item Number Component Description Deficiencies Found by the Reviewer time margin. The hydrogen ignitor control panels were not considered

' qualified by IPC and consequently not reviewed for compliance to 10 CFR 50.49.

9. Victoreen high range No discrepancies noted.

gamma radiation monitor detector and cable assembly (EQ-CLOO15)

10. GE switchboard wire No discrepancies noted.
11. NAMCO limit switch Limit switches located in Zone H-32 were (EQ-CLO13) not identified in CPS's FSAR Table 3.11-3.

However, limit switches located in Zone H-30 were identified in CPS's FSAR Table 3.11-3 but could not be found by the reviewer in CPS's FSAR Table 3.11-1. The reviewer could not determine the operability time margin for those components considered qualified by IPC.

12. NAMCO limit switch Limit switches located in Zones H-16, 23, (EQ-CLOO8) 27, 32, and 55 were not identified in CPS's FSAR Table 3.11-3. The switch located in Zone H-55 does not have a sufficient temperature margin.
13. Brown Boveri 480 V There is no operability time margin for unit substation these components.

(EQ-CLO23)

14. ASCO solenoid valve No qualified life is given for these (EQ-CLO17) components. The demonstrated operability time could not be evaluated for margin.
15. BISCO D.W. LOCA seal These components were not considered (EQ-CLO43) qualified by IPC and consequently not reviewed for compliance to 10 CFR 50.49, 21

TABLE A-1 (continued)

't Item Number Component Description Deficiencies Found by the Reviewer

16. Limitorque valve Valve operators located in Zones H-5, 9, operators (EQ-CLO27) 25, and 40 were not identified in CPS's FSAR Table 3.11-3. However, valve operators were identified in Zones H-3, 6, 20, 31, 32, and 34 in CPS's FSAR Table 3.11-3 that could not be found by the reviewer in CPS's FSAR Table 3.11-1. The reviewer could not determine which set of demonstrated parameters applied to their respective set of components. Also, one set of demonstrated parameters did not have the demonstrated temperature stated. If any of these components are subjected to spray or submergence no attempt has been made to qualify them to spray or submergence.
17. Sentry H-2 sample These components do not have a sufficient panel (EQ-CLO60) temperature margin. There is no operability time margin for these components.
18. Weed RTD (EQ-CLO28) The model numbers for those components located in Zone H-47 are not consistent between CPS's FSAR Tables 3.11-1 and 3.11-3. Four RTDs were not identified in CPS's FSAR Table 3.11-3. Qualification by analysis is being performed for those components subjected to submergence.
19. ASCO solenoid valve Model Number 20638130 located in Zone H-12 (EQ-CLO24) is not consistent between CPS's FSAR Tables 3.11-1 and 3.11-3. Those components with Model Number 2068323U found in Zones H-27 and 55 were not l identified in CPS's FSAR Table 3.11-3, however, components of the same model number in Zone H-31 were identified in CPS's FSAR Table 3.11-3 but could not be found by the reviewer in CPS's FSAR Table 3.11-1. Those components with Model Number NP8320 found in Zone H-55 were not identified in CPS's FSAR Table 3.11-3, however, components of the same model number in Zone H-26 were identified in CPS's FSAR Table 3.11-3 but could not i

22

w

-TABLE A-1 (continued)

Item Number Component Description Deficiencies Found by the Reviewer be found by the reviewer in CPS's FSAR Table 3.11-1. Overall, CPS's FSAR Table 3.11-3 identifies two components that could not be found by the reviewer in CPS's FSAR Table 3.11-1. Both model numbers, 2068323U and 2063813U, located in Zones H-15 and 16 could not be evaluated for submergence. Solenoid valves, Model Number 2068323U, located in Zones H-16, 32, and 55, do not have a sufficient temperature margin. It was assumed that all of the solenoid valves, Model Number NP8320, were not considered qualified by IPC and consequently not reviewed for compliance to 10 CFR 50.49.

20. Seim/Allis motor No demonstrated temperature was given for (EQ-CLO29) these components.
21. Conax medium voltage Qualification to spray has not been electrical penetration demonstrated. No operability time (EQ-CLO37) margin exists for these components
22. Conax low voltage Qualification to spray has not been power and demonstrated for any of the components instrumentation covered by this item. The low voltage penetrations power penetrations do not have an (EQ-CLO38/39) operability time margin.
23. Reliance motor Four motors found in CPS's FSAR (EQ-CLO42) Table 3.11-1 have not been identified in i

CPS's FSAR Table 3.11-3. These c_mponents are not considered qualified by IPC and consequently not reviewed for corr iance to 10 CFR 50.49.

24. Westinghouse motor One motor, located in Zone H-40, has not

! (EQ-CLOO4) been identified in CPS's FSAR Table 3.11-3. There is no test report referenced or qualified life given for those motors located in Zone H-40.

l 25. Bethlehem flow element These components are not considered (EQ-CLO42) qualified by IPC and consequently not

[

reviewed for compliance to 10 CFR 50.49.

l

{

l 23 l

l l - . ._ _ __ . . _ _ - - - _ _ _ _ _ . _ _ _ _ _ _ .

a.

