ML15261A218
| ML15261A218 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 01/21/1999 |
| From: | Joseph Sebrosky NRC (Affiliation Not Assigned) |
| To: | NRC (Affiliation Not Assigned) |
| References | |
| NUDOCS 9901220365 | |
| Download: ML15261A218 (25) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-001 January 21, 1999 LICENSEE:
Duke Energy Corporation (Duke)
FACILITY:
Oconee Nuclear Station, Units 1, 2, and 3
SUBJECT:
SUMMARY
OF MEETING BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION (NRC) STAFF AND DUKE REPRESENTATIVES TO DISCUSS THE OCONEE LICENSE RENEWAL APPLICATION REGARDING ENVIRONMENTAL QUALIFICATION (EQ)
On January 19, 1999, representatives of Duke met with the NRC staff in Rockville, Maryland, to discuss the Oconee license renewal application regarding EQ. A list of meeting attendees is provided as Enclosure 1.
The purpose of the meeting was to discuss how Duke will respond to requests for additional information (RAls) 5.6-1, 5.6-2, and 5.6-3 in the EQ area. A draft of how Duke will respond to these RAls was provided at the beginning of the meeting (Enclosure 2). Prior to the meeting, the staff had given Duke the option to follow the approach that was outlined in a January 7, 1999, letter to Baltimore Gas and Electric. Duke chose to adopt portions of this approach in its draft response. Specifically, Duke provided a summary description of the Oconee EQ program and its implementation in the draft response modeled after the information provided in the January 7, 1999, letter. In addition, Duke provided answers to the RAls that the NRC staff had asked.
The NRC staff agreed with the general approach used to answer the RAls as documented in the draft responses. However, the staff did have some comments regarding the summary description, and the draft RAI responses themselves that Duke agreed to adopt. Regarding the summary description, Duke agreed to reference standards to the extent practical and to supplement the "Reanalyze the qualified life calculation" discussion that starts at the bottom of page 6 of Enclosure 2 in accordance with the January 7, 1999, letter. Specifically, Duke agreed to add a discussion regarding the following: analytical methods, data collection and reduction, underlying assumptions, acceptance criteria, and describing the process by which changes to the underlying assumptions will be made in the future.
Regarding analytical methods, Duke will clarify what thermal model and radiation method it used in the EQ calculations. For data collection and reduction, Duke will provide examples of the temperature data collection and reduction methods it used in the EQ calculations. Concerning underlying assumptions, Duke will add a discussion that no major plant modifications were made, or an event of sufficient duration occurred, that would change the temperature and radiation numbers that were used in the underlying assumptions in the EQ calculations.
Regarding acceptance criteria and corrective actions, Duke will add a discussion about the margins that are inherent in the calculations. For describing the process by which changes to the underlying assumptions will be made in the future, the staff agreed that the "Plant Environmental Changes" discussion that begins on page 8 of Enclosure 2 resolves most of the staffs concerns identified in item 4 of the January 7, 1999, letter in this area. However, the staff requested Duke to add a discussion of how such changes are controlled when they do not change the current licensing basis.
9901220365 990121 PDR ADOCK 05000269 P
DR,
January 21, 1999 Regarding the RAI responses themselves, the staff requested that Duke modify the draft response for RAI 5.6-3. Specifically, Duke agreed to supplement line 11 on page 19 of the draft response to highlight that this portion of the response differs from the material that is contained in its license renewal application (i.e., the license renewal application implies that Duke has no plans to extend the qualified life of equipment, while the RAI response leaves the reanalyses option open). Duke also agreed to add a statement that there is not enough moisture to be a concern regarding aging as it applies to the Arrhenius methodology.
In addition to the discussions above, the staff reviewed details of five EQ calculations. The staff reviewed the two calculations that were requested in RAI 5.6-1 (i.e., calculation OM-360-24 for the Rosemount resistance temperature detectors, and calculation OM-337.00-0080-001 for the Viking electrical penetrations). The staff also reviewed three of the six calculations that were requested in RAI 5.6-2 (i.e., calculation OSC-7167 for Limitorque Acuators, calculation OSC 6530 for Okinite EPR/Neoprene Cables, and calculation OSC-7055 for Samuel Moore EPDM/Hypalon cables).
