ML20023C373

Forwards Response to Open Items Identified in Franklin Research Ctr Technical Evaluation Rept Re Environ Qualification of Electrical Equipment

ML20023C373
Person / Time
Site:	Mcguire, McGuire
Issue date:	05/11/1983
From:	Tucker H DUKE POWER CO.
To:	Adensam E, Harold Denton Office of Nuclear Reactor Regulation
References
NUDOCS 8305170277
Download: ML20023C373 (29)

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DUKE POWER GOMPANY P.O. HOX 33180 CHARLOTrE. N.C. 28242 HALB. TUCKER TELEPHONE vna Paensmen (704) 373-4531 muean PmODUCTRON May 11, 1983 4

Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Ms. E. G. Adensam, Chief Licensing Branch No. 4 Re: McGuire Nuclear Station Docket Nos. 50-369, 50-370 J

Dear Mr. Denton:

Attached is Duke Power Company's response to open items identified in the Franklin Research Center Technical Evaluation Report (TER) concerning environmental qualification of electrical equipment for McGuire Nuclear Station.

Although the TER references only McGuire Unit 1, the equipment covered by the TER and the associated resolutions apply equally to McGuire Unit 2 unless specifically stated otherwise.

Please advise if there are additional questions regarding this matter.

Very truly yours, b l./g Hal B. Tucker GAC/php

, Attachment l cc: Mr. James P. O'Reilly, Regional Administrator l U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900

-l Atlanta, Georgia 30303 Mr. W. T. Orders NRC Senior Resident Inspector McGuire Nuclear Station 8305170277 830511 '

PDR ADDCK 05000369 PDR p

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MCGUIRE NUCLEAR STATION - UNITS 1 AND 2 RESOLUTION OF NRC/FRC TECHNICAL EVALUATION REPORT ITEMS The attached information provides the resolutions for items identified in the NRC/FRC Technical Evaluation Report (TER) for McGuire Nuclear Station.

Attachment 1 is a table that identifies the TER Items and provides a reference to the appropriate resolution. Attachment 2 provides a discussion of the resolutions for each category with additional detail on certain items for clarification purposes or as requested by the Staff. Attachment 3 provides justification for interim operation (JIO) for the TER items still pending completion of qualification. It should be noted that although the TER references McGuire Unit 1, the equipment covered by the TER and the associated resolutions apply equally to McGuire Unit 2 unless specifically stated other-wise. The resolutions provided herein are consistent with those discussed with the NRC Staff on March 29, 1983.

In addition to the attached infomation which addresses specific equipment items, the following paragraphs address specific issues contained in Section 4.3 of the TER.

TER Paragraph 4.3.3.3 - Nuclear Radiation Dose With regard to radiation dose, the McGuire NUREG 0588 submittal identifies certain equipment as being exposed $o a total radiation dose less than the NRC Staff's screening value of 4X10' Rads. In Duke's response to the NRC's previous Equipment Qualification SER for McGuire, we stated that the equipment which has a 40 year normal dose plus accident dose less than the NRC Staff's screening value is only required for a short term function and is therefore not exposed to a high radiation dose prior to performing its safety function.

Additionally, to support the radiation values identified in the McGuire NUREG 0588 submittal, Duke Power Company has provided to the NRC Staff a radiation analysis including bases, assumptions, and sample dose calculations (Ref.

Duke Power Company letters from H. B. Tucker to H. R. Denton dated February 14 and March 21, 1983).

TER Paragraph 4.3.5 - Submergence With regard to submergence, Duke's response to the NRC's previous SER states that in a review of the safety-related motor operated valves located below the maximum post-LOCA water level, it was determined that for all defined events l the valve motor operators will perform their safety function prior to becoming submerged. The flood level will reach the lower most safety-related valves at approximately 5 minutes into an accident situation. These valves, however, will have moved to their safety position at approximately 15 seconds into an accident situation and are not required to reposition subsequent to submergence. This time interval provides adequate margin to assure the completion of the required safety function. Additional information concerning these valves is found in

the McGuire FSAR, Section 15.4.1.3.

With specific regard to the TER item concerning failure modes associated with the submerged valves and the effects on other ecuipment and the operators, we are providing the following additional infomation:

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All motor operated valves located below the maximum LOCA water level are categorized as to their operation in relation to flooding. These three cate-gories are:

1. The valve is not required for post-LOCA operation of any of the safeguard systems. Therefore, operation subsequent to flooding is unnecessary. ,

2. The valve is normally in the post-LOCA position. Therefore, it is not required to reposition before or after flooding.

3. The valve receives a safety signal to close upon the occurrence of a LOCA and is not required to reposition subsequent to flooding.

Duke's response to the previous SER specifically addresses Category 3 above.

However, for all valves in the above categories there is no failure mechanism associated with submergence that could cause these valves to spuriously reposition or fail in a position other than the designated safety position.

Additionally there is no failure mechanism associated with submergence that can affect the performance of a safety function by another piece of safety-related equipment.

With regard to misleading information being supplied to the operator, we have determined that there is a potential for losing control room position indication for these submerged valves due to shorting in the valve limit switch compart-ment. Although these valves are in their safety position prior to submergence-and are not required to reposition following submergence, Duke has implemented an operator aid computer (OAC) application that will produce a valve position report whenever a high water level is detected in the containment sump. This OAC application is designed to report the position of these valves prior to submergence thereby providing the control room operators with an alternate method of verifying the position of these valves.

