ML093430328

Forwards Response to NRC 800919 Order for Mod of License Re Environ Qualification of Electrical Equipment.Responds to Concerns Noted in 800919 Draft Interim Technical Evaluation Rept.Splice Analysis Encl

ML093430328
Person / Time
Site:	Indian Point, Brunswick
Issue date:	10/30/1980
From:	Zulla S Power Authority of the State of New York
To:	Varga S Office of Nuclear Reactor Regulation
Shared Package
ML093430329	List: ML093430328 ML100271768 ML19339B244 ML19339B245
References
IP-JCS-10633, NUDOCS 8011060569
Download: ML093430328 (11)

Text

POWER AUTHORITY OF THE STATE OF NEW YORK INDIAN POINT NO. 3 NUCLEAR POWER PLANT L EC2V:4z D3ISTRIBUTION P. 0. BOX 215 BUCHANAN, N. Y. 10511 SERVICES UNIT TELEPHONE: 914-739-8200 I9 Mr530 P4960 25 IP-JCS-i0633 ET~jTtON SERVICES Director of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Stephen A. Varga, Chief Operating Reactor Branch No. I Division of Operating Reactors

Subject:

Indian Point No. 3 Nuclear Power Plant Docket 286 Environmental Qualifications of Electrical Equipment

Dear Sir:

As a result of NRC Letter, A. Schwencer to G. Berry dated March 5, 1980, which in cluded Indian Point No. 3 into the Systematic Evaluation Program concerning the Environmental Qualification of Electrical Equipment a detailed review was con ducted and submitted on April 28, 1980.

Since questions were raised concerning this task, a regional meeting was held at King of Prussia, Pa. dated July 7, 1980, the NRC stated that all Nuclear Plants under 79-01B and SEP had to have completed responses by November 1, 1980. Indian Point No. 3 stated that they had submitted all the information and had also been audited by Franklin Research Center and by the N.R.C. The NRC response was that this date did not apply to Indian Point.

An order for Modification of License dated August 29, 1980 signed by Stephen A. Varga, and a corrected version dated September 19, 1980, signed by Darrell G. Eisenhut were received by the Authority. The order dictated that all the information needed for the S.E.P. must be submitted by November ist. It was not stated but the NRC understood that this order included the response to the Technical Evaluation Report (TER). The draft interim TER was received from Franklin Research Center on September 19, 1980, and same was reviewed by the Power Authority. The report listed a number of concerns that covered many items. Some of the concerns referred to deficiencies in the documentation, the equipment tested as not being the same as the equipment installed and lack of completely answering the DOR guidelines.

After intensive review of the report by the Authority the following concerns have been addressed:

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Section 3.3.1.A Limit Switches on PCV 1170, 1172, 1190, 1191; 119'2 Franklin's concern is the comparison of the NAMCO EA-180 limit switch to the EA-740. Enclosed is the qualification report from NAMCO Controls covering the EA-180 limit switch.

Section 3.3.1.7 Micro Switches on Hydrogen Recombiner We are designing a shield for the source of radiation which will degrade the environment in the location of the Hydrogen Recombiner control panel.

This yields a decrease in the exposure to the limit switch to 4.0 X 10 2 rads.

This is a significant change in the exposure to the equipment; hence, we consider this area non-hostile.

Section 3.3.1.8.A Limit Switches on Fan Cooler Units The switches are installed at Indian Point No. 3 with Conax connectors.

The connector is a sealed unit that was tested and qualified for use inside containment. The connectors were thermally aged prior to being radiated to 1.5 X 108, LOCA tested to 340°F (max.) and seismically tested to 3 g's vertical and 3.5 g's horizontal. The LOCA test consisted of a chemical spray consisting of Boron and NaOH with a 10.5 pH continued for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before switching to demineralized water.

After the 30 day test all results were satisfactory and no observable deficiencies were detected.

Conax connectors were also used on the switches in section 3.3.1.3.

Section 3.3.2.1.A and B MOV 856 A-K, MOV 880 A-K, MOV 745 A & B, MOV 1802 A & B, MOV 889 A & B, MOV 746, MOV 747, MOV 899 A & B The main concern is that the equipment tested was not an exact duplicate of the equipment installed. In the report B0058, which we believe is already in Franklin Research Center's possession, the subject of thermal aging of the actuator is addressed and shown to be acceptable. The subject of exposed to radiation of the actuator is also addressed in B0058 satisfactorily.