In its draft RAI responses, Duke provided summary descriptions of the basis of the analyses for all of the above calculations with the exception of calculation OSC-7055 for the Samuel Moore EPDM/Hypalon cables. The staff stated that Duke no longer needs to docket the eight calculations that were requested in RAls 5.6-1 and 5.6-2. Instead, the staff agreed that the four summary descriptions that are provided in the draft RAI response were sufficient to answer the question. The staff believes that the calculations do not need to be docketed because the summary descriptions provided in the draft RAI responses illustrate the basis upon which Duke:
c) demonstrated that the analyses remain valid for the period of extended operation in accordance with 10 CFR 54.21(c)(1)(i), and d) demonstrated that the analyses have been projected to the end of the period of extended operation in accordance with 10 CFR 54.21(c)(1)(ii).
During a discussion regarding the EQ master list, Duke noted that the list currently does not flag equipment for replacement, or reanalyses that expires after 40 years of operation. Duke stated that the list would be updated prior to the 4 0th year of operation for the Oconee units.
Docket
~~~Or No.5-69 020 ad5-8 Jose~p r
Project Manager License Renewal Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation Docket Nos. 50-269, 50-270, and 50-287
Enclosures:
As stated (2) cc w/encls: See next page DISTRIBUTION:
See next page DOCUMENT NAME:G:\\SEBROSKY\\1-19EQ D.WPD OFFICE LA PDLR/DRPM:PM EELB/DE PDLR:D NAME LBerry JSebrosky PShemanski CGrimes DATE
/;\\ /99 A /4\\/99 1 /21/99 1/11199 OFFICIAL RECORD COPY
Oconee Nuclear Station (License Renewal) cc:
Mr. J. E. Burchfield Ms. Lisa F. Vaughn Compliance Manager Duke Energy Corporation Duke Energy Corporation 422 South Church Street Oconee Nuclear Site Mail Stop PB-05E P. 0. Box 1439 Charlotte, North Carolina 28201-1006 Seneca, South Carolina 29679 J. Michael McGarry, Ill, Esquire Ms. Karen E. Long Anne W. Cottingham, Esquire Assistant Attorney General Winston and Strawn North Carolina Department of Justice 1400 L Street, NW.
P. 0. Box 629 Washington, DC 20005 Raleigh, North Carolina 27602 Mr. Rick N. Edwards L. A. Keller Framatome Technologies Manager - Nuclear Regulatory Licensing Suite 525 Duke Energy Corporation 1700 Rockville Pike 526 South Church Street Rockville, Maryland 20852-1631 Charlotte, North Carolina 28201-1006 Manager, LIS Mr. Richard M. Fry, Director NUS Corporation Division of Radiation Protection 2650 McCormick Drive, 3rd Floor North Carolina Department of Clearwater, Florida 34619-1035 Environment, Health, and Natural Resources Senior Resident Inspector 3825 Barrett Drive U. S. Nuclear Regulatory Commission Raleigh, North Carolina 27609-7721 7812B Rochester Highway Seneca, South Carolina 29672 Gregory D. Robison Duke Energy Corporation, Regional Administrator, Region II Mail Stop EC-12R U. S. Nuclear Regulatory Commission P. 0. Box 1006 Atlanta Federal Center Charlotte, North Carolina 28201-1006 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30303 Robert L. Gill, Jr.