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ATTACHMENT 1 MCGUIRE NUCLEAR STATION - UNITS 1 AND 2 RESOLUTION OF NRC/FRC TECHNICAL EVALUATION REPORT ITEMS IDENTIFICATION OF TER ITEMS AND CORRESPONDING RESOLUTIONS

MLtdCument i Pag: 1 of 9 -

MCGUIRE NUCLEAR STATION - UNITS 1 AND 2 RESOLUTION OF NRC/FRC TECHNICAL EVALUATION REPORT ITEMS 4

TER TER ITEM COMPONENT MFGR MODEL CATEGORY RESOLUTION 1 Solenoid Valve Valcor V526 II.C; 4 2 Solenoid Valve Valcor V526 II.C 4 3 Solenoid Valve Valcor V70900213 II.A 5,JIO-4 Solenoid Valve Valcor V70900213/V70900211 II.A 5.JIO 5 Solenoid Valve Valcor V70900213 II.A 5,JIO 6 Solenoid Valve Valcor V526/V573 II.C ,4 7 Solenoid Valve Valcor V70900211/V70900213 II.A 5.JIO 8 Solenoid Valve Powers Regulator 2650002 1.B 7 9 Solenoid Valve ASCO NP8316E34E/NP8316E36E II.C 4 10 Solenoid Valve ASCO NP8316E34E II.C 4 11 Solenoid Valve ASCO NP8316E34E II.C 4 12 Solenoid Valve ASCO NP8316E34E/NP8316E36E II.C 4 13 Solenoid Valve Atwood-Morrill MSIV III.B 3 14 Solenoid Valve Target Rock 77CC II.C 4 15 Solenoid Valve Borg-Warner FWIV IV 7 16 Valve Motor Operator Rotork NAl/NA2 I.A 1 17 Damper Motor Operator Rotork llNAZ1 1.A 1 18 Valve Motor Operator Limitorque ,

SMB -

II.A 5

MCGUIRE NUCLEAR STATION - UNITS 1 AND 2 Paga 2 cf 9 .

RESOLUTION OF NRC/FRC TECHNICAL EVALUATION REPORT ITEMS ITEM COMPONENT MFGR MODEL CATEGORY RESOLUTION 19 Valve Motor Operator Rotork NAl I.A 1 20 Damper Motor Operator Rotork 7A/3MW II.C 4 21 Valve Motor Operator Limitorque SMB II.A 5 22 Valve Motor Operator Limitorque SMB II.A 5 23 Valve Motor Operator Rotork NA2 II.C 4 24 Valve Motor Operator Rotork NAl I.A 1 25 Valve Motor Operator Limitorque SMB II.A 5 26 Valve Motor Operator Limitorque SMB II.A 5 27 Valve Motor Operator Rotork NA2 II.B 6 28 Valve Motor Operator Rotork NAl I.A 1 29 Flow Transmitter Veritrak 59DP III.A 2 30 Cable Anaconda EP/HYPALON I.A 1 31 Level Switch Robertshaw SL402843 I.B 7,JIO 32 Level Transmitter Barton 386A II.A 5 -

33 Level Transmitter (Unit 1) Barton 764 (Lot 2) IV 7 34 Level Transmitter (Unit 1) Barton 764 (Lot 2) IV 7 35 Cable Anaconda EP/ilYPALON I.A 1 36 Cable Brand-Rex PVC IV 7 37 Cable Brand-Rex PVC IV 7 38 Pressure Transmitter (Unit 1) Barton 763 (Lot 2) IV 7 39 Pressure Transmitter Rosemount ll53GA9 II.B 6

MCGUIRE NUCLEAR STATION - UNITS 1 AND 2 Page 3 cf 9 TER RESOLUTION OF NRC/FRC TECHNICAL EVALUATION REPORT ITEMS TER ITEM COMPONENT MESR MODEL CATEGORY RESOLUTION 40 Cable Brand-Rex XLPE II.A 5 41 Pressure Transmitter (Unit 1) Barton 763 (Lot 2) IV 7 42 D/P Switch Solon 7PSIADW II.A 5 43 D/P Switch Solon 7PSIADW I.B 7 44 D/P Switch Solon 7PSIDW I.B 7 45 Signal Transmitter RIS 5C1302 IV 7 46 Acoustical Monitor TEC 1414 I.B 7 47 Level System Westinghouse RVLIS I.B 7,JIO 48 Radiation Monitor GA RD23 II.A 5 49 Cable Rockbestos RSS6104-1081 I.B 7 50 Limit Switch NAMC0 EA-180 II.C 4 51 Limit Switch NAMC0 EA-180 II.C 4 52 Limit Switch NAMC0 EA-180 II.C 4 53 Limit Switch NAMC0 EA-740 II.C 4 54 Limit Switch NAMC0 EA-740 II.C 4 55 Limit Switch NAMC0 EA-740 II.C 4 56 Limit Switch NAMC0 EA-740 II.C 4 57 Limit Switch Micro Switch LSM4N II.A 5 58 Limit Switch Micro Switch LSM4N II.A 5 59 Limit Switch NAMC0 EA170302 II.C 4 60 Limit Switch NAMC0 EA170302 II.A 5

MCGUIRE NUCLEAR STATION - UNITS 1 AND 2 Page 4 cf 9 RESOLUTION OF NRC/FRC TECHNICAL EVALUATION REPORT ITEMS TER TER ITEM COMPONENT MFGR MODEL CATEGORY RESOLUTION 61 Temperature Controller Love Controls 54 I.B 7 62 Temperature Controller Love Controls 834 I.B 7 63 Temperature Controller Love Controls 836 I.B 7 j 64 Temperature Controller Love Controls 8134 I.B 7 65 Temperature Controller Love Controls 8160 I.B 7 66 Temperature Controller Love Controls 8165 I.B 7 67 Temperature Controller Love Controls 8173 I.B 7 68 Temperature Controller Love Controls 8174 I.B 7 69 Thermostat United Electric 800G6CS I.B 7

