ML20126L919

Safety Evaluation Re Environ Qualification of safety-related Electrical Equipment.No Outstanding Items Requiring Immediate Corrective Action.Completion of Corrective Actions by 820630 Will Ensure Compliance W/Nrc 800523 Memorandum

ML20126L919
Person / Time
Site:	Rancho Seco
Issue date:	05/29/1981
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML18086B701	List: ML20126L919 ML20126L925
References
IEB-79-01B, IEB-79-1B, TAC-42507, NUDOCS 8106100313
Download: ML20126L919 (28)

Text

A-A 1

(~)

\_/

/ '%, UNITED STATES j' "'

e NUCLEAR REGULATORY COMMISSION

• $ *. .' '.. s WASHINGTON, D. C. 20555

., ,,f

.%, u j

+....

SAFETY EVALUATION REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION EQUIPMENT QUALIFICATION BRANCH FOR SACRAMENTO MUNICIPAL UTILITY DISTRICT RAfiCHO SECO DOCKET NO 50-312 ,

1 1

1 l

<810 610 .0 3D l

e- w

. - . - ~ ~

3:

CONTENTS

. _Page L1 - Introduction ...........................-.................... 1 L2 Background ................................................. 1 2.'1 ' Purpose ................................................ 2 2.2 Scope ................................................. 2 3: Staff Evaluation ........................................... 2 3.-l' Completeness of Safety-Related Equipment ..............

2 3.2 Service Conditions ........ 1.......................... 3

+

3.3~ Temperature, Pressure, and Humidity Conditions

'Inside Containment .................................... 4 L 3.4 ' . Temperature, Pressure, and Humidity Conditions Outside Containment ................................... 4 ,

3.5; Submergence............................................ 5 3.6 LChemicalLSpray ........................................ 6 3.7 ' Aging ........i........................................ 6 3.8 -Radiation 1(Inside'and Outside Containment) ............ 6

~41 Qualification.of Equipment ................................. 7 l

4.1 Equipment. Requiring;Immediate Corrective Action ....... 7 4.2 Equipment Requiring Additional Information and/or

. Corrective' Action ...................................... 8 4.3 Equipment, Considered Acceptable or Conditionally Acceptable ............................................ 9 5 . Deferred Requirements'...................................... 9 6 . Conclusions ................................................ 10

. APPENDIX A ' Equipment Requiring Immediate Corrective Action APPENDIX B Equipment Requiring Additional'Information and/or Corrective' Action M)PENDIX C - Equipment Considered Acceptable or Conditionally Acceptable APPENDIX 0 Safety-Related Systems List Attachmen't'1 Letter from the Foxboro Company dated March 12, 1981, regarding the Model E11 and E13 transmitters t

I!

iii.

- . u . - .-  :. . .~. . , ,- -

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

4 SAFETY EVALUATION REPORT BY THE

. OFFICE OF NUCLEAR REACTOR REGULATION EQUIPMENT QUALIFICATION BRANCH  :

FOR SACRAMENTO MUNICIPAL UTILITY DISTRICT RA.'lCHO SEC0

~0OCKET N0. 50-312 ENVIRONMENTAL QUALIFICATION OF SAFETY-RELATED ELECTRICAL EQUIPMENT 1 INTRODUCTION i General. Design Criteria 1 and 4 specify that safety-related electrical equip-ment in nuclear facilities must be capable of performing its safety-related function-under. environmental conditions associated with all normal, abnormal, and accident plant operation. In order to ensure compliance'with the-cri-teria, the NRC staff. required all licensees of operating reactors to submit a reevaluation of the qualification of safety-related electrical equipment which may be exposed to a harsh environment.

2 BACKGROUND On February'8,1979,L the NRC Office of Inspection and Enfarcement (IE) issued

- to all licensees of' operating plants (except those included in the systematic evaluation program (SEP)) IE Bulletin IEB 79-01, " Environmental Qualification

of Class IE Equipment." .This bulletin, together with'IE Circular 78-08 (issued on May'31, 1978), required-the licensees to perform reviews to assess

.the. adequacy of their environmental qualification programs.

Subsequently, Commission Memorandum and Order CLI-80-21 (issued on May 23, 1980) states-that the 00R guidelines and portions of NUREG-0588 (which were issued aan. January 14, 1980,' as enclosures 4 and 5 to IEB-79-018) form the

. requirements-that licensees must meet regarding environmental qualification of safety-related electrical equipment in order to satisfy those aspects of 110 CFR 50, Appendix A, General Design Criterion (GDC)-4. This order also requires the staff to complete : safety evaluation reports (SERs) for all operating plants. by February 1,1981. In' addition, this order requires that the licensees have qualified safety-related equipment installed in their plants by June 30, 1982.

Supplements to IEB 79-018 were issued for further clarification and definition of the staf f's needs. These supplements were issued on February 29, September 30, and October 24, 1980.

In addition, the staff issued orders dated August 29, 1980 (amended in September, 1980) and October 24, 1980 to all licensees. The August order required that the licensees. provide a report, by November 1, 1980, documenting the qualification of safety-related electrical equipment. The October order required the establishment of a central file location for the maintenance'of all' equipment qualification records. The central file was F mandated to be established by December 1, 1980. The order also required that e all safety related electrical. equipment be qualified by June 30, 1982. In 4

6

-< w y ee.rr e~ w 6 h 4 e-- + W~ - -

k response, the licensee submitted information through letters dated March 3, May 5, October 31, 1980, and January 13, 1981. (A preliminary version of the January 13 submittal was reviewed by the staf f. )

2.1 Purpose The purpose of this SER is to identify equipment whose qualification program does not provide sufficient assurance that the equipment is capable of perform-ing the design function in hostile environments. The staff position relating to any identified deficiencies is provided in this report.

2.2 Scope The scope of this report is limited to an evaluation of the equipment, which must function in order to mitigate the consequences of a loss-of-coolant accident (LOCA) or a high-energy-line-break (HELB) accident, inside or outside containment, while subjected to the hostile environments associated with these accidents.

3 STAFF EVALUATION The staff evaluation of the licensee's response included an onsite inspection of selected Class IE equipment and an examination of the licensee's report for completeness and acceptability. The criteria described in the 00R guidelines and in NUREG-0588, in part, were used as a basis for the staff evaluation of the adequacy of the licensee's qualification program.