Duke Energy Corporation Virgil R. Autry, Director Mail Stop EC-12R Division of Radioactive Waste Management P. 0. Box 1006 Bureau of Land and Waste Management Charlotte, North Carolina 28201-1006 Department of Health and RLGILL@DUKE-ENERGY.C0M Environmental Control 2600 Bull Street Douglas J. Walters Columbia, South Carolina 29201-1708 Nuclear Energy Institute 1776 I Street, NW County Supervisor of Oconee County Suite 400 Walhalla, South Carolina 29621 Washington, DC 20006-3708 DJW@NEI.ORG W. R. McCollum, Jr., Vice President Oconee Site Chattooga River Watershed Coalition Duke Energy Corporation P. 0. Box 2006 P. 0. Box 1439 Clayton, GA 30525 Seneca, SC 29679
ATTENDANCE LIST JANUARY 19, 1999 NRC MEETING WITH DUKE OCONEE UNITS 1, 2 AND 3 NAME ORGANIZATION Bob Smith Duke Energy R. Paul Colaianni Duke Energy Robert Gill Duke Energy William M. Denng Ogden Chris Grimes*
NRR/DRPM/PDLR Joe Sebrosky NRR/DRPM/PDLR Steve Hoffman*
NRR/DRPM/PDLR Bob Prato*
NRR/DRPM/PDLR Sandra Cooke*
NRR/DRPM/PDLR Jose Calvo*
NRR/DE/EELB Dale Thatcher NRR/DE/EELB Paul Shemanski NRR/DE/EELB Jit Vora RES/DET/EMMEB Caudle Julian (Part time via phone)
NRC/Regionll/DRP Doug Walter NEI James Kilpatrick Baltimore Gas and Electric Don Palmrose NUS-IS Lynn Conner*
DSA Deann Raleyr*
SERCH, Bechtel Power Nancy Chapman*
SERCH, Bechtel Power
- Part time
Distribution:
Hard copy PUBLIC Except for the attendees list in Enclosure 1, an advance copy of the handouts to this meeting summary were sent directly to the PDR on 1/20/99 Docket File PDLR RF M. EI-Zeftawy, ACRS T2E2 E-mail R. Zimmerman D. Matthews C. Grimes T. Essig J. Strosnider G. Bagchi H. Brammer T. Hiltz G. Holahan S. Newberry C. Gratton R. Correia R. Latta J. Peralta J. Moore R. Weisman M. Zobler E. Hackett A. Murphy F. Cherny D. Martin W. McDowell S. Droggitis PDLR Staff H. Berkow D. LaBarge L. Plisco C. Ogle R. Trojanowski M. Scott C. Julian R. Architzel J. Wilson R. Gill, Duke D. Walters, NEI
DRAFT Response to Oconee RAIs for Section 5.6 of Exhibit A of the Application 1
RAIs for Section 5.6 of Exhibit A of the Application 2
Per clarification of the RAIs for Section 5.6 of Exhibit A of the Application RAI with the staff, a 3
summary description of Oconee Environmental Qualification program and its implementation is 4
provided prior to answering specific RAIs.
5 6
The following are the main topics contained in this summary description:
7 Oconee Environmental Oualification Program Summary Description 8
Oconee EQ program Responsibilities 9
EQ Process 10
- Original Qualification Basis 11
- EQ Master List 12
- EQ Maintenance Manual 13
- Replacement of EQ Equipment 14 a) Replace the existing equipment with identical equipment 15 b) Replace the equipment with different equipment which is already evaluated 16 under the EQ program 17 c) Replace the equipment with different equipment which is not currently 18 evaluated under the EQ program 19 d) Reanalyze the qualified life calculation 20
- Refurbishment of EQ Equipment 21
- Procurement of EQ Equipment 22
- Plant Environmental Changes 23 24 25 Oconee Environmental Qualification Program Summary Description 26 The Nuclear Regulatory Commission (NRC) has established nuclear station environmental 27 qualification (EQ) requirements in 10 CFR 50 Appendix A, Criterion 4, and in 10 CFR 50.49.
28 10 CFR 50.49 specifically requires that an EQ program be established to demonstrate that certain 29 electrical equipment located in "harsh" plant environments (i.e., those areas of the plant that 30 could be subject to the harsh environmental effects of a loss of coolant accident (LOCA), high DRAFT RAI Response Page 1 of 20 DRAFT RAI Response
g DRAFT Response to Oconee RAls for Section 5.6 of Exhibit A of the Application I
energy line breaks (HELBs) and post-LOCA radiation) are qualified to perform their safety 2
function in those harsh environments. The requirements of §50.49 apply to all new and 3
replacement electrical equipment, within the scope of the §50.49, purchased after February 22, 4
1983.
5 6
The scope of equipment covered by the Oconee EQ program is:
7 Safety-related (as defined in §50.49) electrical equipment located in a postulated harsh 8
environment that is required to mitigate the consequences of the accident causing the harsh 9
environment, or whose subsequent failure can degrade safety systems or mislead the plant 10 operator.
11 Nonsafety-related electrical equipment located in a postulated harsh environment whose 12 failure could prevent a safety function or mislead the plant operator. The impact to 13 emergency operation procedures should be considered in the failure analysis.
14 Post-accident monitoring equipment located in a postulated harsh environment designated as 15 requiring qualification in the Regulatory Guide 1.97 section of Duke Power Company's 16 Response to Supplement 1 of NUREG-0737.
17 18 The Oconee EQ program is described in Section 3.11 of the Oconee UFSAR and is 19 administratively controlled by a nuclear station which explicitly defines the responsibilities and 20 requirements for implementing the Oconee EQ program to ensure compliance with §50.49.