, 70 RTD Weed 101AZNA3C621 I.B 7 71 RTD Rosemount 176KS I.B 7, 72 RTD Rosemount 176KF I.B 7, 73 Motor (NI Pmp) Westinghouse 73F69618 II.C 4 74 Motor (CCP) Westinghouse 72F44587 II.C 4 75 Motor (NS Pmp) Westinghouse 73F56019 II.C 4 76 Motor (RilRPmp) Westinghouse 71F13494 II.C 4 77 Motor (Smp Pmp) Allis-Chalmers 151335645023 II.A 5,JIO 78 Motor (Ann Vent Fan) Reliance 2YF273608 II.C 4 79 Motor (ABFXF) Reliance lYF882 I.A 1 80 Motor (DG Vent Fan) Reliance lVF272608 II.C 4 L

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MCGUIRE NUCLEAR STATION - UNITS 1 AND 2 TER RESOLUTION OF NRC/FRC TECHNICAL EVALUATION REPORT ITEMS TER ITEM COMP 0NENT MFGR MODEL CATEGORY RESOLUTION 81 Motor (FPCPAHU) Reliance 2YF882311/1YF882311 I.A 1 82 Motor (FPCP) Westinghouse 72F44649 II.C 4 83 Motor (FPCP AHU) Reliance 882311 II.A 5 84 Motor (GWSmpPmp) Reliance 2Y273734 IV 7 85 Motor (CCW Pmp) Westinghouse 72F44689 II.C 4 86 Motor (CC Pmp) Westinghouse 72F44587 II.C 4 87 Motor (NSW Pmp) Westinghouse 72F36530 II.C 4 88 Motor (H2 Skimmer Fan) Reliance lYF882315 II.A 5 89 Motor (Cont. Air Ret.) Reliance 2XF-330081 II.A 5 90 Terminal Block States ZWM IV 7 91 Terminal Block States ZWM II.A 5 92 Terminal Block Buchanan SS & TS II.C 4 93 Terminal Block Stanwick SLS I.A 1 94 Terminal Block Stanwick SLS II.C 4 95 Terminal Block Stanwick- DG II.C 4 Terminal Block I.B 96 Buchanan P0721 7 97 Terminal Block Buchanan 0721 I.B 7 98 Fuse Littel Fuse Normal & Slo Blo IV 7 99 Fuse Littel Fuse Slo Blo IV 7 100 Fuse Bussmann FNA IV 7

MCGUIRE NUCLEAR STATION - UNITS 1 AND'2 Paga 6 of 9 RESOLUTION OF NRC/FRC TECHNICAL EVALUATION REPORT ITEMS TER TER .

ITEM COMPONENT MFGR MODEL CATEGORY RESOLUTION 101 Fuse Bussmann FNA IV 7 102 Fuse Bussmann KTK IV 7 103 Indicating Light Cutler-liammer E29 II.A 5 104 Indicating Light Cutlet-llammer E30 II.A 5 105 Indicating Light Cutler-Hammer E30 IV 7 106 Indicating Light Cutler-Hammer E29 IV 7 107 Selector Switch Cutler-Hammer 10250T IV 7

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108 Electrical Switch Cutler-Ilammer 10250T II.A 7 109 Fuse Block Bussmann 4575 II.A 5 110 Fuse Block Bussmann 3792 II.A 5

, 111 Fuse Block Bussmann 3839 II.A 5 112 Fuse Block Bussmann 4439 II.A 5 113 Fuse Block Bussmann 3792 I.A 1 114 Fuse Block Bussmann 4575 I.A 1 115 Fuse Block Bussmann 2808 II.A 5 116 Fuse Block Bussmann 2807 II.A 5 117 Relay Cutler-Hammer D23 IV 7 118 Relay Cutler-Hammer D23 II.A 5 119 Relay Cutler-Ilammer D26 II.A 5

MCGUIRENUCLEARSTATiON-UNITS 1AND2 Pagm 7 of 9 RESOLUTION OF NRC/FRC TECHNICAL EVALUATION REPORT ITEMS TER TER ITEM COMP 0NENTS MFGR MODEL CATEGORY RESOLUTION -

120 Relay Struthers-Dunn 219 IV 7 121 Relay Agastat 7000 series IV 7 122 Surge Suppressor Gen. Semi'c' tor Transzorb IV 7 123 Surge Suppressor Gen. Semi'c' tor Transzorb IV 7 124 Panel (AVFU Cnt) Farr -

I.B 7 125 Transformer Westinghouse PRM75 I.A 1 126 MCC Gould ,KLi.ne I.A 1 127 MCC , ,,

Nelson Elect. C, lass 1035u II.A 5 128 Alarm RIS ET1215 III.B 3 129 Optical Isolator 175D127 175D127 III.B 3 130 Resistor Ohmite, Brown Devil IV 7 131 Resistor. Ohmite Dividohm III.B 3 132 Sealant 3M ,

Scotch Cast 9 I.A 1 133 Splice Material Raychem ,WCSFN II.C 4 134 H2 Recombiner }[Sturtevant A I.A 1 135 Elect. Penetration D. G. O'Brien Types A-H, J-M I.A 1 136 Cable BIW XLPE II.A 5 137 Cable Sany al Moore EP/Hyp II.A 5 138 Cable Samuel Moore EP/Hyp II.A 5 139 Cable Samuel Moore EP/Hyp II.A 5

MCGUIRE NUCLEAR STATION - UNITS 1 AND 2 Page 8 of 9 RESOLUTION OF NRC/FRC TECHNICAL EVALUATION REPORT ITEMS TER ITEM COMPONENTS MFGR MODEL CATEGORY RESOLUTION -

140 Cable Samuel Moore EP/Hyp II.A 5 141 Cable Samuel Moore PVC IV 7 142 Cable Samuel Moore PVC IV 7 143 Cable Okonite Tefzel 200 II.A 5 I 144 Cable Okonite Tefzel 280 II.A 5 2