The NRC Office of Inspection and Enforcement performed (1) a preliminary evaluation of the licensee's response, documented in a technical evaluation report (TER) and (2) onsite verification inspections (April and December 1990) of selected safety-related electrical equipment. The containment isola-tion system was inspected. The inspe: Lion verified prcper installation of equipment, overall interface integrity, and manufacturers' nameplate data.

The manufacturer's name and model number from the nameplate data were compared to information given in the Component i. valuation Work Sheets (CES) of the licensee's report. The site inspectiy is documented in report IE 50-312/80-37.

No deficiencies were noted. For this review, the documents referenced above have been factored into the overall staff evaluation. I 3.1 Completeness of Safety-Related Eouipment In accordance with IEB 79-018, the licensee was directed to (1) establish a list of systems and equipment that are required to mitigate a LOCA and an HELB and (2) identify components needed to perform the function of safety-related display information, post-accident sampling and monitoring, and radiation monitoring.

The staff developed a generic master list based upon a review of plant safety analyses and emergency procedures. The instrumentation selected includes l parameter: to monitor overall plant performance as well as to monitor the per-formance of the systems on the list. The systems list was established on the basis of the functions that must be performed for accident mitigation (without I regard to location of equipment relative to hostile environments). l

The list of safety-related systems provided by the licensee was reviewed against the staff-developed master list.

Based 'on the licensee's submittal, the staff has concluded that the information on safety-related systems included in the. submittal is insufficient to verify that~those systems are all the systems required to achieve or support: (1) emergency reactor shutdown,-(2) containment isolation, (3) reactor core cooling, (4) containment heat removal, (5) core residual heat removal, and (6) prevention of significant release of radioactive material to the environment. The staff acknowledges the licensee's effort to include only those safety-related systems located in_a potentially harsh environment. However, this review requires the

. listing of all safety-related systems, both inside and outside potentially harsh _ environments. The list of safety-related systems submitted by'the

licensee'is included in Appendix D.

Display instrumentation which provides information for the reactor operators to aid them in the safe handling of the plant was not specifically identified by the licensee. A complete list of all display instrumentation mentioned in the'LOCA and_HELB emergency procedures must be provided. Equipment qualifi-cation information in the form of summary sheets should be provided for all

components of the display instrumentation exposed to harsh environments.

Instrumentation which is not-considered to be safety related but which is mentioned in the emergency precedure should appear on the list. For these

. instruments,.(1) justification should be provided for not considering the instrument safety related and (2) assurance should be provided that its subse-quent failure will not mislead the operator or adversely affect-the mitigation of-the' consequences of the accident.' The environmental cualification of post-accident sampling and monitoring and radiation monitoring equipment is closely-related to the review of the TMI Lessons-Learned modifications and

,will be performed in conjunction with that review.

LThellicensee' identified 204itemsofequipmentwhichwereassessedbythe staff.

3.2' Service Conditions Commission. Memorandum and Order CLI-80-21 requires that the 00R guidelines and the "For Comment" NUREG-0588 are to be used as the criteria for establishing the adequacy of the safety-related electrical equipment environmental quali-  !

fication' program. .These documents provide the option of establishing a bounding i pressure and temperature condition based on plant-specific analysis identified 1 in the licensee's Final Safety Analysis Report (FSAR) or based on generic profiles using the methods identified in these documents.

l On this basis,'the staff has assumed, unless otherwise noted, that the analysis for. developing the environmental envelopes for Rancho Seco relative to the; temperature, pressure, .and the containment spray caustics, has been performed j in accordance with the requirements stated above. The staff has reviewed the '

qualification documentation to ensure that the qualification specifications J env_ elope the conditions established by the licensee, During this review, the staff assumed that for plants designed and equipped with an automatic containment n .

-. aa <

. . . - . = - - -, ,, -,

4 spray system which satisfies the single-failure criterion, the main-steam-line-break'(MSLB) environmental conditions are enveloped by the large-break-LOCA environmentaliconditions. However; Rancho Seco has an automatic spray system with'a' delayed initiation. Therefore, in accordance with Section 4.2'.1 of'the DOR guidelines, equipment inside containment should be qui.ified for an MSLB environment. This is discussed in Section 3.3 below.

Equipment submergence has also been addressed where the possibility exists.

that flooding of equipment may result from HELBs.

.3.3 _ Temperature, Pressure, and Humidity Conditions Inside Containment The~ licensee has provided theLresults of accident analyses as follows:

Max Temo ( F) Max Press-(psig) Humidity (%)

a LOCA- 286 52 100

'The staff has concluded that the minimum teaperature profile for equipment qualification purposes should include a margin to account for higher-than-average temperatures in the upper regions of the containment that can exist due to

. stratification, especially following a postulated MSLB. Use of the steam

. saturation temperat'ure corresponding to the total building pressure (partial pressure of steam plus partial. pressure of air) sersus time will provide an acceptable margin for either a postulated 1.0CA or MSLB, whichever is control-111ng, as' to potential adverse environmental effects on equipment.

The licensee's specified temperature (service condition) of 286 F does not i satisfy the abo've requirement. A saturation temperature corresponding to the

. peak profile'(299 F peak' temperature at 52 psig) should be used instead. The l Hlicensee should update his equipment summary tables to reflect this change.

If there is'any eouipment that does not meet the staff position, the licensee l 'must provide either justification that the equipment will perform its intended l function under the specified conditions or propose corrective action.