TABLE A-1 (continued)

Item Number Component Description Deficiencies Found by'the Reviewer

26. Semco temperature These components are not considered

- element (EQ-CLO42) qualified by IPC and consequently not reviewed for compliance to 10 CFR 50.49.

~ 27. Conax airlock .This item covers four components. One is in Zone H-15, one is in H-19, and two are in H-44. Those located in Zones H-15 and 44 are required to operate during containment spray. The penetration located in Zone H-15 is required to operate submerged. Justification for not qualifying these. components to submergence or spray is being used. The ,

operability time margin for these components could not be evaluated.

NOTE: These components function primarily as a mechanical seal, and could be covered under CPS's mechanical equipment qualification program instead of their electrical equipment qualification program.

29. NAMCO limit switch Two limit switches, Model Number EA-170, (EQ-CLOO8) located in Zone H-47, are not identified in CPS's FSAR Table 3.11-3. Limit switches, Model Number EA-180, located in Zones H-22, 27, 31, and 55,-are not identified in CPS's FSAR Table 3.11-3, however, switches of the same model number, located in in Zones H-6,15, 26, 29, and 46, are identified in CPS's FSAR Table 3.11-3 but could not be found by the reviewer in CPS's FSAR Table 3.11-1.
30. Valcor solenoid valve There is a solenoid valve, Model (EQ-CLO12) Number V25659408, located in Zone H-29, not identified in CPS's FSAR Table 3.11-3. It appears that the numbers representing the number of components covered by this item have been switched. Spray has not been addressed for those components located in Zone H-15. Submergence could not be evaluated for those components located in 24

TABLE A-1 (continued)

Item Number Component Description Deficiencies Found by the Reviewer Zone H-15. No qualified life has been given for any of the components covered

. by this item.

31. BBN SRVM accelerometer Spray has not been addressed for.the and TEC charge charge converters. Accuracy or response converter (EQ-CLO26) time has not been addressed for any of these components. There is no operating time margin for any of these components.
32. Misc. Powers panel One panel was not identified in CPS's subcomponents FSAR Table 3.11-3. These components are (EQ-CLO62) not considered qualified and consequently not reviewed for compliance to 10 CFR 50.49.
33. Eberline safety The equipment classification appears to related process be wrong in either CPS's Table 3.11-1 radiation monitoring or 3.11-3. An indicating transmitter, system (EQ-CL016) located in Zone H-17, was not identified in CPS's FSAR Table 3.11-3. CPS's FSAR Table 3.11-3 identifies one indicating transmitter, located in Zone H-27, that cannot be found by the reviewer in CPS's FSAR Table 3.11-1. These components are not considered qualified by IPC and consequently not reviewed for compliance to 10 CFR 50.49.
34. Westinghouse The demonstrated temperature does not switchgear (EQ-CLO20) envelope the specified temperature.
35. Westinghouse Two breakers identified in CPS's FSAR breaker (EQ-CLO20) Table 3.11-3 could not be found by the reviewer in CPS's FSAR Table 3.11-1. The l demonstrated temperature does not envelope the specified temperature.
36. Raychem NPKV stub If any of these kits are subjected to connection kit spray or submergence, no attempt has (EQ-CLO48) been made to qualify these kits for submergence or spray. Peak specified pressures and temperatures for kits found in Zones H-36, 39, 41, 42, 45, and 57 i have not been supplied by IPC. .No l

l l

25

TABLE A-1 (continued)

Item Number Component Description Deficiencies Found by the Reviewer qualified life is given for these components. None of these components

, have an operability time margin.

37. Nuthers heater These components are not considered (EQ-CLO47) qualified by IPC and consequently not reviewed for compliance to 10 CFR 50.49.

t

38. Barton DP switch CPS's FSAR Table 3.11-3 identifies (EQ-CLO41) components in Zone H-51 that could not be found by the reviewer in CPS's FSAR Table 3.11-1. None of these components have an operability time margin.
39. Barton DP transmitters These components are not considered (EQ-CLO94) qualified by IPC and consequently not reviewed for compliance to 10 CFR 50.49.
40. Kidde temperature These components are not considered element (EQ-CLO46) qualified by IPC and consequently not reviewed for compliance to.10 CFR 50.49.
41. Nutherm temperature These components are not considered switch (EQ-CLO47) qualified by IPC and consequently not reviewed for compliance to 10 CFR 50.49.
42. GPE LICON limit switch These components are not considered

! (EQ-CLO92) qualified by IPC and consequeritly not reviewed for compliance to 10 CFR 50.49.

t

43. Weed temperature CPS's FSAR Table 3.11-1 states that transmitter these components are located in Zone H-47 (EQ-CLO28) where CPS's FSAR Table 3.11-3 states they are in Zone H-27. These components are not considered qualified by IPC and
consequently not reviewed for compliance to 10 CFR 50.49.

3 44. ITT actuator The demonstrated parameters for Model

(EQ-CLO44) Number NH-91 with a polyurethane/buna

~

seal could not be determined. The reviewer assumed they were the same as the others. No qualified life is given

. for any of the components covered by this item. There is no temperature margin for 26

TABLE A-1 (continued)

Item Number Component Description Deficiencies Found by the Reviewer those actuators found in Zone H-11.