21 22 The Oconee EQ program is currently implemented as described in this summary. Changes in the 23 implementation of the Oconee EQ program as described in this summary are made whenever 24 appropriate by changing the controlling nuclear station directive. Changes to the nuclear station 25 directive for the EQ program are administratively controlled by a nuclear station directive which 26 gives instructions for administrative procedures and the Oconee quality assurance process to 27 ensure continued compliance with §50.49.
28 DRAFT RAI Response Page 2 of 20 DRAFT RAI Response
DRAFT Response to Oconee RAIs for Section 5.6 of Exhibit A of the Application 1
The Oconee EQ program consists of activities which are integrated into the overall plant design 2
and modification process including, initial design and modification (e.g. selection and application 3
of equipment), documentation review and approval, maintenance, refurbishment, replacement 4
and procurement. The following is a summary description of these activities and how they are 5
implemented.
6 7
Oconee EQ program Responsibilities 8
Oconee EQ program responsibilities are assigned to several groups within Duke. The nuclear 9
general office has the responsibility to provides overall administration of the EQ program, 10 provide technical support for EQ related issues, control and administer the EQ maintenance 11 manual, resolve generic EQ issues, provide information to the other station sections and divisions 12 to maintain qualification.
13 14 Station engineering has the responsibility to provide information and technical support to the 15 craft and other station sections and divisions for EQ related issues, ensure that all EQ mandated 16 activities are addressed and scheduled, control and administer the EQ master list and the EQ 17 criteria manual, ensures that the station modification process addresses EQ requirements such as 18 the degree of documentation required, specification of applicable environmental parameters in 19 procurement documents, and review and approval of environmental qualification test plans.
20 21 The station maintenance organization has the responsibility to write and implement station 22 procedures, and ensure that maintenance personnel are properly trained on the EQ program.
23 Other departments who maintain equipment at the station are responsible for ensuring the 24 qualification of this equipment is maintained as specified by the EQ maintenance manual.
25 26 DRAFT RAI Response Page 3 of 20 DRAFT RAI Response
DRAFT Response to Oconee RAls for Section 5.6 of Exhibit A of the Application 1
EQ Process 2
3
- Original Qualification Basis 4
In establishing the original qualification basis for the equipment, and in developing the EQ 5
master list and EQ maintenance manual, all equipment within the scope of §50.49 were reviewed 6
under the quality assurance program. Each test report was reviewed under an environmental 7
qualification test report and analysis summary and placed on file and each piece of equipment, by 8
tag number, was reviewed under an EQ documentation review and verification to document that 9
qualification of the equipment was adequate for its intended application.
10 11 The EQ process is controlled by two documents, the EQ master list and the EQ maintenance 12 manual, which are described next.
13 14 EQ Master List 15 The EQ master list provides an up-to-date, controlled listing and references for electrical 16 equipment in the Oconee EQ program. All EQ master list information must be originated and 17 revised according to the nuclear station directive which controls the EQ program. The EQ 18 master list provides equipment information such as:
19 a) Station tag number of the equipment 20 b) The manufacturer and model or series number for the equipment 21 c) The building, floor elevation and specific location of the equipment 22 d) If the equipment is located in a harsh or mild environment 23 e) The applicable EQ maintenance manual section which addresses maintaining the 24 qualification of the equipment 25 f) The equipment installation date 26 g) The qualified life of the equipment 27 28 EQ Maintenance Manual 29 The EQ maintenance manual defines the specific requirements for maintaining EQ equipment in 30 its qualified configuration and ensures consistency in maintaining the environmental DRAFT RAI Response Page 4 of 20 DRAFT RAI Response
DRAFT Response to Oconee RAls for Section 5.6 of Exhibit A of the Application 1
qualification of electrical equipment within the scope of §50.49. All EQ maintenance manual 2
information must be originated and revised according to the nuclear station directive which 3
controls the EQ program. The EQ maintenance manual specifically addresses the following 4
activities:
5 a) EQ mandated maintenance required to maintain the equipment qualification 6
b) The qualified life of the equipment, any component part to be replaced and the 7
replacement interval (i.e., replace cover o-ring every 18 months) 8 c) The electrical cable termination method 9
d) If the equipment cable entrance must be sealed to prevent moisture intrusion 10 e) Installation and mounting configurations required to maintain qualification 11 f) The shelf life for the equipment or components parts along with storage requirements 12 g) Procurement and reorder information specific to the equipment 13 14 Documentation such as maintenance manuals, test reports, calculations, and installation 15 specifications, from which the activity requirements originate or must be used to implement the 16 requirements, is referenced under each of the activities. The requirements contained in the EQ 17 maintenance manual section for specific equipment are incorporated into craft work procedures 18 (maintenance, termination, sealing, installation), the work management system (scheduling &
19 replacement), and procurement engineering procedures (shelf life and procurement).