The licensee states that the electrical equipment inside containment has been  ;

compared to the LOCA environment to determine qualification. .However, an r

. analysis is being performed to determine if tne LOCA qualification conditions exceed or are equivalent to the maximum calculated MSLB conditions. This i

analysis is scheduled for completion by June 30, 1981. If it is determined that the MSLB environmental conditions are not envelopeJ by the LOCA conditions, the licensee should then update his equipment work sheets and either show that the equipment is qualified to the MSLB environment or propose corrective action, c

3.4 Temperature, Pressure, and Humidity Conditions Outside Containment The licensee has provided the temperature, pressure, humidity and applicable environment associated with an HELB.outside containment. The following areas

outside containment have been addressed:

)

1 4

v w w + ,v .- (. yy -- ,ye --w w,.w - + , . . - , - r,~,,,-.

g (1) West deccy heat pump room (001)

. (2) East decay heat pump room (002)

(3) HPI pump room B (043)

(4) Make-up pump room (044)

(5) Seal return cooler room (046)

(6) East penetration room (051)

, ('7 ) West penetration room (052)

(8) HPI pump room A (053) s The staff has verifieo that the parameters identified by the licensee for the HELBs are acceptable, with the exception of Room 053, HPI pump room A. It was noted during the Decemcer 1980 IE site visit that the environmental profile for Room 053 does not include the effects of a break within the room of a steam line passing through the room. Instead, the profile shows the cunditions within the room as a result of a break external to the room. Therefore, the licensee should revise the ervironmental profile for this room and update the component work sheets accordingly.

3.5 Submergence The maximum subcergence levels have been established and assessed by the licensee. Unless otherwise noted, the staff assumed for this review that the methodology cmployed by the licensee is in accordance with the appropriate criteria as established by Commission Memorandum and Order CLI-80-21.

The licensee's value fnr maximum submergence is 8 ft. Equipment below this level has been identified by the licensca. The licensee identified 19 safety-related electrical components--8 Bailey Meter level transmitters, 8 Bailey Meter flow transmitters, 3 Limitorque motor operated valves, and associated Cerro cable and Scotch insulation tape-as having the potential for becoming submerged after a postulated event; The Cerro cable is qualified for submer-gence; the Bailey Meter level and flow transmitters perform their functions prior to submergence. The f.imitorque motor-operated valves are used only to isolate the letdown coolers in the event of a tube rupture in the coolers, and they will not be subject to submergence during ;his event. These valves are not required to operate after a LOCA when they could become submerged. The Scotch insulation tape is used to insulate connections on the above equipment which, as stated previously, either performs its functions before submergence or is not required when subject to submergence.

For the equipment items discussed above, the licensee should provide an assess-ment of the failure modes associated with their submergence. The licensee should also provide assurance that the subsequent failure of these components will not adversely affect any other safety functions or mislead an operator.

Additionally, the licensee should discuss operating time, across the spectrum of events, in relation to the time of submergence. If the results of the licensee's assessment are acceptable, then the equipment may be exempt from the submergence parameter of qualification It is r.ot clear from the information submitted that submergence of safety-related electrical equipment outside of containment was addressed. The licensee should address this area more specifically in the 90-day response and upgrade the CES as appropriate.

E  ; . 4 .- ,' 4 -

i s

m 4 3.6 Chemical Spray)

The licensee provided only_a value for the pH of the spray (that is, 9.3-9.5)

, and did not identify the concentration of boric acid. Further, no specific boric acid concentration or ~pH was given for the qualification environment.

Therefore, for the purpose of this review, the effects of chemical spray will <

be'. considered unresolved. The staff will review the-licensee's response when i it is submitted and discuss the resolution in a supplemental report.

-3.7 -Aging Section 7 of the 00R guidelines does not require a qualified life to be estab-

. lished for all safety-related electrical equipment. .However, the following

. e7 actions are required:  ;

(1) .Make a detailed comparison of existing equipment and the materials identi- "

fled in Appendix C of the 00R guidelines. The first supplement to IEB-79-018 requires licensees to utilize the table in Appendix C and  !

identify any additional materials as the result of their effort.

(2)' Establish an' ongoing program to review surveillance and maintenance records to identify potential age-related degradations.

(3)' Establish component maintenance and replacement schedules which include considerations of aging characteristics of the installed components.

, The licensee identified a number of equip ~.ent items for which a specified ,

. qualified life of 40 years was established. In its assessment of these l submittals,-the staff did not review the adequacy of the methodology nor the-basis used to arrive at these values; the staff has assumed that the established  !

values are based on state-of-the-art technology and are acceptable.

For this review, however, the staff requires that the licensee submit supple-mental information to verify and identify the degree of 'conformance to the I above requirements. The response should include all the equipment identified

as required to maintain functional operability in harsh environments.

.The licensee indicated that this phase of the response is outstanding and that the review is in progress. The staff will review the licensee's response when it is submitted and discuss its evaluation in a supplemental report.

.3. 8 Radiation (Inside and Outside Containment)-

The licensee has provided values for the radiation levels postulated to exist following a LOCA. The application and methodology employed to determine these values were presented to the licensee as part of the NRC staff criteria con-r tained in the 00R. guidelines, in NUREG-0588, and in the guidance provided in IEB-79-018, Supplement 2. Therefore, for this review, the staff has assumed that, unless otherwise noted, the values provided have been determined in

.accordance with the prescribed criteria. The staff review determined that the values t'o which equipment was qualified enveloped the requirements identified by the licensee.

t L <

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

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

l l

l The value required by the licensee inside containment is an integrated dose of

. 1 x 108 rads. This value envelopes the 00R guideline requirements and is therefore acceptable.

1 A required value outside containment of 5.5 x 107 rads has been used by the licensee to specify limiting radiation levels within Rooms ,001 and 002 of the auxiliary buil_ ding. This value appears to consider the radiation levels influ-enced by the source term methodology associated with post-LOCA recirculation fluid lines and is therefore acceptable.

4 QUALIFICATION OF EQUIPMENT The following subsections present the staff's assessment, based on the licensee's submittal, of the qualification status of safety-related electrical equipment.

The staff has separated th. safety-related equipment into three categories:

(1) equipment requiring immediate corrective action, (2) equipment requiring additional qualification information and/or corrective action, and (3) equip-ment considered acceptable if the staff's concern identified in Section 3.7 is satisfactorily resolved.

In its assessment of the licensee's submittal, the NRC staff did not review the methodology employed to determine the values established by the licensee.

However, in reviewing the data sheets, the staff made a determination as to the stated conditions presented by the licensee. Additionally, the staff has not completed its review of supporting documentation referenced by the licen-see (for example, test reports). It is expected that when the review of test reports is complete, the environmental qualification data baca established by the staff will provide the means to cross reference each supporting document to the rer'erencing licensee.

If supporting documents are found to be unacceptable, the licensee will be required to take additional corrective actions to either establish qualifi-cation or replace the item (s) of concern. This effort will begin in early 1981.