145 Cable Okonite Tefzel 280 IIvA 5 i 146 Cable Okonite EP II.A 5 147 Cable Okonite.  ; EP -

II.A 5 148 Cable Okonite EP II.A. 5 149 Cabl e . ' . . . .. . n. Okonite EP II.A 5 150 Cable Okonite EP/Hyp - II.A 5 151 Cable Okonite Hypalon II.A 5 152 Cable Okonite Hypalon II.A 5 153 Cable ... .ai Brand-Rex XLPE' II.A 5 154 Cable Brand-Rexc . XLPE II.A 5 155 Cable -

Brand-Rex. XLPE II.A 5 156 Cable Anaconda EP/Hyp I.A 1 157 Cable Anaconda EP/Hyp I.A 1 158 Power Supply Lambda -

LCS i IV 7 l

159 Valve Motor Operator Rotork NA2 II.C 4 160 Reliance lYF882311 II.A 5 Motor (FPAHU)

MCGUIRE NUCLEAR STATION - UNITS 1 AND 2 Page 9 ef 9 ,'

RESOLUTION OF NRC/FRC TECHNICAL EVALUATION REPORT ITEMS TER ITEM COMPONENTS MFGR MODEL. CATEGORY RESOLUTION 161 Panel (ABFU Cnt) Allison -

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.MCGUIRE NUCLEAR STATION - UNITS 1 AND 2 RESOLUTION OF NRC/FRC TECHNICAL EVALUATION REPORT ITEMS

, RESOLUTION DISCUSSION i

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Attachment 2 Pagg 1 of 9 MCGUIRE NUCLEAR STATION - UNITS 1 AND 2 RESOLUTION OF NRC/FRC TECHNICAL EVALUATION REPORT ITEMS Resolution No. Resolution Discussion

1. This equipment is in TER Category I.A, Equipment Qualified. No resolution is required for this equipment.

2. This equipment is in TER Category III.A, Equipment Exempt from Qualification. No resolution is required for this equipment.

3. This equipment is in TER Category III.B Equipment Not in the Scope of the Review. No resolution is required for this equipment. It should be noted that TER Item 13 (solenoid valve supplied by Atwood-Morrill as a part of the main steam isolation valves) was incorrectly identified as a TER Category III.B item. The environmental quali-fication of these solenoid valves is documented in Atwood-Morrill Report 201-39500 dated May 1, 1979.

4. This equipment is in TER Category II.C, Equipment Satisfies All Requirements Except Qualified Life or Replacement Schedule Justified.

Duke Power Company has reviewed the items in this category and determined that the TER concerns can be satisfactorily resolved for McGuire. Documentation of the specific resolutions for each TER Item is currently in progress. As discussed with the NRC Staff on March 29,1983, the methods for resolving these concerns are consistent with the NUREG 0588 Category II requirements and NRC Generic Letter 82-09 and include one or more of the following:

0 Aging simulations were included in the test program for the equip-ment. A qualified life based on McGuire conditions has been determined with appropriate equipment / component replacement schedules established.

8 Surveillance and maintenance activities established to review equip-l ment for significant aging degradation.

0 Equipment has been determined to have no significaat aging mechanisms based on material evaluation or Duke experience. In all cases where radiation is an environmental parameter, the equipment has been shown to be qualified for the 40 year normal dose plus the appropriate accident dose (typically 1 year).

With specific regard to TER Items 55 and 56 (EA-740 limit switches furnished by NAMCO), it should be noted that these two items are not used in safety-related applications outside containment and there-fore do not require environmental qualification.

5. This equipment is in TER Category II.A, Equipment Qualification Not Established. Duke Power Company has reviewed the items in this category. Technical resolutions have been determined and documen-tation of the specific resolutions for each TER Item is currently in progress. Additionally, key resolutions discussed with the NRC Staff on March 29, 1983 are as follows:

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Page 2 of 9 Resolution No. Resolution Discussion 4 Traceability of installed equipment to the qualification documentation was a principle concern for cables (TER Items 40, 136-140, and 143-155), Limitorque valve motors (TER Items 18, 21, 22, 25, and 26),

hydrogen skimer fan motors (TER Item 89). For these items, Duke Power Company has identified the auditable link between the installed equipment and the qualification documentation and is updating the qualification files with this information.

This effort will be based on manufacturer's certifications that are traceable through specifications, purchase orders, or other pertinent documents.

9 Valcor solenoid valves models V70900211 and V70900213 (TER Items 3, 4, 5, and 7) were originally qualified by similarity to another Valcor solenoid valve. However, the specific models identified above are presently endergoing qualific~ation testing that is scheduled for completion in September 1983. Duke Power Company intends to use the qualification test results from this new test program as the basis of qualification for these Valcor solenoid valves.

Refer to the attached JIO for this equipment.

8 Solon differential pressure switches model 7PSlADW (TER Item 42),

located in the upper containment are qualified for less than one hour. These switches detect high differential pressure between the upper and lower containment associated with large breaks and actuate to provide an open permissive to dampers located between the upper and lower containment. This high differential pressure in containment will occur and equalize less than one minute into the

, event. Once the switches have provided the permissive signal, they are electrically isolated from the circuit and perform no further safety function. Based on the design described above, the location of the switches (upper containment), and the need for their function only for a large break event, qualification for less than one hour is justified. Additionally, margin is provided between the required time (1 minute) and the qualified time (5 minutes).

'O Micro Switch limit switches model LSM4N (TER Items 57 and 58) provide damper position indication only and are used to observe damper position during testing of the associated ventilation system.

These switches perform no safety function, are not used by the operators as a basis for a required action and their failure cannot prevent satisfactory accomplishment of any required safety function.

Additionally, these switches will be removed from safety power orior to startup following the first refueling outage of the respective McGuire units.