Demonstrated operability time is not given for some of these actuators.

Justification for having a lower demonstrated radiation dose than that which is specified is being used.

45. Love Controls flow A controller located in Zone H-57 was not indicator controller identified in CPS's FSAR Table 3.11-3.

and temperature These components are not considered indicating transmitter qualified by IPC and consequently not (EQ-CL018) reviewed for compliance to 10 CFR 50.49.

46. Validyne flow These components are not considered transmitter qualified by-IPC and consequently (EQ-CLO66) not reviewed for compliance to
47. Transmission OP, These components are not considered temperature alarm and qualified by IPC and consequently flow alarm relays not reviewed for compliance to (EQ-CLO18) 10 CFR 50.49.
48. GE hand switch These components are not considered (EQ-CL018) qualified by IPC and consequently not reviewed for compliance to 10 CFR 50.49.
49. Agastat time delay These components are not considered relay (EQ-CLO18) qualified by IPC and consequently not reviewed for compliance to 10 CFR 50.49.
50. United temperature These components are not considered indicating switch qualified by IPC and consequently (EQ-CLO18) not reviewed for compliance to 10 CFR 50.49.
51. GE indicating lamp Lamps found in Zones H-51, 56, and 57 (EQ-CLO18) were not identified in CPS's FSAR Table 3.11-3. Overall, one component could be found by the reviewer in CPS's FSAR Table 3.11-1 that was not identified in CPS's FSAR Table 3.11-3. No qualified life is given for any of these components.

27

TABLE A-1 (continued)

Item Number Component Description Deficiencies Found by the Reviewer

52. ASCO temperature and These components are not considered flow solenoids qualified by IPC and consequently (EQ-CLO18) not reviewed for compliance to 10 CFR 50.49.
53. Love Controls Components located in Zones H-5 and 57 indicating meter were not identified in CPS's FSAR (EQ-CLO18) Table 3.11-3. Overall, two components could be found by the reviewer in CPS's FSAR Table 3.11-1 that were not identified in CPS's FSAR Table 3.11-3.

These components are not considered qualified by IPC and consequently not reviewed for compliance to 10 CFR 50.49.

54. Validyne DP These components are not considered transmitter (EQ-CLO66) qualified by IPC and consequently not reviewed for compliance to 10 CFR 50.49.
55. Love Controls These components are not considered transmitter (EQ-CL018) qualified by IPC and consequently not reviewed for compliance to 10 CFR 50.49.
56. Rosemount flow These components are not considered transmitter (EQ-CLO42) qualified by IPC and consequently not reviewed for compliance to 10 CFR 50.49.
57. ASCO solenoid valve The reviewer could not find the solenoid (EQ-CLOO40) valves located in Zones H-25 and 35 in CPS's FSAR Table 3.11-1. Overall, four components could not be found in CPS's FSAR Table 3.11-1. There are apparent typographical errors in CPS's FSAR Table 3.11-1 in the model numbers for some of the solenoid valves. Due to conflicting data received from IPC prior to the on-site audit as to the qualification status of these components and the qualification status depicted in CPS's FSAR Table 3.11-3, no evaluation of these components was performed for compliance to 10 CFR 50.49.

4

, 58. United Electric These components are not considered temperature swit~ch qualified by IPC and consequently (EQ-CLO18) not reviewed for compliance to

, 10 CFR 50.49.

t 28

TABLE A-1 (continued)

L-1 Item Number Component Description Deficiencies Found by the Reviewer "

]

59. Solon DP switch Components located in Zone H-5 were not (EQ-CLO18) identified in ' CPS's FSAR Table 3.11-3.

' CPS's Table 3.11-3 identifies components in Zone H-51 that could not be found by the reviewer in CPS's FSAR Table 3.11-1.

These components are not considered qualified by IPC and consequently not reviewed for compliance to 10 CFR 50.49.

60. (EQ-CLOO94) CPS's FSAR Table 3.11-3 states that this item has been deleted, however, there are
components in CPS's FSAR Table 3.11-1 l referencing this item.

t

61. MCC Powers temperature These components have no temperature elements (EQ-CLO33) margin.
62. Conax seals (EQ-CLO94) Components located in Zone H-54 were not-identified in CPS's FSAR Table 3.11-3.

If any of these components are subjected to spray or submergence no attempt has been made to qualify these components to

, submergence or spray. No qualified life is given for these components. None of these components have an operability time j margin. Specified peak' pressures and temperatures for those components located in Zones H-39 and 42 have not been j supplied by IPC.

