ML060950250
Text
XI.E3 Inaccessible Medium-Voltage Cables Not Subject To 10 CFR 50.49 EQ Requirements 1
AUDIT WORKSHEET GALL REPORT AMP PLANT: ______________________________
LRA AMP: __________________________
REVIEWER: ______________________
GALL AMP: XI.E3, Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements DATE: __________________________
Program Element Auditable GALL Criteria Documentation of Audit Finding Program Description A. Most electrical cables in nuclear power plants are located in dry environments. However, some cables may be exposed to condensation and wetting in inaccessible locations, such as conduits, cable trenches, cable troughs, duct banks, underground vaults or direct buried installations. When an energized medium-voltage cable (2KV to 35 KV) is exposed to wet conditions for which it is not designed, water treeing or a decrease in the dielectric strength of the conductor insulation can occur. This can potentially lead to electrical failure.
Consistent with GALL AMP:
Yes No Document(s) used to confirm Criteria:
Comment:
B. The purpose of the aging management program described herein is to provide reasonable assurance that the intended functions of inaccessible medium-voltage cables that are not subject to the environmental qualification requirements of 10 CFR 50.49 and are exposed to adverse localized environments caused by moisture while energized will be maintained consistent with the current licensing basis through the period of extended operation. An adverse localized environment is a condition in a limited plant area that is significantly more severe than the specified service environment for the cable. An adverse variation in environment is significant if it could appreciably increase the rate of aging of a component or have an immediate adverse effect on operability. This program considers the technical information and guidance provided in Consistent with GALL AMP:
Yes No Document(s) used to confirm Criteria:
Comment:
XI.E3 Inaccessible Medium-Voltage Cables Not Subject To 10 CFR 50.49 EQ Requirements 2
Program Element Auditable GALL Criteria Documentation of Audit Finding NUREG/CR-5643, IEEE Std. P1205, SAND96-0344, and EPRI TR-109619.
C. In this aging management program periodic actions are taken to prevent cables from being exposed to significant moisture, such as inspecting for water collection in cable manholes, and draining water, as needed. The above actions are not sufficient to assure that water is not trapped elsewhere in the raceways.
For example, if duct bank conduit has low points in the routing, there could be potential for long-term submergence at these low points. In addition, concrete raceways may crack due to soil settling over a long period of time and manhole covers may not be watertight. Additionally, in certain areas, the water table is high in seasonal cycles and therefore, the raceways may get refilled soon after purging. Furthermore, potential uncertainties exist with water trees even when duct banks are sloped with the intention to minimize water accumulation. Experience has shown that insulation degradation may occur if the cables are exposed to 100 percent relative humidity. The above periodic actions are necessary to minimize the potential for insulation degradation. In addition to above periodic actions, in-scope, medium-voltage cables exposed to significant moisture and significant voltage are tested to provide an indication of the condition of the conductor insulation. The specific type of test performed will be determined prior to the initial test, and is to be a proven test for detecting deterioration of the insulation system due to wetting, such as power factor, partial discharge, or polarization index, as described in EPRI TR-103834-P1-2, or other testing that is state-of-the-art at the time the test is performed.
Consistent with GALL AMP:
Yes No Document(s) used to confirm Criteria:
Comment:
D. As stated in NUREG/CR-5643, "The major concern with cables is the performance of aged cable when it is exposed to accident conditions." The statement of considerations for the final license renewal rule (60 Fed. Reg. 22477) states, "The major concern is that failures of deteriorated cable systems Consistent with GALL AMP:
Yes No Document(s) used to confirm Criteria:
XI.E3 Inaccessible Medium-Voltage Cables Not Subject To 10 CFR 50.49 EQ Requirements 3
Program Element Auditable GALL Criteria Documentation of Audit Finding (cables, connections, and penetrations) might be induced during accident conditions." Since they are not subject to the environmental qualification requirements of 10 CFR 50.49, the electrical cables covered by this aging management program are either not exposed to harsh accident conditions or are not required to remain functional during or following an accident to which they are exposed.
Comment:
- 1. Scope of Program A. This program applies to inaccessible (e.g., in conduit or direct buried) medium-voltage cables within the scope of license renewal that are exposed to significant moisture simultaneously with significant voltage. Significant moisture is defined as periodic exposures to moisture that last more than a few days (e.g., cable in standing water). Periodic exposures to moisture that last less than a few days (i.e., normal rain and drain) are not significant. Significant voltage exposure is defined as being subjected to system voltage for more than twenty-five percent of the time. The moisture and voltage exposures described as significant in these definitions, which are based on operating experience and engineering judgment, are not significant for medium-voltage cables that are designed for these conditions (e.g., continuous wetting and continuous energization is not significant for submarine cables).
Consistent with GALL AMP:
Yes No Document(s) used to confirm Criteria:
Comment
- 2. Preventive Actions A. Periodic actions are taken to prevent cables from being exposed to significant moisture, such as inspecting for water collection in cable manholes, and draining water, as needed.