20 21 Replacement of EQ Equipment 22 Prior to the expiration of the qualified life of a piece of EQ equipment, a notice is generated by 23 the Oconee work management system to alert engineering that the equipment is scheduled for 24 replacement in the near future. Several options are available:
25 26 a) Replace the existing component with an identical component - This option only 27 requires the generation of a work order and an update to the EQ master list since all the 28 required documentation and procedures already exist.
29 b) Replace the equipment with different equipment which is already evaluated under 30 the EQ program -When new or replacement EQ equipment is installed in the plant DRAFT RAI Response Page 5 of 20 DRAFT RAI Response
DRAFT Response to Oconee RAls for Section 5.6 of Exhibit A of the Application 1
which is currently addressed in the EQ maintenance manual, the equipment is added to 2
the EQ master list and a review is performed which:
3 Confirms that the EQ maintenance manual addresses the specific manufacturer and 4
model number of the equipment.
5
- Identifies the plant areas for which the component is qualified to be installed.
6
manual.
8
- Identifies additional documentation relevant to the application versus the tested 9
configuration and test parameters.
10 Identifies where the equipment is to be located and whether the location is in a 11 postulated harsh environment area.
12
- Confirms that the new or replacement component is qualified for its application.
13 c) Replace the equipment with different equipment which is not currently evaluated 14 under the EQ program - When replacing a piece of equipment with one not already 15 addressed in the EQ program, a QA Condition 1 calculation (to verify assumptions and 16 conclusions) is performed to document the qualification of the equipment. This 17 calculation includes the following:
18 Equipment Data - Includes data such as equipment tag numbers, manufacturer, QA 19 condition, specifications, and applicable test report.
20 Functional Review - Determine applicability of §50.49 to the equipment; i.e.,
21 installed in a postulated harsh environmental area, required to operate during an 22 accident, etc.
23 Environmental Qualification Review - examines test parameters vs. installed 24 accident parameters, operability times, qualified life, equipment tested versus 25 installed equipment, test report anomalies, etc.
26 This information is evaluated and a determination made that the equipment is not 27 qualified for the application or certifies that the equipment is qualified for the application.
28 d) Reanalyze the qualified life calculation - The reanalysis is done for a specific 29 application to extend the qualified life if excess conservatism exists in the original DRAFT RAI Response Page 6 of 20 DRAFT RAI Response
00 DRAFT Response to Oconee RAls for Section 5.6 of Exhibit A of the Application 1
qualified life calculation. Conservatisms may include such things as the assumed 2
ambient temperature of the equipment, an unrealistically low activation energy, or 3
application of the equipment (de-energized versus energized). The reanalysis is 4
documented under a QA Condition 1 calculation with data to verify all assumptions and 5
conclusions. Typically, the guidelines outlined in EPRI TR-104873, Methodologies And 6
Processes To optimize Environmental Qualification Replacement Intervals, are followed.
7 It should be noted that adequate margin, per established industry standards, is maintained 8
during any reanalysis.
9 10 Refurbishment of EQ Equipment 11 Qualified equipment is required to be refurbished before it can be placed back into storage if the 12 equipment is to be used in EQ applications following storage. Refurbishment is performed in a 13 manner that preserves its qualification. This is typically accomplished by replacing "soft" items 14 such as gaskets, seals, and wires which have a limited life.
15 16 All EQ limited life/replacement parts are identified in the EQ maintenance manual for a 17 particular equipment, manufacturer and model. These parts must be replaced prior to placing the 18 equipment into storage to maintain its qualified configuration. Additionally, guidance for shelf 19 life of refurbished equipment is contained in the introduction to the EQ maintenance manual.
20 21 Procurement of EQ Equipment 22 Procurement policy and criteria for QA Condition 1 equipment within the scope of §50.49 is 23 controlled by the nuclear station directive for equipment procurement, the nuclear station 24 directive for the EQ program, and the nuclear station directive for the quality standards manual.