4

63. Okonite instrument The TW cable was not considered qualified i cable-TW and Okonite by IPC and consequently not reviewed for i special instrument compliance to 10 CFR 50.49.

cable (EQ-CLO49/57) The special instrument cable was t

! , considered qualified and the results of 4 the review are as follows. If any cable '

is required to operate submerged no attempt has been made to qualify this

' cable for submergence. Cable found in

, Zones H-2, 3, 16, 27, 32, 53, and 55 do not have a sufficient temperature j margin. Peak specified pressures and

temperatures for cable found in Zones H-36,'39, 41, 42, 45, and 57 have
not been supplied by IPC. Qualified life j has not been given for these components.
29

_ _ - - . _._ i . . _ _ - _ _ _ _ _ _ _ . - _ _ _ _ _ _ _ _ _ . . _ _ _ _ - - _ - _ _ . _

TABLE A-1 (continued)

Item Number Component Description Deficiencies Found by the Reviewer

64. Okonite instrument If any cable is subjected to spray or cable (EQ-CLO58) submergence, no attempt has been made to qualify this cable for spray or submergence. Cable found in Zones H-2, 3, 16, 27, 32, 33, and 55 do not have a sufficient temperature margin. Peak specified pressures and temperatures for cable found in Zones H-36, 39, 41, 42, 45, and 57 have not been supplied by IPC. Qualified life has not been given for these components.
65. Rockbestos RSS If any cable is required to operate Firewall III and RSS submerged no attempt has been made to second generation qualify this cable for submergence.

cable (EQ-CL0025) The Firewall III cable found in Zones H-2, 3, 16, 27, 32, 53, and 55 does not have a sufficient temperature margin. Peak specified pressures and temperatures for cable found in Zones H-36, 39, 41, 42, 45, and 57 have not been supplied by IPC. The RSS second generation cable has no operability time margin.

66. AMP C&K cable lug If any cable is required to operate (EQ-CL0054) submerged no attempt has been made to qualify this cable for submergence. Peak specified pressures and temperatures for cable found in Zones H-36, 39, 41, 42, 45, and 57 have not been supplied by IPC.

There is no operability time margin for these components.

67. (EQ-CL0012) CPS's FSAR Table 3.11-3 states that this item has been deleted, however, there are components in CPS's FSAR Table 3.11-1 referencing this item.
68. Bettis actuator These components are not considered (EQ-CLO70) qualified by IPC and consequently not reviewed for compliance to 10 CFR 50.49.

l 30 i

TABLE A-1 (continued)

Item Number Component Description Deficiencies Found by the Reviewer

69. Burndy cable lug If any of these components are required (EQ-CLO30) to operate submerged no attempt has been made to qualify them for submergence.

Specified peak pressures and temperatures for those components located in Zones H-2, 3, 16, 27, 32, 53, and 55 have not been supplied by IPC.

70. Electromark labels These components are not considered as (EQ-CLO53) an electrical item by the reviewer and therefore were not reviewed.
71. Grady labels These components are not considered (EQ-CLO55) as an electrical item by the reviewer and therefore were not reviewed.
72. Marathon terminal No discrepancies noted.

(EQ-CLO31)

73. Morrison Knudsen ,

Four ignitors were identified in CPS's hydrogen ignitor FSAR Table 3.11-3 that could not be (EQ-CLO91) found by the reviewer in CPS's FSAR Table 3.11-1. These components are not considered qualified by IPC and consequently not reviewed for compliance to 10 CFR 50.49.

75. Chromolax heater These components are not considered (EQ-CLO42) qualified by IPC and consequently not reviewed for compliance to 10 CFR 50.49.
76. Reliance motor These motors do not have an operability (EQ-CLO59) time margin. No qualified life is given for these components.
77. Kidde temperature These components are not considered switch (EQ-CLO46) qualified by IPC and consequently not reviewed for compliance to 10 CFR 50.49.
78. Love Controls These components are not considered temperature indicating qualified by IPC and consequently transmitter (EQ-CLO18) not reviewed for compliance to 10 CFR 50.49, 31

6 TABLE A-1 (continued)

Item Number Component Description Deficiencies Found by the Reviewer

80. Reliance motor Demonstrated radiation doses and (EQ-CLO61A, 8, & C) humidity are not given for the SLCS motors. Qualified life is not given for any of the motors covered by this item.

The equipment classification in CPS's FSAR Table 3.11-1 is wrong for the SLCS

motors.
81. Rosemount flow, level, The transmitters located in Zones H-8 OP, and pressure and 17 identified in CPS's FSAR transmitters Table 3.11-3 could not be found by (EQ-CLO21) the reviewer in CPS's FSAR Table 3.11-1.

Overall, 20 transmitters identified in CPS's FSAR Table 3.11-3 could not be found by the reviewer in CPS's FSAR Table 3.11-1. No qualified life is given for these components. No demonstrated pressure is given for those components.

No demonstrated spray rate or spray duration has been given for these components. The demonstrated radiation dose does not envelope the specified radiation dose for those components found in Zone H-26.

82. NAMCO limit switch Due to conflicting data received from IPC (EQ-CL013) prior to the on-site audit as to the qualification status of these components

! and the qualification status depicted in CPS's FSAR Table 3.11-3, no evaluation of these components was performed for compliance to 10 CFR 50.49.