Section 3.3.2.2.B MOV 894 A-D The accumulator motor-operated valves, item 7, are not required to be operated after the injection phase.

Section 3.3.2.2.G With respect to the replacement of the motor operators committed, Limitorque Report B0058 again addresses the difference in the tested units and units which are to be installed.

Section 3.3.2.4 PT 1126, 1205, 1260, 1261, 1262, 1263, 1264, 1265, 406 A & B, FT 1200, 1201, 1202, 1203.

In response to the concern of water and steam jetting, the justification for not being concerned of the jetting in the auxiliary pump room is 2 of 6

oP-discussed in the *ysis of High Energy Lines pre d for Con Edison by United Engineers dated May 3, 1973, which has be docketed. Two redundant valves in the main steam supply line to the auxiliary feed pump turbine outside this room has been installed. Each valve is signaled to close automatically on high temperature by its own temperature sensor located in the auxiliary feed pump room. Each valve has control room indication, control and alarm. Each system is completely independent of the other. Therefore, with the closure of the isolation valves upon a steam line break steam jetting would be eliminated. Water jetting has not been included within the scope of the DOR guidelines. Loss of these transmitters will not prevent the ability to safely bring the plant to cold shutdown since manual control capabilities exists.

In addition, it is felt worthwhile to reiterate note "r" of our response, dated April 28, 1980, which states, "Since a concurrent break in the main steam line, feedwater system or a loss of cool ant accident in conjunction with a break in the auxiliary feedwater pump steam line results in a double failure and is not considered using single failure criteria, a break in the auxiliary feedwater pump steam line is the accident. With this break, the auxiliary feed system is not initiated because of the small loss of steam, followed by isolation by valves 1310 A and B. Therefore, there is no need for pumps to start and valving to change position."

Section 3.3.2.5 PT 419 A-C, 429 A-C, 439 A-C, 449 A-C, 1163, 1164, 1165, 1166, FT 418 A & B, 428 A & B, 438 A & B, 448 A & B In response to the concern of water and steam jetting, the justification for not being concerned of the jetting in the auxiliary pump room is discussed in the Analysis of High Energy Lines prepared for Con Edison by United Engineers dated May 3, 1973, which has been docketed. Two redundant valves in the main steam supply line to the auxiliary feed

.pump turbine outside this room has been installed. Each valve is signaled to close automatically on high temperature by its own temperature sensor located in the auxiliary feed pump room. Each valve has control room indication, control and alarm. Each system is completely.

independent of the other. Therefore, with the closure of the isolation valves upon a steam line break steam jetting would be eliminated.

Water jetting has not been included within the scope of the DOR guidelines.

Section 3.3.2.9.A and C PCV 1191, 1192, FCU 1170, 1172, 1190 The concern is that the ASCO solenoid valves NP 8316A75E which was installed differs from the tested model NP 831665E. The difference between the valves are the size of the pipe connection and the orifice.

The concern of aging is on-going, however, since we have data to indicate that the solenoid will perform its function for a minimum of four years, a small replacement schedule is incorporated. This schedule will be modified as necessary when more data on aging is received.

Section 3.3.1.10.A SOV 519, 552, 956 A-H 548, 549, 1788, 1789, 1702, 1705, 1723, 1728, 1786, 1787, 201, 202, 791, 793, 796, 798.

LCV-1158, PCV 1234-1241, 1223-1226A, 11711 1173, 1228, 1214-1217A.

This paragraph implies that the degraded environment will effect the metallic spring. We do not see the reason for this conclusion since the environment will not have an adverse effect on a metallic spring.

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Section 3.3.2.11 PCV 197, 1187, 1188, 1121, 1123, 417,027, 437, 447 This concern is covered by the jet and water discussion in Section 3.3.2.5.

Section 3.3.2.12 MS-1-31, MS-1-32, MS-1-33, MS-1-34, SOV 1310 A and B This concern is covered by the jet and water discussion in section 3.3 2.5.

In addition, the Laurence solenoid valves used on the main steam stop valves are discussed by the High Energy Line Analysis. The report states that the solenoids are protected from steam and water jetting by the shield wall.