An appendix for each subsection of this report provides a list of equipment for which additional information and/or corrective action is required. Where appropriate, a reference is provided in the appendices to identify deficiencies.

It should be noted, as in the Commission Memorandum and Order, that the deficien-cies identified do not necessarily mean that equipment is unqualified. However, they are cause for concern and may require further case-by-case evaluation.

4.1 Eauicment Requiring Immediate Corrective Action Appendix A identifies equipment in this category. The licensee was asked to review the facility's' safety-related electrical equipment. The licensee's review of this equipment identified ASCO solenoid valves, NAMCO limit switches, Meletron pressure switches, and a Foxboro flow transmitter requiring immediate corrective action; therefore, licensee event reports (LERs) 80-43, 80-44, <

80-45, and 80-47 were submitted. The licensee has committed to replace all l these components, identified in the LERs, by June 30, 1982. Additionally, the  !

licensee has provided acceptable justification for interim operation before l this equipment is replaced. In this review, the staff nas not identified any ,

l I

other safety-related electrical equipment which is not able to perform its

. intended safety function during the time in which it must operate.

4.2 Equipment Reouiring Additional Information and/or Corrective Action Appendix B identifies equipment in this category, including a tabulation of deficiencies. The deficiencies.are noted by a letter relating to the legend (identified below), indicating that the information provided is not sufficient for _the qualification parameter or condition.

Legend R - radiation T - temperature QT qualification time RT - required time P - pressure H - humidity CS - chemical spray A - material-aging evaluation; replacement schedule; ongoing equipment surveillance S - submergence M - margin I - HELB evaluation outside containment not completed QM qualification method RPN - equipment relocation or replacement; adequate schedule not provided EXN - exempted equipment justification inadequate SEN separate-effects qualification justification inadequate QI qualification information being developed RPS equipment relocation or replacement schedule provided As noted in Section 4, these deficiencies do not necessarily mean that the equipment is unqualified. However, the deficiencies are cause for concern and require further case-by-case evaluation. The staff has determined that an acceptable basis to exempt equipment from qualification, in whole or part, can be established provided the following can be established and verified by the licensee:

(1) Equipment does not perform essential' safety functions in the harsh environ-ment, and equipment failure in the harsh environment will not impact

$afety-related functions or mislead an operator.

-(2a/ Equipment performs its function before its exposure to the harsh environ-ment, and the adequacy for the time margin provided is adequately justified, l and (2b) Subsequent failure of the equipment as a result of the harsh environment does not degrade other safety functions or mislead the operator.

c L (3) .The safety-related function can be accomplished by some other designated l equipment that has been adequately qualified and satisfies the single-failure criterion.

(4) Equipment will not be subjected to a harsh environment as a result of the postulated accident.

l '

The licensee is, therefore, required to supplement the information presented by providing resolutions to the deficiencies identified; these resolutions should include a description of the corrective action, schedules for its completion (as applicable), and so forth. The staf f will review the licensee's response, when it is submitted, and discuss the resolution in a supplemental report.

It should be noted that in cases where testing is being conducted, a condition ma'y arise which results in a determination by the licensee that the equipment does not satisfy the qualification test requirements. For that equipment, the licensee will be required to provide the proposed corrective action, on a timely basis, to ensure that qualification can be established by June 30, 1982.

4.3 Eouic ent Considered Acceptable or Conditionally Acceptable Based on the staf f review of. the licensee's submittal, the staf f identified the equipment in Appendix C as (1) acceptable on the basis that the qualifi-

_1 cation program adequately enveloped the specific environmental plant parameters, or (2) conditionally acceptable subject to the satisfactory resolution of the staff concern identified in Section 3.7.

For the equipment identified as conditionally acceptable, the staff determined that'the licensee did not clearly (1) state' that an equipment material evaluation was conducted to ensure that no known materials susceptible to degradation because of aging have been

-used, (2) establish an ongoing program to review the plant surveillance and main-tenance records in order -to identify equipment degradation which may be age related, and/or (3) propose a maintenance program and replacement schedule for equipment l identified in item 1 or equipment that is qualified for less than the I life of the plant.

The licensee is, therefor , required to supplement the information presented for equipment in this category before full acceptance of this equipment can be established. The staff will review the licensee's response when it is sub-mitted and discuss the resolution in a supplemental report.

5 DEFERRED REQUIREMENTS IEB 79-018, Supplement 3 has relaxed the time constraints for the submissica of the information associated with cold shutdown equipment and TMI lessons-learned modifications. The staff has required that this information be provided by February 1,1981. The staff will provide a supplemental safety evaluation addressing these concerns.

l

6 CONCLUSIONS The staff has determined that the licensee's listing of safety-related sjatems and associated electrical equipment whose ability to function in a harsh environment following an accident is required to mitigate a LOCA or HELB is complete and acceptable, except as noted in Section 3 of this report. The staff has also determined that the environmental service conditions to be met by the electrical equipment in the harsh accident environment are appropriate, except as noted in Section 3 of this report. Outstanding information identified in Section 3 should be provided within 90 days of receipt of this SER.

The staff has reviewed the qualification of safety-related electrical equip-ment to the extent defined by this SER and, because the licensee has committed to replace the components identified in Section 4.1 of this SER and has provided acceptable justification for interim operation, has found no outstanding items which would require immediate corrective action to ensure the safety of plant operation. However, the staff has determined that many items of safety-related electrical equipment identified by the licensee for this review do not have adequate documentation to ensure that they are capable of withstanding the harsh environmental service conditions. This review was based on a comparison of the qualification values _with the specified environmental values required by the design, which were provided in the licensee's summary sheets.

Subsection 4.2 identified deficiencies that must be resolved to establish the qualification of the equipment; the staff requires that the information lack-ing in this category be provided within 90 days of receipt of this SER.

Within this period, the licensee should either provide docun-entation of the missing qualification information which demonstrates that such equipment meets the 00R guidelines or NUREG-0588 or commit to a corrective action (requalifi-cation, replacement, relocation, and so forth) consistent with the requirements to establish qualification by June 30, 1982. If the latter option is chosen, the licensee must provide justification for operation until such corrective action is complete.

Subsection 4.3 identified acceptance and conditional acceptance based on noted de ficiencies. Where additional information is required, the licensee should respond within 90 days of receipt of this SER by providing assurance that these concerns will be satisfactorily resolved by June 30, 1982.