25 26 Procurement of like-for-like replacement EQ equipment is controlled such that the equipment 27 procured is as good as or better than the original equipment. The procurement process also 28 assures applicable performance requirements and qualification criteria are met. Guidance for 29 assuring qualification is found in the EQ maintenance manual section for a particular piece of DRAFT RAI Response Page 7 of 20 DRAFT RAI Response
DRAFT Response to Oconee RAIs for Section 5.6 of Exhibit A of the Application I
equipment. The procurement section in the EQ maintenance manual addresses the manufacturer 2
or vendor from which to purchase the equipment, the test reports to be referenced on the 3
requisition and the specification numbers to which the equipment is to be purchased.
4 5
Specifications for procurement of new EQ equipment are reviewed by the nuclear general office 6
or Oconee EQ coordinator to ensure applicable performance requirements and qualification 7
criteria are met. Test plans are reviewed and approved prior to testing to assure compliance with 8
the specification. Upon receipt of a new test report, the responsible engineer will initiate an EQ 9
test report and analysis summary which establishes the qualification of the equipment. A copy of 10 the summary is also inserted into the test report and is formally placed on file under a controlled 11 documentation number. Updating the EQ master list and the EQ maintenance manual are 12 handled similar to the replacement process addressed above.
13 14
- Plant Environmental Changes 15 Plant environmental zones are identified in the Oconee EQ criteria manual. The EQ criteria 16 manual identifies the harsh environmental areas of the plant for LOCA, HELBs, and radiation.
17 The EQ criteria manual is a QA.Condition 1 controlled document. Changes in the environmental 18 parameters are initially reviewed, to address on a generic basis if applicable, by the nuclear 19 general office EQ coordinator in conjunction with the EQ criteria manual responsible engineer.
20 If the changes cannot be dispositioned on a generic basis, the problem investigation program 21 would be initiate to resolve the specific equipment concerns. It should be noted that 22 measurements of critical parameters (e.g., containment average temperatures for Tecliical 23 Specification requirements) are trended on an ongoing basis. Adverse changes must be addressed 24 on an ongoing basis also.
25 26 This concludes the summary description of the Oconee EQ program. The RAIs for Section 5.6 27 of Exhibit A of the Application follow.
28 29 DRAFT RAI Response Page 8 of 20 DRAFT RAI Response
DRAFT Response to Oconee RAIs for Section 5.6 of Exhibit A of the Application 1
RAI 5.6-1 (11-25-98A) 2 Sections 5.6.24 (Viking electrical penetration assemblies) and 5.6.26 (Rosemount RTDs) of the 3
application are based on option (i) of 10 CFR Part 54.21 (c)(1) to demonstrate that the analyses 4
remain valid for the period of extended operation.
5 6
To illustrate the basis upon which you have concluded that the existing analyses are valid for the 7
period of extended operation, provide calculation OM-360-24 for the Rosemount RTDs and the 8
calculation from OM-337.00-0080-001 for the Viking electrical penetrations.
9 10 In addition, provide summaries of the thermal and radiation analyses for the Rosemount RTDs.
11 12 13 Response to RAI 5.6-1 (11-25-98A) 14 Per clarification of this RAI with the staff, a summary description of the basis of the analyses for 15 Viking electrical penetrations and Rosemount RTDs is provided.
16 17 This equipment was originally reviewed under its original qualification as described in the EQ 18 program summary description under Original Qualification Basis.
19 20 Viking Electrical Penetrations 21 Section 5.6.24 of Exhibit A of the Application gives the thermal and radiation values contained 22 in the vendor qualification documentation and compares these values to the Viking electrical 23 penetration assembly service conditions. The basis of these values, including a description of the 24 process, analysis method, and any assumptions and boundary conditions, is given in this RAI 25 response.
26 27 As stated in Section 5.6.24 of Exhibit A of the Application, the thermal and radiation values 28 contained in the vendor qualification documentation are compared to the Viking electrical 29 penetration assembly service conditions. The vendor qualification is based on appropriate 30 considerations such as materials of construction, service environment, and testing. The vendor DRAFT' RAI Response Page 9 of 20 DRAFT RAI Response
DRAFT Response to Oconee RAIs for Section 5.6 of Exhibit A of the Application 1
qualification and documentation has been checked and meets all Oconee quality assurance 2
requirements.