Section 3.3.2.13 Hydrogen Recombiner Solenoid Valves We are designing a shield for the source of radiation which will degrade the environment in the location of the Hydrogen Recombiner Control Panel. There-'

fore the associated shielding analysis yielded a total integrated dosage less than initially reported in our April 28, 1980 submittal. The new dosage will be 4.0 X 102 rads. Hence we consider this area non-hostile.

Section 3.3.2.14 FCV 1121, 1123 In response to the concern of water and steam jetting, the justification for not being concerned of the jetting in the auxiliary pump room is discussed in the Analysis of High Energy Lines prepared for Con Edison by United Engineers dated May 3, 1973, which has been docketed. Two redundant valves in the main steam supply line to the auxiliary feed pump turbine outside this room has been installed. Each valve is signaled to close automatically on high temperature by its own temperature sensor located in the auxiliary feed pump room. Each valve has control room indication, control and alarm. Each system is completely independent of the other. Therefore, with the closure of the isolation valves upon a steam line break steam jetting would be eliminated. Water jetting has not been included within the scope of the DOR Guidelines.

Section 3.3.2.15 Auxiliary Feed Pump Drive Motors We are obtaining further documentation from Westinghouse to substantiate the conclusions that the motors are qualified under the documentation in our submittal dated April 28, 1980.

Section 3.3.2.16 Safety Injection Pump Motor, Residual Heat Removal Pump Motor We are obtaining further documentation from Westinghouse to substantiate the conclusions that the motors are qualified under the documentation in our submittal dated April 28, 1980.

Section 3.3.2.17 Recirculation Pump Motor, Fan Cooler Unit Motors We are obtaining further documentation from Westinghouse to substantiate the conclusions that the motors are qualified under the documentation in our submittal dated April 28, 1980.

Section 3.3.2.19 Terminal Blocks All the terminal blocks inside containment are mounted in junction boxes.

Resilient washers will be installed under the blocks to perclude any failures.

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Section 3.3.2.20 Penetrations The design of the penetration is such that all mechanical joints are metal to-metal, metal to ceramic or metal to glass. No reliance is placed on organic compounds or potting componds of any type to effect a mechanical joint and/or leak tight seal.

In addition, the Brunswick Nuclear Power Plant penetration is constructed the same as Indian Point's with respect to it's seals. Attached is an en vironmental qualification report for the Brunswick Plant which includes irradiation of the various components. Treated steam was used in the test which has a higher conductivity than boron, also the components which are exposed to the containment environment are non-corresive with respect to boron.

Section 3.3.2.21 and 3.3.2.22 -Cables and Splices The T.E.R. states that our reference #22 is not directly relevant to qualification.

We would like to point out that this document forms th& bridge between the type of cables that were tested and installed. The document also spells splicing procedure which were used in the field therefore it is also valuable in order to compare with the tested splice. The document also identifies the manufactures who supplied the cable by tabulating the associated purchase orders. The following is a comparison between the environment qualif ication tests performed at Franklin Institute Research Lab and the cables used at IP for safety related systems.

We concur that reference #23 of our 'response is not applicable to 1P3, this was an oversite.

The kerite cable received 50M rads of gamma dose which is more than adequate to encompass the accumulation of the exposure stated in the guidelines of 20 M rads and any additional dosage due to Beta., The installed life dosage is considered in the guideline recommended exposure therefore further defining this valve is pointless.

The cable order specification for 1P2 an'd IP3 are identical therefore the actual cables must be fabricated with some formulation of insulation and jacket material. With respect to the Lewis Gable Section 3.3.2.22 paragraph b the statement does not follow. "The description of both the installed cable and test specimen are somewhat vague, but seems to refer to different construction."

See Attachment on cables 5 of 6

Section 3.3.2.25 Resis ce Temperature Detector Elemer*

The wide range resistance temperature detector elements are on a schedule and are changed out accordingly.

Section 3.3.3.1 Gem Level Switches NUREG 0578 required installation of an environmentally qualified level system..

We are proceeding with the installation of that system. The transmitters are ordered and will be installed at the next outage of-sufficient duration.

Section 4.0 Conclusions The Power Authority takes exception to the fact that Franklin Research Center referenced a report concerning the levels of radiation inside the plant and compared this to Indian Point No. 3. The report was used in Consolidated Edison's S.E.P. response and the Power Authority had not reviewed it.