The staff issued to the licensee Sections 3 and 4 of this report and requested, I under the provisions of 10 CFR 50.54(f), that the licensee review the deficien-cies enume.ated and the ramifications thereof to determine whether safe operation ,

of the facility would be impacted in consideration of the deficiencies. The l licensee has completed a preliminary review of the identified deficiencies and I has determined that, after due consideration of the deficiencies and their ramifications, continued safe operation would not be adversely affected.

Based or these considerations, the staff concludes that conformance with the above requirements and satisfactory completion of the corrective actions by June 30, 1982 sill ensure compliance with the Commission Memorandum and Order ,

of May 23, 1980. The staff further concludes that there is reasonable l assurance of continued safe operation of this facility pending completion of tnese corrective actions. This conclusion is based on the following: i l

e 1

6-(1)' that there are no outstanding items which would require immediate correc-tive action to assure safety of plant operation (2) some of the items found deficient have been or are being replaced or relocated, thus improving the facility's capability to function following a LOCA or HELB (3) the harsh environmental conditions for which this equipment must be

. qualified result from low probability events; events which might reasonably be anticipated during this very limited period would lead to less demanding service conditions for this equipment.

(

i e

APPENDIX Al Equipment Requiring Im. mediate Corrective Action (Category 4.1)

LEGEND:

Designation for Deficiency R - Radiation T - Temperature QT - Qualification time RT - Required time P - Pressure H - Humidi ty CS - Chemical spray A - Material aging evaluatior, replacement schedule, ongoing equipment surveillance 5 - Submergence M - Margin I - HELB evaluation outside containment not completed QM - Qualification method RPN - Equipment relocation or replacement, adequate schedule not provided EXN - Exempted equipment justification inadequate SEN - Separate effects quali'ication justifi:ation inadequate QI - Qualification information being developed RPS - Equipment relocation or replacement schedule provided Equipment Description Manufacturer Plant 10 No. Deficiency Limit Switch NAMCO SFV22009 QT,T.P,H,R,A,RPS Limit Switch NAMCO SFV24013 QT,T,P,H,R,A,RPS Limit Switch NAMCO SFV46014 QT,T,P,H,R,A,RPS Limit Switch NAMCO SFV46204 QT,T,P,H,R,A,RPS Limit Switch NAMCO SFV46906 QT,T,P,H,R,A,RPS 1

'Ine licensee has provided acceptable justification for interim operation for I all the components in this appendix and, therefore, no immediate corrective action is required. These components are listed in this appendix only because an LER was submitted.

W A-1

a. ,

I

. APPENDIX A (Continued)

Equipment Descriotion Manufacturer Plant 10 No. Deficiency Limit Switch NAMC0 SFV46908 QT,T,P,H,R,A,RPS Limit Stitch NAMCO SFVS3610 QT,T,P,H,R,A,RPS Lim t Switch NAMC0 SFV60002 QT,T,P,H,R,A,RPS Limit Switch a NAMCO SFV60004 QT,T,P,H,R,A,RPS Limit Switch NAMC0 SFV66309 QT,T,P,H,R,A,RPS Limit Switch NAMCO SFV70002 QT,T,P,H,R,A,RPS Limit Switch NAMC0 SFV72502 QT,T,P,H,R,A,RPS Limit Switch NAMCO SFV92520 QT,T,P,H,R,A,RPS Solenoid Valve ASCO SFY22009 QT,T,P,H,R,A,RPS Solenoid Valve ASCO SFY24013 QT,T,P,H,R,A,RPS Solenoid Valve ASCO SFY46014A QT, T,P,H,R, A,RPS Solenoid Valve ASCO SFY460148 QT,T,P,H,R,A,RPS

- Solenoid Valve ASCO SFY46026 QT,T,P,H,R,A,RPS Solenoid Valve ASCO SFY46027 QT,T,P,H,R,A,RPS Solenoid Valve ASCO SFY46028 QT,T,P,H,R,A,RPS Solenoid Valve ASCO SFY46029 QT,T,P,H,R,A,RPS Solenoid Valve ASCO SFY45204 QT,T,P,H,R,A,RPS Solenoid valve GC0 SFY46225 QT,T,P,H,R,A,RPS Solenoid Valve xSCO SFY46906A QT,T,P,H,R,A,RPS Solenoid Valve ASCO SFY469068 QT,T,P,H,R,A,RPS Solenoid Valve ASCO SFY46908 QT,T,P,H,R,A,RPS Solenoid Valve ASCO SFY46919 QT,T,P,H,R,A,RPS 1

A-2 l

l j

1.

APPENDIX A (Continued)

Equipment Descriotion Manufacturer Plant 10 No. Deficiency Solenoid Valve ASCO SFY46920 QT,T,P,H,R,A,RPS Solenoid Vcive ASCO SFY46921 QT,T,P,H,R,A,RPS Solenoid Valve ASCO SFY46922 QT,T,P,H,R,A,RPS Solenoid Valve ASCO SFY46923 QT,T,P,H,R,A,RPS Solenoid Valve ASCO SFYS3610 QT,T,P,H,R,A,RPS Solenoid Valve ASCO SFY60002 QT,T,P,H,R,A,RPS

- Solenoid Valve ASCO SFY60004 QT,T,P,H,R,A,RPS Solenoid Valve. ASCO SFY66309 QT,T,P,H,R,A,RPS Solenoid Valve ASCO SFY70002 QT,T,P,H,R,A,RPS Solenoid Valve ASCO SFY72502 QT,T,P,H,R,A,RPS Solenoid Valve ASCO SFY92520A QT,T,P,H,R,A,RPS Solenoid Valve ASCO SFY925208 QT,T,P,H,R,A,RPS

^ Flow Transmitter Foxboro FT20001 QT,T,P,H,CS,R,A,RPS

. Pressure Switch Meletron PSL20601 QT,T,P,H,CS,R,A,RPS

' Pressure. Switch Meletron PSL20602 QT,T,P,H,CS,R,A,RPS Pressure Switch Meletron PSL20603 QT,T,P,H,CS,R,A,RPS Pressure Switch Meletron PSL20604 QT,T,P,H,CS,R,A,RPS l Pressure Switch Meletron PSL20605 QT,T,P,H,CS,R,A,RPS Pressure Switch Meletron PSL20606 QT,T,P,H,CS,R,A,RPS l 1

Pressure Switch Meletron PSL20607 QT,T,P,H,CS,R,A,RPS l l

Pressure Switch Meletron PSL20608 QT,T,P,H,CS,R,A,RPS l

• See Attachment 1: Foxboro letter (3/12/81), " Potential Deficiency Af fecting Foxboro Transmitters," for corrective action. ,'

A-3 t -

, - ^:-

~ ^

APPENDIX 8 Equipment Requiring . Additional-Information and/or Corrective Action 1 (Category 4.2)

LEGENDi

. 0EsignationforDeficiency R - Radiation'.