1 i

4 32

TABLE A-2. RESULTS OF THE REVIEW OF CPS's FSAR TABLE 3.11-4 BY ITEM NUMBER Item Number Component Description Deficiencies Found by the Reviewer

1. GE motor (EQ-CL001) No discrepancies noted.
2. GE motor (EQ-CLO11) No discrepancies noted.
3. GE motor (EQ-CLO10) No discrepancies 'noted.
4. Misc. GE panel Panels that are stated to be in Zone H-17 subcomponent in CPS's FSAR Table 3.11-4 cannot be (EQ-CLO45) found by the reviewer in CPS's FSAR Table 3.11-2. Overall, ten panels that are identified in CPS's FSAR Table 3.11-4 cannot be found by the reviewer in CPS's FSAR Table 3.11-2. These components are not considered qualified by IPC and consequently not reviewed for compliance to 10 CFR 50.49.
5. Gould level and DP Transmitters located in Zones H-4 and 19 transmitters were not identified in CPS's FSAR

, (EQ-CLO69) Table 3.11-4. However, CPS's FSAR Table 3.11-4 identifies transmitters located in Zones H-7 and 11 that cannot be found by the reviewer in CPS's FSAR Table 3.11-2. These components are not considered qualified by IPC and consequently not reviewed for compliance to 10 CFR 50.49.

6. Limitorque valve Due to conflicting data received from operator (EQ-CLOO9) ICP prior to the on-site audit as to the qualification status of these components and the qualification status depicted in CPS's FSAR Table 3.11.-4, no evaluation of these components was performed for compliance to 10 CFR 50.49.

. 7. GE heater (EQ-CLO67) There is no operability time margin for these components.

9. PYC0 temperature CPS's FSAR Table 3.11-4 identifies element (EQ-CLO63) components located in Zones H-3, 12, 26, 30, and 39 that cannot be be found by the reviewer in CPS's FSAR Table 3.11-2.

Overall, there are 21 components that are identified in CPS's FSAR Table 3.11-4 that 33

l TABLE A-2. (continued) l Item Number Component Description Deficiencies Found by the Reviewer cannot be found by the reviewer in CPS's FSAR Table 3.11-2. There are no demonstrated parameters given for these components. Specified temperatures and pressures for components located in Zones H-39 and 42 have not been supplied by IPC.  !

l

11. Oikkers/Seitz SRV These components are not considered actuator solenoid qualified by IPC and consequently not (EQ-CLO65) reviewed for compliance to 10 CFR 50.49.
13. S&K flow meter These components are not considered (EQ-CLO19) qualified by IPC and consequently not reviewed for compliance to 10 CFR 50.49.
14. GE pre-amplifier The equipment classification for these (EQ-CLO35) components is wrong in CPS's FSAR Table 3.11-2,
15. GE IRM detectors The equipment classification for these and connectors components is wrong in CPS's FSAR (EQ-CLO34A) Table 3.11-2. No specified parameters for the detectors are given. No specified radiation dose is given for the connectors.
16. GE power range The equipment classification for these detectors and components is wrong in CPS's FSAR connectors Table 3.11-2. Specified parameters for (Eq-CLO348) the detectors are not given. There is no qualified life given for any of these components.
17. GE LPRM detectors The equipment classification for these and connectors components is wrong in CPS's FSAR (EQ-CLO348) Table 3.11-2. Specified parameters for the detectors are not given. There is no qualified life given for any of these components.
19. GE gamma radiation These components are not considered detector (EQ-CLO43) qualified by IPC and consequently not reviewed for compliance to 10 CFR 50.49.

34

TABLE A-2. (continued)

Item Number Component Description Deficiencies Found by the Reviewer

20. Magnetrol level These components are not considered switch (EQ-CLO50) qualified by IPC and consequently not reviewed for compliance to 10 CFR 50.49.
22. Rosemount OP and CPS's FSAR Table 3.11-4 identifies pressure transmitters transmitters in Zone H-6 that the (EQ-CLO97) reviewer cannot find in CPS's FSAR T4ble 3.11-2. Overall, there is only one transmitter that is identified in CPS's FSAR Table 3.11-4 that the reviewer cannot find in CPS's FSAR Table 3.11-2. The components located in Zones H-6, 11, and 12 have no temperature margin. None of these components have an operating time margin.
23. Conax control valve The equipment classification is wrong (EQ-CLO64) for these components in CPS's FSAR Table 3.11-2.

35

Os D.

APPENDIX B SUMMARIES OF CENTRAL FILE REVIEWS 36

>. i APPENDIX B SUMMARIES OF CEN' TRAL FILE REVIEWS GE-IRM, PR, AND LPRM DETECTORS / CONNECTORS MODELS 112C3144 G008 and NA 250 This equipment is part of the neutron monitoring system (NMS) sensor (instrument) channels. The NMS has inputs to the Reactor Protection (Trip) '

System (RPS). The neutron detectors are located in-core and the connectors are located in zone H-3, the drywell area under the reactor pressure vessel. This equipment is not required for LOCA/HELB mitigation and is classified as Type 3. (CPS's FSAR Table 3.11-2 shows this to be Type 1 and is to be corrected).

The specified environment for the detectors is not given in the Clinton FSAR, however it is identified in the Qualification Test Report 710-01-45 and will be included in an FSAR amendment.