O Allis Chalmers sump pump motors model 151335645023 (TER Item 77) located outside the containment are exposed to only a post-LOCA radiation environment. Duke Power Company has pursued the radiation qualification of these motors with the manufacturer and obtained a manufacturer's statement that the motor is qualified. However, Duke Power Company will replace these motors with qualified motors having complete qualication documentation.

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Pag 2 3 of 9 l Resolution No. Resolution Discussion I

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Refer to attached JIO for this equipment.

I 6. This equipment is in TER Category II.B. Equipment Not Qualified.

. Duke Power Company has reviewed the two items in this category.

1 Based on our review we have determined that the following additional

, information addresses the TER concerns and in conjunction with the j qualification documentation referenced in the McGuire NUREG 0588

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submittal demonstrates qualification of the two equipment items.

I G TER Item 27 - Rotork Model NA-2 Valve Actuators Located Outside Containment Statement of Problem: Following exposure to 212*F steam environment 3

for 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br />, the torque switch mechanism in the Rotork NA-2 style j actuator failed resulting in the motor running to stall and burning up following the actuation of a valve in the close direction. This '

situation is described in Rotork Test Report TR-3025.

i Background Information: The torque switch mechanism of the NA-2 actuator was the component which failed during qualification testing as reported in TR-3025. The NA-2 torque switch mechar. ism (helix)is

, made of a thermoplastic material, nilotron, which at approximately 180*F becomes pliable resulting in failure to actuate the torque switch at the end of valve stroke. As noted in our response to the

McGuire Unit 1 equipment qualification SER, TR-3025 demonstrates that at least one valve operation is available after a torque switch mechanism failure; therefore, the valves are capable of moving to their safety position. It should be emphasized that the torque switch failure could occur only after the valve has reached its j safety position and would not affect the valves' ability to remain in its safety position, would not affect other safety-related equipment, and would not mislead the operator.

4 Duke has analyzed all NA-2 actuator applications at McGuire and has determined that once the actuator has reached its safety position, no additional safety operation is required.

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Conclusion:

Based on the Rotork NA-2 test report TR-3025 and the above discussion, Duke has determined that these actuators are capable of performing their safety function and that continued use of the NA-2 actuator in its current applications is acceptable.

' 4 TER Item 39 - Rosemount Transmitters Model ll536A9 (RCS Wide Range ,

f Pressure Transmitter) Located in the Annulus.

Statement of Problem: Based on the FRC review, the Rosemount ll53GA9 transmitter is identified as not qualified for accident conditions. This conclusion was reached based on the Rosemount qualification report submitted as part of the H. B. Robinson facility SER response. This H. B. Robinson report identifies a failure of some components in the 1153 Series A transmitters due to environmental testing in accordance with IEEE 323-1974 which significantly exceeds I the McGuire requirements.

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Page 4 of 9 Resolution No. Resolution Discussion Background Information: The applicable qualification document for the McGuire 1153GA9 transmitter, as referenced in Duke's NUREG 0588 submittal, is Rosemount Report No. 3788, Revision A. This report documents results of type testing which qualifies the Model 1153 Series A transmitter for Class lE service in Nuclear Power Generating Stations in accordance with IEEE 323-1971. Specifically, Rosemount Report No. 3788, Revision A documents that the Rosemount Model 1153 Series A transmitter successfully completed testing with no signifi-cant anomaliespsig; Pressure-120 under the following relative conditions:

humidity-100".; and Temperature-350*F;7 radiation dose-4X10 R; and chemical spray. The accident environment for the McGuire Unit 1 and 2 RCS wide range pressure transmitters, located in the annulus, is 142*F, relative humidity 100% and radiation dose 1.2X10 7R.

Pressure, steam, and chemical spray environments are not applicable environmental parameters in the annulus. With regard to transmitters 0-ring seal integrity, station procedures will require 0-ring seal replacement consistent with transmitters calibration intervals.

Replacement intervals for the entire transmitter or the circuit board is being reviewed and will be addressed and included in our qualifi-cation files.

Conclusion:

The Rosemount report referenced in the H. B. Robinson SER response does not apply to the Duke transmitters since the report addresses a qualification program which significantly exceeds the McGuire requirements. Therefore, based on Rosemount's Report l No. 3788, Revision A and the above discussion, Duke has determined that the subject transmitters are qualified to perform their safety function in the annulus accident environment as identified in the McGuire NUREG 0588 response.

7. This equipment is in either TER Category I.B. Equipment Qualifica-tion Pending Modification or TER Category IV, Documentation Not Made Available. Duke Power Company has reviewed the items in these two categories and determined that the major deficiency noted in each category is documentation not available for review (Note:

circumstances related to documentation not available for review included qualification testing not complete at the time of our submittal, proprietary nature of certain qualification documentation, and certain documents not requested by NRC/FRC). We have further l

determined that qualification documentation is now available in l

Duke files for the equipment items noted in the following table.

l For the remaining equipment items in these two categories, the l following information is provided:

0 TER Item 31; Robertshaw Level Switches - Model SL402843 These level switches are installed outside contair ant in the dog-house and function to terminate main feedwater fic. in the event of a main feedwater line break in the doghouse. Main feedwater termin-ation is required in order to prevent the flooding of safety-related equipment in the doghouse.

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Page 5 of 9 Resolution No. Resolution Discussion As stated in the Duke NUREG 0588 submittal for McGuire, these switches were in a qualification program that was scheduled for completion in 1982. Following evaluation of the results of the thermal aging portion of this qualification program, Duke has decided to replace the Robertshaw level switch with a Magnetrol level switch which is presently undergoing qualification testing.

The testing is scheduled for completion by April 1983. The results of the Magnetrol level switch testing will be provided in the McGuire NUREG 0588 submittal.

Refer to the attached JIO for the Magnetrol level switches.