T - Temperature .

1QT - Qualification time

'RTc . Required time

'P - Pressure ,

"H - Humidity-

CS - Chemical spray

.A'- Material aging evaluation, replacement schedule, ongoing equipment surveillance LS --Submergence

.M Margin I HELB evaluation outside containment not completed QM - Qualification method

..RPN - Equipment relocation or replacement, adequate schedule not provided EXN -' Exempted.equipmen' 'ustification: inadequate SEN - Separate effect alification' justification inadequate QI.-; Qualification ii.. mation being developed RPS'" Equipment. relocation'orLreplar,ement schedule provided  :

4' ' Equipment-

Description Manufacturer Plant ID No. De ficiency

~ Mot'or Operated Valve Limitorque HV20609 CS,A Motor Operated Valve 'Limitorque. HV20610 CS,A Motor Operated Valve Limitorque HV20611 QT,T,P,H,R,A

-' Motor Operated Valve Limitorque SFV22023 T,P,CS,R,A Motor Operated Valve Limitorque SFV24004 CS,A Motor Operated' Valve Limitorque SFV46203 CS,A LMotor Operated Valve. Limitorque. SFV46907 CS,R,A Motor Operated '/alve Li,94 torque SFV53504 QT,T,P,H,CS,R,A

' Motor Operated valve .Limitorque SFV53603 CS,R,A B-1 -

AP'ENDIX B (Continued)

' Equipment Description Manufacturer Plant ID No. Deficiency Motor Operated Valve Limitorque SFV53605 QT,T,P,H,CS,R,A Motor Operated Valve Limitorque SFV60001 CS,A Motor Operated Valve Limitorque SFV60003 R,A Motor Operated Valve Limitorque SFV70001 QT,T,P,H,CS,R,A Motor Operated Valve Limitorque SFV70003 QT,T,P,H,CS,R,A Motor Operated Valve Limitorque SFV72501 CS,R,A Level' Transmitter Bailey Meter LT26505 QT,T,P,H,CS,R,A Level Transmitter Bailey Meter LT26506 QT,T,P,H,CS,R,A Level Transmitter Bailey Meter LT26507 QT,T,P,H,CS,R.,A Level Transmitter Bailey Meter LT26508 QT,T,P,H,CS,R,A Motor Allis Chalmers A5290 QM Motor Allis Chalmers A529E QM Motor- Westinghouse P261A QM Motor Westinghouse P2618 QM Flow Transmitter Bailey Meter FT26048 M,A Flow Transmitter Bailey Meter FT26049 M,A Flow Transmitter Bailey Meter FT26003 QT,T,P,H,R,A,RPS Flow Transmitter Bailey Meter FT26004 QT,T,P,H,R,A,RPS Motor Operated Valve Limitorque HV20001 CS,A Motor Operated Valve Limitorque HV20002 CS,A Motor Operated Valve Limitorque HV20003 QT,T,P,H,CS,R,A Motor Operated Valve Limitorque HV26008 T,M,A Motor Operated Valve Limitorque HV26038 T,M,A B-2 '

l

APPENDIX B (Continued) e Equipment Description Manufacturer Plant ID No. Deficiency Motor Operated Valve Limitorque HV26105~ R,A Motor Operated Valve Limitorque HV26106 R,A Motor Operated Valve Limitorque SFV25003 T,R,A Motor Operated Valve Limitorque SFV25004 R,A Motor Operated Valve -Limitorque SFV26005 T,R,A Motor Operated Valve Limitorque SFV26006 T,R,A Motor Operated Valve Limitorque SFV26040 T,M,A Limit Switch NANCO HV20001-300 T,P,H,CS,A Limit Switch NAMC0 HV20001-330 T,P,H,CS,A Motor Joy A500A CS,A Motor Joy A5008 CS,A Motor Joy ~ A500C CS,A Motor Joy A5000 CS,A Motor Joy A532A CS,A Motor Joy A5328 CS,A Motor Joy A532C CS,A Motor Joy A532D CS,A Level Transmitter Bailey Meter LT20503A CS,A,5,M Level Transmitter Bailey Meter LT205038 CS,A,5,M Level Transmitter Bailey Meter LT20503C CS,A,5,M Level Transmitter Bailey Meter LT20503D CS,A,S,M Level Transmitter Bailey Meter LT20504A CS,R,A,5 Level Transmitter Bailey Meter LT20504B CS,R,A.S B-3 1

._ . ~ . .. . .

1

.' l l

l APPENDIX 8 (^ontinued) 4 Equipment

- Description Manufacturer Plant IO No. Deficiency Level Transmitter Bailey Meter LT20504C CS,R,A,5 Level Transmitter Bailey. Meter LT205040 CS,R,A,S Motor Operated Valve Limitorque SFV26016 T,M,A Motor Operated Valve Limitorque SFV26018 T,M,A Motor Operated Valve Limitorque SFV50005 R,A Motor Operated Valve Limitorque SFV50006 R,A Motor Operated Valve Limitorque' SFV50007 R,A Motor Operated valve Limitorque SFV50008 R,A Motor Operated Valve Limitorque SFV50009 R,A Motor Operated Valve Limitorque SFV50010 R,A