The specified normal environment for the connectors is: temperature, 135 F; pressure, 2 psig; relative humidity, 90%; and radiation 1 x 10 7 TID.

The test environment for the detectors was: temperature, 575 F; pressure, 1250 psig; humidity, 100%; and radiation, 2 x 108 rads TID.

The test environment for the connectors was: temperature, 185*F; 7

pressure, 2 psig; humidity, 90%; and radiation, 1 x 10 rads (PR and 6

LPRM), 1.1 x 10 rads (IRM) TID.

A qualified life of 2.5 yrs (IR) up to 7.5 yrs (PR and LPRM) is established by type testing, analysis, and operating experience and is l dependent on periodic replacement as well as surveillance (calibration) requirements to be included in the CPS Technical Specs and Maintenance Instructions for the plant.

l 37

. _ _ . . _ - _ _ - _= _ _ _ _ . _ . . ..

_ _ . . . ~ . _ _ . . . _ _ . _ _ _ _ . _ _ _ . .

j In conclusion the detectors / connectors are qualified for their '

specified environment and documentation is contained in the applicant's file. The utility has committed to making the specified changes to the FSAR.

i.

4 i

f i

1 a

i h

38

OKONITE INSTRUMENT CABLE-TW (0K0ZEL/0K0ZEL)

This cable is located throughout the Clinton Power Station, except in the containment drywell (Zone H-28) and the Turbine Building (Zone H-54),

carrying a maximum voltage of 600 Vac.

The specified accident environmental parameters are: temperature, 330*F; pressure, 30 psig; relative humidity,100%/ steam; radiation, 2 x 108rads; and an operability time, post DBE of 100 days. The cable is susceptible to flooding and/or containment spray.

Aging and environmental testing have been performed on this cable and is reported in an Okonite Company test report titled " Qualification of Okozel Insulation for Nuclear Plant Service" report number NQRN-4, Revision 2 dated August 19, 1982. The cables were thermally aged and exposed to a TID of 2 x 10 8rads then post-LOCA simulation tests were performed with the following peak parameters: temperature, 345 F; pressure, 112 psig; relative humidity, 100%; and chemical spray, 10.5 pH.

Submergence and an operability time of 130 days were demonstrated during 4 the test. By use of the Arrhenius Methodology a qualified life of 40 years was established for this cable.

It is concluded that the Okonite (Okozel/0kozel) insulated cable is qualified for the specified environment. Documentation to support this conclusion is contained in the applicant's file. However, the applicant should supply information on how they intend to monitor the effects of long

term aging / degradation on this cable. The applicant also needs to revise FSAR Tables 3.11-1 and 3.11-3 to reflect that this cable is subjected to and qualified for submergence.

l l -

i i

39

ROSEMOUNT TRANSMITTER MODEL 1153 '.ERIES B PLANT I.D. NO. 1821-N076A This transmitter is located in the turbine building at an elevation of 744 ft. It is used.to sense main steam pressure at the turbine stop valve. This transmitter has a 0-3000 psig range. The maximum expected process pressure that this transmitter will see is 1200 psig.

The worst case conditions that this transmitter is required to operate in occurs during a HELB. This accident results in the following conditions: Temperature, 212 F; pressure, atmospheric; radiation, 4

1 x 10 rads TID; and humidity, 100%/ steam. The required accuracy for this component during an accident is 8% and the required operating time is ,

one hour. l Qualification for this component is contained in Rosemount reports 108025, Revision A, and 108026 Revision 0, and supporting documentation. This component was thermally aged at 203 F for 47 days.

Using the Arrhenius Methodology a qualified life for this component was established at 9 years. The demonstrated parameters as contained in the above test reports is as follows: temperature, 318*F; pressure, 73 psig; 7

radiation, 2.62 x 10 rads; humidity, 100%/ steam; and an operability time of 137 days.

l The specified and demonstrated accuracies were found to be misleading in the applicant's files and CPS's FSAR Table 3.11-3. The interviewer was assured by the applicant that the demonstrated accuracy for this component was within the required accuracies and that the files and CPS's FSAR Table 3.11-3 will be updated to reflect this.

In conclusion this transmitter is qualified for the above use and documentation in the applicant's files support this.

40

WESTINGHOUSE CUSTOM 6.9 kV SWITCHGEAR PLANT I.D. NO. 1RR01E AND WESTINGHOUSE 6.9 kV BREAKER MODEL 75DHP500 PLANT I.D. NO. IRR01EA The purpose of this switchgear and associated breaker is to supply power to the reactor recirculation pumps and to trip the pumps on a receipt of a turbine trip signal. This equipment is located in the fuel building.

This a Category D (NUREG 0588 Appendix E) type equipment. This  ;

equipment is not required to operate under post DBA/HELB conditions. The

=aximum abnormal conditions under which this equipment is required to operate are; temperature, 104 F; pressure, atmospheric; radiation, 1 x 104rads TID; and humidity, 90%.