Consistent with GALL AMP:
Yes No Document(s) used to confirm Criteria:
Comment:
- 3. Parameters Monitored/
Inspected A. In-scope, medium-voltage cables exposed to significant moisture and significant voltage are tested to provide an indication of the condition of the conductor insulation. The specific type of test performed will be determined prior to the initial test, and is to be a proven test for detecting deterioration of the insulation system due to wetting, such as power factor, Consistent with GALL AMP:
Yes No Document(s) used to confirm Criteria:
Comment:
XI.E3 Inaccessible Medium-Voltage Cables Not Subject To 10 CFR 50.49 EQ Requirements 4
Program Element Auditable GALL Criteria Documentation of Audit Finding partial discharge, or polarization index, as described in EPRI TR-103834-P1-2, or other testing that is state-of-the-art at the time the test is performed.
- 4. Detection of Aging Effects A. Medium-voltage cables exposed to significant moisture and significant voltage that are within the scope of this program are tested at least once every 10 years. This is an adequate period to preclude failures of the conductor insulation since experience has shown that aging degradation is a slow process. A 10 year testing interval will provide two data points during a 20-year period, which can be used to characterize the degradation rate.
The first tests for license renewal are to be completed before the period of extended operation.
Consistent with GALL AMP:
Yes No Document(s) used to confirm Criteria:
Comment:
B. The inspection for water collection should be performed based on actual plant experience with water accumulation in the manhole. However, the inspection frequency should be at least once every two years. The first inspection for license renewal is to be completed before the period of extended operation.
Consistent with GALL AMP:
Yes No Document(s) used to confirm Criteria:
Comment:
- 5. Monitoring and Trending A. Trending actions are not included as part of this program because the ability to trend results is dependent on the specific type of method chosen. However, results that are trendable provide additional information on the rate of degradation.
Consistent with GALL AMP:
Yes No Document(s) used to confirm Criteria:
Comment:
XI.E3 Inaccessible Medium-Voltage Cables Not Subject To 10 CFR 50.49 EQ Requirements 5
Program Element Auditable GALL Criteria Documentation of Audit Finding
- 6.
Acceptance Criteria A. The acceptance criteria for each test is defined by the specific type of test performed and the specific cable tested.
Consistent with GALL AMP:
Yes No Document(s) used to confirm Criteria:
Comment:
- 7. Corrective Actions A. An engineering evaluation is performed when the test acceptance criteria are not met in order to ensure that the intended functions of the electrical cables can be maintained consistent with the current licensing basis. Such an evaluation is to consider the significance of the test results, the operability of the component, the reportability of the event, the extent of the concern, the potential root causes for not meeting the test acceptance criteria, the corrective actions required, and the likelihood of recurrence. When an unacceptable condition or situation is identified, a determination is made as to whether the same condition or situation is applicable to other inaccessible, in-scope, medium-voltage cables. As discussed in the appendix to this report, the staff finds the requirements of 10 CFR Part 50, Appendix B, acceptable to address the corrective actions.
Consistent with GALL AMP:
Yes No Document(s) used to confirm Criteria:
Comment:
- 8.
Confirmation Process A. As discussed in the appendix to this report, the staff finds the requirements of 10 CFR Part 50, Appendix B, acceptable to address the confirmation process.
Consistent with GALL AMP:
Yes No Document(s) used to confirm Criteria:
Comment:
- 9.
Administrative Controls A. As discussed in the appendix to this report, the staff finds the requirements of 10 CFR Part 50, Appendix B, acceptable to address the administrative controls.
Consistent with GALL AMP:
Yes No Document(s) used to confirm Criteria:
Comment:
- 10. Operating A. Operating experience has shown that cross linked Consistent with GALL AMP:
Yes No
XI.E3 Inaccessible Medium-Voltage Cables Not Subject To 10 CFR 50.49 EQ Requirements 6
Program Element Auditable GALL Criteria Documentation of Audit Finding Experience polyethylene (XLPE) or high molecular weight polyethylene (HMWPE) insulation materials are most susceptible to water tree formation. The formation and growth of water trees varies directly with operating voltage. Water treeing is much less prevalent in 4kV cables than those operated at 13 or 33kV. Also, minimizing exposure to moisture minimizes the potential for the development of water treeing. As additional operating experience is obtained, lessons learned can be used to adjust the program, as needed.
Document(s) used to confirm Criteria:
Comment:
XI.E3 Inaccessible Medium-Voltage Cables Not Subject To 10 CFR 50.49 EQ Requirements 7
EXCEPTIONS Item Number Program Elements LRA Exception Description Basis for Accepting Exception Documents Reviewed (Identifier, Para.# and/or Page #)
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ENHANCEMENTS Item Number Program Elements LRA Enhancement Description Basis for Accepting Enhancement Documents Reviewed (Identifier, Para.# and/or Page #)
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DOCUMENT REVIEWED DURING AUDIT Document Number Identifier (number)
Title Revision and/or Date
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