- Motor Operated Valve Limitorque SFV50011 R,A Motor Operated Valve Limitorque SFV50012 R,A Motor Westinghouse P291A QM,A Motor Westinghouse P2918 QM,A Motor Operated Valve Limitorque SFV29015 R,A Motor Operated Valve Limitorque SFV29016 R,A Motor Operated Valve Limitorque SFV29107 QT,T,P,H,R,A Motor Operated Valve Limitorque SFV29108 QT,T,P,H,R,A Motor Operated Valve Limitorque HV21505 CS,A Motor Operated Valve Limitorque HV21515 QT,T,P,H,CS,R,A Motor Operated Valve Limitorque HV21517 CS,A Motor Operated Valve Limitorque HV22005 CS,A,5 Motor Operated Valve Limitorque HV22006 CS,A,5 f

9 8-4

• l l

APPENDIX B (Continued)

Equipment Description Manufac turer Plant 10 No. Deficiency l

Motor Operated Valve Limitorque HV22025 QT,T,P,H,CS,R,A,5 Level Transmitter Bailey Meter LT21503A CS,R,A Level Transmitter Bailey Meter LT215038 CS,R,A Level Transmitter Bailey Meter LT21503C CS,R,A Temp. Element Rosemount TE21023A QM,CS,A,M Temp. Element Rosemount TE210238 QM,CS,A,M Temp. Element Rosemount TE21024A QM,CS,A,M Temp. Element Rosemount TE21024B QM,CS,A,M Temp. Element Rosemount TE21031A QM,CS,A,M Temp. Element Rosemount TE210318 QM,CS,A,M Temp. Element Rosemount TE21032A QM,CS,A,M Temp. Element Rosemount TE210328 QM,CS,A,M Flow Transmitter Bailey Meter FT21027A CS,M,A,5 Flow Transmitter Bailey. Meter FT210278 CS,M,A,5 Flow Transmitter Bailey Meter FT21027C CS,M,A,5 Flow Transmitter Bailey Meter FT210270 CS,M,A,5 Flow Transmitter Bailey Meter FT21028A CS,M,A,5 Flow Transmitter Bailey Meter FT210288 CS,M,A,5 Flow Transmitter Bailey Meter FT21028C CS,M,A,5 Flow Transmitter Bailey Meter FT210280 CS,M,A,5 Pressure Switch Mercoid PSH53606 QT,T,P,H,R,A Pressure Switch Mercoid PSH53617 QT,T,P,H,R,A Pressure Switch Mercoid PSH53619 QT,T,P,H,R,A B-5

- _ _ _ _ _ _ _ _ _ _ ~ - -

APPENDIX B (Continued)

Equipment Description Manufacturer Plant ID No. Deficiency Pressure Switch Mercoid PSH53620 QT,T,P,H,R,A Pressure Transmitter Westinghouse PT21037 QT,T,P,H,CS,R,A,RPS Pressure Transmitter Westinghouse PT21038 QT,T,P,H,CS,R,A,RPS Pressure Transmitter Westinghouse PT21039 QT,T,P,H,CS,R,A,RPS Pressure Transmitter Westinghouse PT21040 QT,T,P,H,CS,R,A,RPS Temp. Element Rosemount TE21029 CS,M,A,QM Temp. Element Rosemount TE21030 CS,M,A,QM Temp. Element Rosemount TE21033 CS,M,A,QM Temp. Element Rosemount TE21034 CS,M,A,QM

• Pressure Transmitter Foxboro PT21042 CS,R,A,QM

• Pressure Transmitter Foxboro PT21043 CS,R,A,qM

• Pressure Transmitter Foxboro PT21092 CS,R,A,QM

• Pressure Transmitter Foxboro PT53606B T,R,A,QM

• Pressure Transmitter Foxboro PT53607 R,A,QM,M

• Pressure Transmitter Foxboro PT53608 M,R,A,QM Pressure Transmitter Rosemount PT21099 CS,R,A,QM Motor Allis Chalmers A529A T,A,QM Motor Allis Chairrers A529B T,A,QM Motor Allis Chalmers A529C T,A,QM Motor Westinghouse P236 T,A,QM Motor Westinghouse P238A T,A,qM Motor Westinghouse P2388 T,A,QM Flow Transmitter Bailey Meter FT23606 QT,T,P,H,R,A

• See Attachment 1: Foxboro letter (3/12/81), " Potential Deficiency Affecting '

Foxboro Transmitters," for corrective action.

B-6

4 APPENDIX B (Continued)

Equipment Description Manufacturer Plant ID No. Deficiency Flow Transmitter Bailey Meter FT23805 QT,T,P,H,R,A Flow Transmitter Bailey Meter FT23806 QT,T,P,H,R,A Flow Transmitter Bailey Meter FT23807 QT,T,P,H,R,A Flow Transmitter Bailey Meter FT23808 QT,T,P,H,R,A Switch I.T.E Imperial HSDP236 QT,T,P,H,R,A Switch GE HSP23508 QT,T,P,H,R,A Switch GE H8PA5298 QT,T,P,H,R,A Motor Operated Valve Limitorque HV23801 QT,T,P,H,CS,R,A Motor Operated Valve Limitorque HV23802 QT,T,P,H,CS,R,A Motor Operated Valve Limitorque SFV23508 QT,T,P,H,R,A Motor Operated Valve Limitorque SFV23604 R,A Motor Operated Valve Limitorque SFV23616 T,M,A Motor Operated Valve Limitorque SFV23809 R,A Motor Operated Valve Limitorque SFV23810 R,A Motor Operated Valve Limitorque SFV23811 R,A Motor Operated Valve Limitorque SFV23912 R,A Electrical Penetrations Conax H7RP CS,M,A Cable Cerro Various T,CS,A Containment ,

l Terminal Blocks Kulka Various CS,R,A l Containment l l

Terminal Blocks Square O Various QT,T,P,H,R,A,RPS Outside 1 l

Containment Insulation Tape Scotch Various QT,T,P,H,CS,R,A,5,RPS Containment ,

l

,1 B-7 -

1 i

4

-'s I

1 APPENDIX B (Continued)

Equipment Gescription Manufacturer Plant 10 No. Deficiency Motor Operated Valve Limitorque HV26007 T,A Notor Operated Valve Limitorque HV26037 T,A Mc'or Operated Valve Limitorque HV26046 M,A Motor Operated Valve Limitorque HV26047 M,A Motor Operated Valve Limitorque HV26039 T,A Motor Operated Valve Limitorque SFV26017 T,A Motor Operated Valve Limitorque SFV26019 T,A Motor Operated Valve Limitorque SFV23645 M,A Motor Operated Valve Limitorque . 723646 M,A 1

e B-8

APPENDIX C Equipment Considered Acceptable or Conditionally Acceptable (Category 4.3)