6 TER Item 47 - Reactor Vessel Level Instrument System (RVLIS)

The RVLIS is a TMI/NUREG 0737 item (II.F.2). The environmental qualification documentation for the equipment in this system subject to harsh environment is scheduled to be available by May 31, 1983.

Refer to the attached JIO for the RVLIS.

9 TER Item 71; Rosemount RTD's - Model 176KS These RTD's are provided to monitor reactor coolant system wide range temperature and are used for post-accident monitoring indication. As stated in the McGuire NUREG 0588 submittal, these RTD's will be replaced at each refueling outage of the respective McGuire units.

This replacement commitment for Rosemount 176KS RTD's is based on the qualified (test) radiation dose of 1X108 rads and the NRC require-ment to address source terms associated with the contained accident scenario.

The materials used in this model RTD have been reviewed for thermal aging effects. The results show that no significant thermal de-gradation will occur during one refueling interval. Based on the thermal aging review and the qualified radiation dose of IX108 rads, the proposed replacement schedule is justified.

9 TER Item 72; Rosemount RTD's - Model 176KF These RTD's are provided to monitor reactor coolant system narrow-range temperature and have a short term reactor trip input function.

As stated in the McGuire NUREG 0588 submittal, these RTD's would be replaced on a 10 year cycle unless it could be shown that EPR is a non-critical material of the RTD. Based on our review of the materials used in the RTD, we have found that EPR which was initially thought to be a material in these RTD's is in fact not an RTD material. Therefore, based on the qualification report for these RTD's, a review of the materials of these RTD's (including thermal and radiation aging), and the application of these RTD's, these RTD's are qualified for 40 years of normal operation plus their short-term trip function, l

Page 6 of 9 Resolution No. Resolution Discussion 0 TER Item 84; Reliance Motor - Model 2Y273734 This motor is installed outside containment and serves as the motor drive for the groundwater drainage sump pump. Although this motor is exposed to a pipe break environment, it is not required to function for any pipe break event. Further, failure of this motor following exposure to the postulated harsh environment will not prevent the satisfactory accomplishment of any required safety function by other safety-related equipment.

9 TER Item 124 - Annulus Ventilation Filter Unit Control Panels These panels have been relocated to a mild environment on both McGuire units.

9 TER Item 161 - Auxiliary Building Filter Unit Control Panel These panels have been modified and reclassified is non-safety-related on both McGuire units; therefore, environmental qualification is not required.

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Attachment 2 Pagm 7 cf 9 MCGUIRE NUCLEAR STATION - UNITS 1 AND 2 RESOLUTION OF NRC/FRC TECHNICAL EVALUATION REPORT ITEM QUALIFICATION DOCUMENTATION REFERENCES FOR CATEGORY I.B AND IV ITEMS I FRC ITEM NO. COMPONENT MFGR MODEL # 00ALIFICATION DOCUMENTATION 8 Solenoid Valve Powers Regulator 2650002 CCL Test Report A-490-82 15 Solenoid Valve Borg-Warner FWIV Borg Warner Test Reports 1785 and 1779, dated 11/12/79 33 Level Transmitter (Unit 1) Barton 764 (Lot 2) WCAP-9885 34 Level Transmitter (Unit 1) Barton 764 (Lot 2) WCAP-9885 36 Cable Brand-Rex PVC Duke Report QTF TR-032 (Supersedes TR-017) 37 Cable Brand-Rex PVC Duke Report QTF TR-032 (Supersedes TR-017) 38 Pressure Transmitter (Unit 1) Barton 763 (Lot 2) WCAP-9885 41 Pressure Transmitter (Unit 1) Barton 763 (Lot 2) WCAP-9885 43 D/P Switch Solon 7PSIADW CCL Report A-490-82 44 D/P Switch Solon 7PSIDW CCL Report A-490-82 45 Signal Transmitter RIS SC1302 RIS Manual SC-1302 (MCM-1346.00-0010) 46 Acoustical TEC 1414 TEC Test Report 517-TR-03, Rev. 3 49 Cable Rockbestos RSS6104-1081 Rockbestos Test Report 2806

Attachment 2 Page 8 cf 9 MCGUIRE NUCLEAR STATION FRC ITEM NO. COMPONENT MFGR MODEL # QUALIFICATION DOCUMENTATION 61 Temperature Controller Love Controls 54 CLL Test Report A-490-82 62 Temperature Controller Love Controls 834 CCL Test Report A-490-82 63 Temperature Controller Love Controls 836 CCL Test Report A-490-82 64 Temperature Controller Love Controls 8134 CCL Test Report A-490-82 65 Temperature Controller Love Controls 8160 CCL Test Report A-490-82 66 Temperature Controller Love Controls 8187 CCL Test Report A-490-82 67 Temperature Controller Love Controls 8173 CCL Test Report A-490-82 68 Temperature Controller Love Controls 8174 CCL Test Report A-490-82 69 Thermostat United Electric 800G6CS CCL Test Report A-490-82 70 RTO Weed 101AZNA3C621 CCL Test Report A-490-82 90 Terminal Block States ZWM ESSEM IV-B-4 & IV-B-5/ Duke Analysis 96 Terminal Block Buchanan P0721 CCL Test Report A-490-82 97 Terminal Block Buchanan 0721 CCL Test Report A-490-82 98 Fuse Littel Fuse Normal & Slo Blo ESSEM III-A-7/Derating Curve 99 Fuse Littel Fuse Slo Blo ESSEM III-A-7/')TF TR-047 100 Fuse Bussmann FNA ESSEM III-A-4/QTF TR-040 101 Fuse Bussmann FNA ESSEM III-A-4/Derating Curve 102 Fuse Bussmann KTK ESSEM III-A-1/Derating Curve 105 Indicating Light Cutler-Hammer E30 ESSEM VI-C-1/QTF TR-040

Attachment 2 '.