Qualification for this equipment is contained in a Westinghouse report prepared for IPC CPS Unit 1, Revision 2, dated 7/82. This document, along ,

with extensive evaluation performed by the applicant, demonstrated that this equipment is qualified to the above conditions. This evaluation resulted in a qualified TID of 3 x 105 rads and a qualified life, conservatively estimated by use of the 10*C rule, of 40 years (with the exception of four types of relays; COM-5, SSC-T, CO-11, and AR, which have a qualified life of 27 years).

The only item of concern for this equipment is that IPC should change CPS's FSAR Table 3.11-3 to reflect that this equipment is qualified to the maximum abnormal temperature of 104 F.

e 41

BBN ACCELEROMETER MODEL 424-ISO-TEC PLANT I.D. NO. JP/21-N800 AND )

TEC CHARGE CONVERTER MODEL 504B PLANI I.D. 1821-K550 Both of these components, along with associated cable, splice kits, l and transient shield, make up the SRVM system which provides an alarm when l the SRVs open. The original test done on these components (except the transient shield) resulted in failures of the charge converter. At this time a transient shield was incorporated into the design and another test performed on this system to qualify it for use inside the containment.

The maximum specified accident parameters for this system are:

Temperature, 330*F; pressure, 30 psig; radiation 2 X 100 rads TID; and humidity, 100%/ steam; and containment spray, demineralized water. The required operating time for this system is 100 days.

Qualification for this system is contained in Technology for Energy Corporation environmental qualification test report No. 517-TR-03, Revision 2, 12-1-81 and supporting documentation. The peak parameters in which this system is qualified to are: temperature, 400 to 500*F; pressure, 60 to 80 psig; radiation, 2.22 x 10 8rads TID; and humidity, 100%/ steam; and demineralized water spray. The demonstrated operating time for this system is >100 days. Various temperatures and times were used to thermally age the components of this system. Using the Arrhenius Methodology a qualified life for this system was established at 40 years.

All the components that make up this system that were tested in the above test report are the same as those that will be used at the Clinton Power Station. The only exception to this is that the instrument cable that is to be used at CPS is manufactured by Brand-Rex. The tested cable was manufactured by TEC.

This system was not installed at CPS at the time of the on-site audit and consequently not inspected during the plant walk down.

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In conclusion this system is qualified for the above use at CPS and documentation in the applicant's files supports this provided that the equipment actually installed at CPS can be verified to be the same in make, codel, and orientation, as those used in the test report and supporting documentation.

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WEED INSTRUMENT COMPANY RTD MODEL 611 This RTD.is part of the suppression pool water temperature assembly and is used in containment atmosphere monitoring. It is located in various Environmental Zones, the most severe being H-16 and H-27.

The maximum specified environmental parameters these RTDs are subjected to are: temperature, 330*F; pressure, 30 psig; relative humidity,100%; spray, demineralized water; submergence, pool swell; and radiation, 2.0 x 10 8rads TID. The specified operability time is 100 days.

. Testing has been performed on similar RTDs and is documented in

, National Technical Systems test report number 548-8854-2, Revision B. The maximum environmental parameters to which the RTDs were tested are:

temperature, 485'F; pressure, 75 psig; relative humidity, 100%; radiation, 3.0 x 108rads TID; chemical spray, pH 4 to 11; and operability time, l >124 day's. The_ tested equipment was not subjected to submergence, however, the methodology incorporated by the applicant to justify this was found acceptable. Thermal aging was performed on the test samples for

724 hrs at 304 F which demonstrates a 40 year life for the CPS environments.

None of these RTD's were completely installed at CPS at the time of the on-site audit and consequently a complete inspection of them was not

_ performed during the plant walk down.

In conclusion, the Weed RTDs are environmentally qualified and evidence of qualification is provided in the applicant's files provided that the RTDs actually installed at CPS can be verified to be the same in ~

- make, model, and orientation, as those used in the test report. ,

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1 CONAX AIRLOCK ELECTRICAL PENETRATION ASSEMBLY The Conax penetration is used to pass lighting and communications circuits into the containment.

The maximum specified environmental parameters to which the penetration may be exposed are: temperature, 185'F; pressure, 15 psig; humidity, 100%; radiation, 2 x 10 8rads; containment spray, demineralized water; possible submergence; and an operability time of 100 days.

Environmental testing is reported in Conax EQ report IPS-919 dated 8/18/82. The environmental parameters are: temperature, 255 F; pressure, 18 psig; relative humidity, 100%/ steam; radiation, 2.28 x 108 rads.

Thermal aging was accomplished by subjecting the penetration assembly to 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> at 250*F, yielding a qualified life of 40 years using Arrhenius Methodology. The tested equipment was not subjected to spray or submergence, however, the methodology incorporated by the applicant to justify this was found acceptable. _

In conclusion the Conax airlock electrical penetration assembly is qualified for the environment specified for CPS and documentation is contained in the applicant's file provided that the equipment actually installed at CPS can be verified to be the same in make, model, and orientation, as those used in the test report.

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s CONAX. MEDIUM VOLTAGE POWER PENETRATION ASSEMBLY The Conax penetration is used to pass medium voltage circuits into the containment.