LEGEND:

Designation for Deficiency R - Radiation T - Temperature QT - Qualification time RT - Required time P - Pressure H - Humidity CS - Chemical spray A - Material aging evaluation, replacement schedule, ongoing equipment surveillance 5 - Submergence M - Margin I - HELS evaluation outside containment not completed QM - Qualification method RPN - Equipment relocation or replacement, adequate schedule not provided EXN - Exempted equipment justification inadequate SEN - Separate effects qualification justification inadequate QI - Qualification information being developed RPS - Equipment relocation or replacement schedule provided Equipment Description Manufacturer Plant ID No. Deficiency Motor Operated Valve Limitoeque SFV66308 A 600 V Power Control Cerro Various A and Instrumentation Aux. Building Cable

')

C-1

o j 4

i l

i APPENDIX 0 1

Safety-Related Systems List ,

Containment Isolation System i Core Flood System l

~

Control Rod Drive Decay Heat

]

Heating Venting System Main Feedwater System Main Steam System Nuclear Service Cooling-Water System Reactor Building Spray System  !

Reactor Coolant System Reactor Protection System Safety Feature System Seal Injection and Makeup System Interfaces l

l 1

i c

)

1As submitted by licensee.

D-1 i

. 1 ATTACHMENT 1 Foxboro, MA 02005 U.S A I The Foxboro Company smsomo l l

12 March 1981

Subject:

Potential Deficiency Affecting Foxboro Trans=itters, Model Nu=bers N-Ell, N-E13 or Ell, E13 vich suffix Codes /MCA, /MCA/R17, or /MCA/RR Gentlemen:

Our records indicate that you have received one or = ore of the Foxboro =odel nu=bered trans=itters listed above. This letter is to notify you that two deficiencies have been discovered in some of these transeitters which =sy exist in the units shipped to you. The trans=it:ers in question operate at a signal level of 10-50=A. Si=1lar =edel nu=bered units operating at 4-20=A are not affected.

The first issue involves the possible use of incorrect insulating sleeving on transistor and :ener diode lead wires in the a=plifier. The second issue involves the use of a specific vendor's capacitor which is not her=etically sealed (al: hough clai=ed to be so) . As a result, the capacitor electrolyte can leak under adverse service condicions, specifically heat and ti=e. The failure code is a decrease in resistance across the capacitor resulting in electrical leakage. The trans=1:ter opera: ion can be af fected by 11=iting the output to so=ething less than full value which, in ti=e, can degrade to no output at all.

Lusulating Sleeving - Radiation resistant sleeving consisting of a silicone coated glass fiber braid has been substituted by a teflon sleeving in so=e tr ans=it:er s . Tests have shown that teflon will beco=e bri::le and deteriors:e with a substantial integrated radia:1on dose. Foxboro testing has de= ens::sted tha: the teflon sleeving used in these devices vill withstand an integrated dose of 10 =egarads with no no:1ceable de:eriora:1on. Tests to 200 =egarads produce the brittle conditions which can result in the :eflon flaking f rc= the wires.

Based en these tests, operating plants not expected to exceed an integrated dose of 10 megarads have no potential proble: and no action is required.

Where :he integrated dose rate could exceed 10 =egarads, then uni:s in service should be inspec:ed to deter =ine if the proper insula:ing =aterial has been l used. This can be acce=plished by opening the trans=itter in accordance with l Foxboro Master Instruction M: 20-145. The a=plifier cover =ust be re=cved l

exposing the a=plifier asse=bly. At one end of the asse=bly, a transistor and '

a :ener diode are =ounted in the' base casting which serves as a heat sink. The insulating =a:erial in question is a sleeving slipped over the lead s ites fres these two co=ponents. The proper =aterial is white and heavy looking. Posi:ive i

?OXBORQ N .!

l

o, l 1

Page 2 12 Marck 1981 l

Subject:

l l

identification can be =ade by inspecting one end of the =atertal to establish that the outer =aterial covers an inner braid. Tef'.on, if used , vill be a single layer =aterial and could be either e. lear or white.  ;

i If i= proper insulation is present, then the corrective action is to replace the-a=plifier (Foxboro P/N N0148PW) . Replace =ent a=plifiers can be purchased fec=  !

your local Foxboro Sales or Service Representatives. If you prefer to have Foxboro Service Personnel inspect the equip =ent and, if necessary, replace the a=plifier, this can be arranged at standard service rates.

Cacacitor - The capacitor degradation proble= vas discovered over time thr'ough tracking f ailure situations. Internal corrective action has been taken to re=ove the vendor involved fro = the qualified vendor list and to purge all stock of capacitors fro = this vendor. Degradation of this capacitor is a function of ti=e and service conditions with here being a pri=ary contributor. This phene =enen was observed in 'recent tests of trans=1tters using these capacitors. The capacitor in question is =anuf actured by Cornell-Duebilier and can be specifically identified by a type nu=ber in the for= TX-o5-:CCCC as well as a monogra= in a box followed by a date code, e.g. {CDE 0874 l . It is assigned Foxboro part nu=ber N0141MF.

To_ deter =ine if this capacitor is present requires a v'isual inspection of the a=plifier which can be acco=plished as described above for the insulating sleeving insp ection. The' reco== ended corrective action should the above described capaciter be present is to replace the a=plifier (Foxboro P/N 50148?W) although is is possible to replace the capacitor with a Foxboro provided substitute. Use of Foxboro Service personnel to perfor= the inspection and replace =ent, if necessary, can be arranged at standard service rates as described above.

Due to lack of knculedge of specific application, redundancy, and the like, Foxboro cannot decor =ine if the NRC reporting require =ents of 10CFR ? art 21 are applicable.

This deter =ination is the tesponsibility of the user and any such reporting would be =ade by the= af ter co=pleting their evaluation of the situation.

If you have any questions regarding the above, please contact the undersigned directly.

Very truly yours ,

TEE FOI30R0 COMPANY e

Willia = Calder, . nager Corporate Quality Assurance joy 120381 Enclosure MI 20-145 IOXBORO

-mm- -mem, .

.