Appendix A - Environmental Service Conditions The assumptions made by Franklin were conservative with respect to accident and normal environments in non-hostile areas. The concern of ventilation in these areas were discussed at the regional meeting at King of Prussia, Pa., dated 7/7/80, and was deferred until a later date. In addition, the curves for the Containment Building should not be bounded as suggested by this report.

An aging and qualified life program is ongoing at Indian Point No. 3. All the suppliers have been contacted and given the model numbers and serial numbers of their supplied equipment. The vendors are supplying bills of material for this equipment. When the bills are received, the material is reviewed and the effects of radiation and thermal aging is determined from the data that is available for the material.

In response to the letter received from the NRC dated October 1, 1980, signed by Darrell G. Eisenhut covering the testing of electrical equipment to en vironmentally qualify it, the Power Authority does not have any equipment scheduled to be tested at this time. We will contact the NRC when we plan on testing any component.

The Power Authority of the State of New York reserves the right to request a hearing on any questions brought forth on the subject of environmental qualification of electrical equipment.

Very truly yours, S. S. a Resident Manager JCS/jd Enclosures State of New York )

County of Westchester) SS:

On this ist day of November,11980, personally appeared before me S. S. Zulla, known to me as the person who executed the above document.

/RUTHANNE B. BOWMAN Notary Public, State of New Yo&

No. 4651904, Westchester County 6 of 6 Commission Epires March 30, 1981

SPLICE ANALYSIS 1/C #4 with silicone rubber insulation and having Mylar wrap and asbestos outerbraid. Purchase Order - United Engineers and Constructors 9321-05-i13-3 o - General Electric Environmental Test Splice Field Splice Remarks

1. Hydent compression 1. Burndy Hydent compres Same connector sion connector

2. Raychem flexible end 2. Raychem polyolefin Fishback & Moore infor Viton Spec. RT-1312 expanded molded parts mation indicates Raychem (part no. 202B821) as per Raychem spec. 202B811-3-00 Molded parts RT-301. used.

3. Adhesive a two-part 3. Adhesive a two part Same sealant G.E. Co. sealant G.E. Co.

Type RTV-615. Type RTV-615.

4. Outer most jacket Additional HST applied completed with Kynar to field splice.

HST* as per Raychem spec. RT-850.

• Heat Shrinkable Tubing.

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SPLICE ANALYSIS 1/C #12 with silicone rubber insulation and having Mylar wrap and asbestos outerbraid. Purchase Order - United Engineers and Constructors 9321-05-113-3( General Electric.

Environment Test Splice Field Splice Remarks

1. Hydent compression 1. Burndy Hydent Compres Same connector. sion connector.

2. Adhesive, G.E. Co. 2. Adhesive, G.E. Co. Same RTV-102 One part RTV-102.

sealant.

3. Raychem SFR HST as per 3. Raychem SFR HST as per Same specification RT-1140. specification RT-1140.

4. Raychem Kynar HST as 4. Raychem Kynar HST as Same per specification per specification RT-850. RT-850.

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SPLICE ANALYSIS 2/C #12 Kerite cable 3/64" insulation, FR braid, zinc tape and FR jacket.

Purchase Order - United Engineers and Constructors 9321-05-i13-5g Kerite Co.

Environmental Test Splice Field Splice Remarks

1. Hydent Compression 1. Burndy Hydent compres Same connector. sion connector.

2. Raychem SCL HST with 2. Raychem WCS HST with As per UE&C SCL meltable adhesive inner mastic type sealant not-available therefore wall as per Raychem precoated. TCS substituted approved.

Compound RT-862. WCS is an upgrade of TCS (i.e. walls thicker).

3. Raychem RT-876 HST. 3. Raychem WCS HST with WCS is an upgrade of mastic type sealant RT-876 (i.e. walls thicker precoated. and includes a mastic adhesive.

4. Raychem Kynar HST 4. Raychem Kynar HST Same as per specification as per specification RT-850. RT-850.

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SPLICE ANALYSIS Multiconductor silicone rubber insulation with glass bread with overall jacket of aluminum, shielding glass braid and silicone rubber. Purchase Order United Engineers and Constructors 9321-05-113 Lewis Cable.

Environment Test Splice Field Splice Remarks NONE 1. Burndy Hydent Connector Acceptable based on.

satisfactory results of similar splices for

2. Adhesive, G.E. Co. the 1/C #12 cable.

RTV-102.

3. Raychem Type SFR HST per specification RT-1140.

4. Repeat 2. and 3. over jacket.

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