'Page 9 ef 9 MCGUIRE NUCLEAR STATION .

FRC ITEM NO. COMPONENT MFGR MODEL # QUALIFICATION DOCUMENTATION 106 Indicating Light Cutler-Hammer E29 ESSEM III-B-1/QTF T -040 107 Selector Switch Cutler-Hammer 10250T ESSEM VI-A-1/QTF TR-040 117 Relay Cutler-Hammer D23 ESSEM VII-A-2.1/QTF TR-040 120 Relay Struthers-Dunn 219 ESSEM VII-A-3/ Duke Test Report 121 Relay Agastat 7000 series ESSEM VII-C-5/Agastat Spec.

122 Surge Suppressor Gen. Semi'c' tor Transzorb ESSEM III-C-1/G.S. Spec.

123 Surge Suppressor '

Gen. Semi'c' tor Transzorb ESSEM III-C-1/G.S. Spec.

130 Resistor ' ' -

'Ohmite Brown Devil ESSEM IX-B-2/Derating Curve 141 Cable Samuel Moore - PVC Duke Report QTF TR-032 (Supersedes TR-017) 142 Cable Samuel Moore PVC Duke Report QTF TR-032

• ' (Supersedes TR-017) 158 Power Supply Lambda LCS ESSEM VIII-G-1/ Lambda Spec.

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• ATTACHMENT 3 MCGUIRE NUCLEAR STATION - UNITS 1 AND 2 RESOLUTION OF NRC/FRC TECHNICAL EVALUATION REPORT ITEMS JUSTIFICATIONS FOR INTERIM OPERATION

Attachment 3 i

j. MCGUIRE NUCLEAR STATION - UNITS 1 AND 2 JUSTIFICATION FOR INTERIM OPERATION i

i TER Items 3, 4, 5, & 7 - Valcor Solenoid Valves (Models V70900-21-1, - 3)

Valcor solenoid valves (Models V70900-21-1 and V70900-21-3) are used in i various safety-related applications both inside and outside containment. In i all safety-related applications, these valves are normally energized. Ad-ditionally, in all safety-related applications the safety function of the solenoid is, by design, to de-energize. Following the performance of the safety function (i.e.,de-energizing), these solenoids are not required to re-energize.

These Valcor solenoid valves were the subject of IE Bulletin 80-23. This bulletin identified a problem with the solenoid coils in terms of not being

, designed for continuously energized applications. In response to this sit-uation Duke Power Company has replaced the coils on the McGuire Unit 1 and Unit 2 Valcor solenoids with coils of an improved potted construction.

Valcor solenoid valves with these new coils are presently in a qualification test program. All initial baseline testing and thermal and cyclic aging is i complete. The entire test program is scheduled for completion in July,1983 i with the qualification report scheduled to be available in September,1983 However, these solenoid valves are considered to be acceptable for use at McGuire pending completion of the qualification program based on the following l

l 1. The use of these valves in applications where the safety function is to de-energize.

I 2. The problems experienced with normally energized operation were a result i of a problem with the old coil design only.

3. The coil has been redesigned for normally energized operation by (.1) a change in materials of construction and (2) the addition of a potting compound between the solenoid coil and the shell enclosure.

(a) Materials of Construction - All materials utilized in the construc-tion of the new coils and U.L. rated for continuous operation at 220*C (428 F) with the exception of a tape used to cover both the solder joints and the complete coil wincing. The tape is classified as a 180*C (356*F) tape and is a U. L. recognized component.

(.b) Potting Compound - The potting material used is rated oy Emerson -

and Cuming at 350*F.

4. The significance of the above design improvements is as follows:

(a) The utilization of the higher temperature rated materials means that the new coils will be suitable for normally energized oper-ation at normal and accident temperatures. The addition of.the potting material allows the coil to dissipate more heat, and in normal operation, the coils will operate at a reduced temperature which extends the operating life. This has been proven by the additional testing described in interim test report MR70905-21-3-1.

. Attachment 3 l 1

(b) Valcor has subjected six (6) prototype potted solenoid coils to thermal aging tests. The coils were energized such that the coil wire is at its rated material temperature of 220*C (428'F).

No failures were experienced in this testing.

(c) Based on .ast data obtained from valves at an equillibrium ambient temperature of 140*F, the coil temperature rose 91*F over ambient after 15 minutes of energization. Using 91*F as the coil temper-ature rise during a LOCA, the coil temperature would be 433 F. This is based on a constant ambient of 327'F plus the 15'F margin re-comended by IEEE-323 (1974). The 433 F coil temperature figure is conservative for the following reasons. First, the coils will be energized before and during a LOCA. Therefore, the only mechanism affecting the coil temperature rise will be the increase in the ambient temperature and not the change in state (energization) of the coil. The increase in the ambient temperature will not have as great an effect on the coil temperature rise as the change in state of the coil, because the coil saturation temperature before the onset of a LOCA averages 337 F. Second, as the coil temper-ature begins to rise, the resistance of the coil wire increases, thereby reducing the power required by the solenoid, resulting in a reduction in the amount of heat to be dissipated by the valve.

Third, the fifteen minute specified energization of the coil after the onset of the LOCA exceeds McGuire requirements by a factor of three, rather than the 10% margin recommended by IEEE-323 (1974).

5. The previous radiation and seismic qualification of the solenoid valve with the new coil is unaffected by the replacement of the coil and the addi-tion of the potting compound for the following reasons:

(a) All materials utilized in the new coil as well as the potting material are rated acceptable in a radiation environment at least 2X108 rads, which exceeds the McGuire requirements by a factor of two (2).

(b) The addition of the potting compound and the changes in the coil design increase the weight of the solenoid valve by less than 10%,

and does not affect the response of the moving parts of the solenoid valve. The addition of the patting compound increased the rigidity of the solenoid coil, a seismic improvement over the original updated design.