The maximum specified environmental parameters to which the penetration may be exposed are: temperature, 185*F; pressure, 15 psig; humidity, 100%; radiation, 2 x 10 8rads; containment spray, demineralized water; and an operability time of 150 days.

Environmental testing is reported in.Conax test report IPS-750 Revision A dated 1-18-83. The environmental parameters are: temperature, 253 F; pressure, 23 psig; radiation 2.2 x 108rads; and humidity, 100%/ steam. Justification for spray was satisfactorily addressed in the applicant's file.

In conclusion the Conax medium voltage penetrations assembly is qualified for 40 years for the environment specified for CPS and documentation is contained in the applicant's file to support this.

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,, - <e CONAX LOW VOLTAGE POWER PENETRATION AND CONAX LOW VOLTAGE CONTROL AND INSTRUMENTATION PENETRATION ,

These penetrations are used to pass low voltage circuits, including control and instrumentation, into the containment. l l

l The specified environmental parameters to which the penetrations may be exposed are: temperature,185 F; pressure,15 psi'g ; radiation, 8

2 x 10 rads; humidity, 100%; containment spray, demineralized water; and an operability time of 100 days.

Environmental testing is reported in Conax test reports IPS 691 Revision A and IPS 692 Revision A. The environmental parameters are:

temperature, 255*F; pressure, 18 psig; radiation, 2.1 x 108 rads; and l humidity, 100%/ steam. Justification for spray was satisfactorily addressed in the applicant's file.

In conclusion the Conax low voltage power penetrations and low voltage control and instrumentation penetration assemblies are qualified for 40 years by type testing for the environments specified for CPS and documentation is contained in the applicant's file.

D 37424 47

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AC FOmas 338 U S seuCLif=8iKE#UL&TDKT COneusS5 Cas : *trO*** Nuwst M #Am paar te reoC sae won sce, .tenys

'"',"3di' BIBLIOGRAPHIC DATA SHEET .

st... ..uC..O~sO~ ,.E .t t. t EGG-EA-6829 3 tithe aND5utlifti J6tavtsta%a Audit of the Environmental Qualification of Safety-Related Electrical Equipment for the . O.,E.1,e2,Co ,st,t0 Clinton Power Station .Q~r- u.a l

..v,-0..., May 1985 e Davi a4POR1 e55vt3 uoNTw v4aR M. Trojovsky May 1985

) ,ERSORUeNG ORGANi2 AllON hAME AND WeeLING ADOmt55 r#acweele Comri a PROJ4CT4Y A5stwoan v4'1 Nvusta EG&G Idaho, Inc. * *'a ca Gaa~r au-sta Idaho Falls, ID 83415 A6415 sc !.PONSOneNG OmGawi2 47sO4 4 Awt ANO WestsNG aOORE 55 ffac4,se le Cesses its Tvrt OF REPopeT Division of Systems Integration Office of Nuclear Reactor Regulation .

Technical Evaluation Report U.S. Nuclear Regulatory Commission """"'"'"""'"

Washington, DC 20555 t) $vPPLEMENT Anv NOTtS 13 ag6T R ACT /J00 *erse er 'essJ The Clinton Power Station was audited to determine the environmental qualification of safety-related electrical equipment. Results of the audit are summarized in this report.

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$taTEVENT Unlimited 16 $ECLaiTv CLassiseCATION

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Unclassified IF AvuttRO5PAGES J

14 PaiCE 9

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. UNITED STATES NUCLEAR REGULATORY COMMISSION 14 .I wAssiscios. o. c. 2esss

%,,a . . * * ,o -

April 9, 1985

~

. MEMORANDUM FOR: Chaiman Palladino Comissioner Roberts .

Comissioner Asselstine Comissioner Bernthal Comissioner Zech FRCH: Sharon R. Connelly, Director

  • I Office of Inspector and Auditor

SUBJECT:

SHOREHAM CONSTRUCTION This is in respon'se to Chairman Palladino's March 26,19E5, memorandum requesting that we provide the Comission with a summary report about actions that have been taken or.will be taken relative to the alleged construction problems at Shoreham that were broadcast on the "60 Minutes" show.

The Office of Inspector and Auditor (OIA) reviewed a tape of the "60 Minutes" program as well as the Office of Public Affairs transcript. We have one past action pertaining to th'e alleged construction problems at Shoreham which was investigated in 1980 and completed as unfounded. At present, we have one ongoing inquiry concerning an allegation that NRC inspectors were unresponsive to information brought to their attention at the Shoreham Nuclear Station.

In addition to conducting the inquiry, we plan to contact the Assistant United States Attorney (AUSA), Eastern District of New York, who is handling

-the U.S. Department of Justice case on this issue. OIA will attempt to ascertain from the AUSA if any NRC employee is or was involved in this matter.

We will also advise the AUSA that our office shculd be contacted if NRC

'e6ployee involvement is identified in the future.

Further, we plan to essess the agency's action's in this matter to determine whether further OIA involvement is warranted.

We will keep you informed as to the results of our efforts, cc: OGC '

OPE SECY i.

CONTACT: Keith G. Logan, CIA 492-7170 4 l

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