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Attachment 3 MCGUIRE NUCLEAR STATION UNITS 1 AND 2 JUSTIFICATION FOR INTERIM OPERATION TER Item 31 - Robertshaw Level Switch (Model SL402843)

As stated in the McGuire NUREG 0588 submittal, the Robertshaw level switches were in a qualification program that was scheduled for completion in 1982.

Following evaluation of the results of the thermal aging portion of this qualifi-cation program, Duke decided to replace the Robertshaw level switch with a Magnetrol level switch which is presently undergoing qualification testing.

The baseline functional tests, thermal and cyclic aging, and seismic portions of the Magnetrol test program are complete with only the HELB simulation remaining to be completed. The HELB test is scheduled for completion by the end of April, 1983. l Based on our decision to replace the Robertshaw level switches with Magnetrol level switches (Model A103F-3X-Y-MPG-TDM-SlMD4DC-S1MD4DC-S1MD40C) and since the Magnetrol switches have not yet completed qualification testing, the following justification for interim operation is provided for the Magnetrol switches pending completion of qualification testing.  ;

Magnetrol level switches are now installed on both McGuire units. These switches are located outside contianment in the doghouse and function to terminate main feedwater flow in the event of a main feedwater line break in the doghouse. Main feedwater termination is required in order to prevent the flooding of safety-related equipment in the doghouse. The feedwater line break environment in the l doghouse results in a temperature of 240 F and a very brief pressure transient to 9 psig.

It is our engineering judgement that the Magnetrol level switches will not only successfully pass the HELB portion of the qualification program but are also acceptable for interim operation based on testing. Magnetrol has performed dry heat tests on the identical switch mechanisms utilized in the McGuire level switches at 300 F for up to 1954 hours0.0226 days <br />0.543 hours <br />0.00323 weeks <br />7.43497e-4 months <br /> with no failures. In addition, elevated temperature and humidity aging tests were performed on a Magnetrol model no.

A153F-Y-MPG-TDM-SlMD4DC-SlMD4DC-SlMD4DC level switch, which is similar to the McGuire switches for a total of 160 hours0.00185 days <br />0.0444 hours <br />2.645503e-4 weeks <br />6.088e-5 months <br /> at 300 F and 480 hours0.00556 days <br />0.133 hours <br />7.936508e-4 weeks <br />1.8264e-4 months <br /> at 95-100%

relative humidity. The only problems encountered were 1) a broken housing cover gasket after 110 hours0.00127 days <br />0.0306 hours <br />1.818783e-4 weeks <br />4.1855e-5 months <br /> at 300 F, 239 hours0.00277 days <br />0.0664 hours <br />3.95172e-4 weeks <br />9.09395e-5 months <br /> at 95-100% relative humidity and 30 to 40 cover installations and 2) micro switch mounting screws were becoming loose during the test. These are not a concern for the McGuire evaluation because

1) the problem with the housing gasket occurred at 110 hours0.00127 days <br />0.0306 hours <br />1.818783e-4 weeks <br />4.1855e-5 months <br />, which greatly exceeds the duration of the postulated McGuire doghouse environment and occurred after at least 30 cover installations. Duke maintenance procedures requires an inspection of the housing gasket each time the cover is removed and 2) Magnetrol now utilizes lock-tite on the micro switch mounting screws to prevent loosening of the screws. -

Attachment 3 MCGUIRE NUCLEAR STATION - UNITS 1 AND 2 JUSTIFICATION FOR INTERIM OPERATION

.TER Item 47 - Reactor Vessel Level Instrument System (RVLIS)

The RVLIS is a TMI/NUREG 0737 item (II.F.2) which is being furnished for McGuire by Westinghouse. This system is installed on Unit 1 and is required by license condition to be installed on Unit 2 prior to startup following the first Unit 2 refueling outage. It should be noted that even though this system is installed on Unit 1, it will not be declared operable until upgraded emergency operating procedures are approved and implemented (late 1983).

The environmental qualification of the equipment in this system subject to a harsh environment is complete and addressed in the McGuire NUREG 0588 submittal with the exception of the Minco strap-on RTD's. Westinghouse has recently successfully completed the qualification of these RTD's which will be documented in WCAP 8687, Supplement 1. E42A in late May,1983. However, because Duke Power Company has not reviewed the qualification data and since the Unit 1 RVLIS system will be energized for test purposes prior to being declared operable, we have reviewed the impact of failure of the Minco strap-on RTD's on other safety-related equi pment. Our review indicates that failure of the Minco RTD's would not prevent the satisfactory accomplishment of any required safety function by other safety-related equipment.

Attachment 3 MCGUIRE NUCLEAR STATION - UNITS 1 AND 2 JUSTIFICATION FOR INTERIM OPERATION TER Item 77 - Allis Chalmers Pump Motor (Model 151335645023)

These motors are located outsidg the containt ent and subject only to post-LOCA recirculation radiation (9.1X10* Rads TID 40 years plus 1 year post-accident).

These motors are provided to drive sump pumps associated with RHR and contain-ment spray pump leakage collection.

Duke Power Company has obtained a letter from the manufacturer stating that these motors are qualified for the postulated radiation environment. However, we have been unable to obtain copies of test / analysis data to support the manufacturer's statement. As a result of the lack of confirmatory documentation, these motors are being replaced with Reliance Electric motors having complete qualification documentation for the postulated radiation environment. These motors are scheduled for replacement on both McGuire units by May 16,1983.

Interim operation until the changeout is complete is acceptable based on the extremely low normal radiation dose that would be experienced by these motors prior to their changeout (by May 16,1983), accessibility of these motors for maintenance / repair, and the manufacturer's certification of radiation qualifica-tion at IX105 Rads. ,

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