3 4
The Viking penetrations were thermally aged at 3000F for 350 hours0.00405 days <br />0.0972 hours <br />5.787037e-4 weeks <br />1.33175e-4 months <br />. The following organic 5
materials were identified in the report:
6 7
- 1. Zytel 100 Nylon - Ae = 0.86 eV (EPRI/EQDB database) 8
- 2. E.P.R. Terpterpolymer rubber - Ae = 0.95 to 1.28 eV (EPRI Report NP-1558) 9
- 3. G-10 glass filled epoxy - Ae = 0.94 eV (EPRI/EQDB database) 10 11 Activation energies were researched and established per the references in parenthesis.
12 13 Using the lowest Ae, 0.86 eV, the thermal aging established a qualified life of 62.12 years at an 14 ambient temperature of 120 0F (48.90 C). Temperature measurements in the installed location of 15 the penetrations indicate an average ambient temperature of 1020F (48.90C). Therefore there is 16 significant conservatism in using 120'F (48.90C) as the ambient temperature for the qualified life 17 calculation.
18 19 Temperature rise of the penetration conductors is insignificant, as the conductor current limit, per 20 the test report, is 370 amps. The worst case loading for the Viking penetration is 135 amps 21 continuous for the Reactor Building Cooling Unit Fan Motors. This is only 36% of the 22 maximum current limit. The temperature rise in the conductor is approximately 70C. The 23 temperature rise is adequately addressed in the conservative ambient temperature of 120aF 24 (48.90 C).
25 26 The Viking electrical penetration service conditions also include consideration of radiation 27 exposure. The bounding Reactor Building 60-year total integrated dose used in the comparison 28 is obtained by multiplying the highest design radiation dose for areas where Viking electrical 29 penetration are installed (documented in the EQ criteria manual for a 40-year dose) by 1.5 to DRAFT RAI Response Page 10 of 20 DRAFT RAI Response
DRAFT Response to Oconee RAls for Section 5.6 of Exhibit A of the Application 1
obtain a bounding 60-year dose and adding the LOCA (accident) dose to the result. Design 2
radiation values are used and no additional radiation measurements were taken or calculated.
3 4
For the Viking penetrations, the 40 year normal dose is 3.0E7 rads. This equals 4.5E7 rads as the 5
60 year normal dose. Combined with an accident dose of 6. 1E7 rads equals a Total Integrated 6
Dose (TID) for 60 years of 1.06E8 rads. The penetrations were tested and qualified to 1.2E8 7
rads.
8 9
The process and data used in the comparison of vendor qualification documentation to the Viking 10 electrical penetration assembly service conditions is in accordance with regulatory and industry 11 standards and provides adequate basis upon which to conclude that the existing analysis is valid 12 for the period of extended operation.
13 14 Rosemount RTDs 15 Section 5.6.26 of Exhibit A of the Application states that all installed Rosemount RTDs have no 16 organic materials as the reason why the existing analysis remains valid for the extended period of 17 operation. The response to this RAI for Rosemount RTDs provides the basis for this conclusion 18 based on information contained in the vendor qualification documentation. A Summary of the 19 radiation analyses for the Rosemount RTDs is also provided.
20 21 The Rosemount RTDs are constructed of materials, primarily metal, glass and ceramics, for use 22 at process temperatures up to 700'F and for environments up to 140'F. The materials that will 23 degrade with temperature are located in the connection head. The most sensitive material to 24 thermal degradation is the connection head o-ring. The installed configuration does not utilize 25 the connection head supplied by Rosemount. The supplied connection box is removed and a 26 termination box is mounted on the RTD. Raychem splices are installed in the box and the box is 27 filled with Scotchcast 9 epoxy to cover the splices. This configuration provides both a seal at the 28 RTD/termination box junction and protects the splices.
29 DRAFT RAI Response Page 11 of 20 DRAFT RAI Response
DRAFT Response to Oconee RAls for Section 5.6 of Exhibit A of the Application 1
The 60-year total integrated dose is obtained by multiplying the highest design radiation dose for 2
areas where Rosemount RTDs are installed (documented in the EQ criteria manual for a 40-year 3
dose) by 1.5 to obtain a bounding 60-year dose and adding the LOCA (accident) dose to the 4
result.
5 6
The 40 year normal dose is 3.0E7 rads. This equals 4.5E7 rads as the 60 year normal dose.
7 Combined with an accident dose of 6. 1E7 rads equals a total integrated dose for 60 years of 8
1.06E8 rads. The Rosemount RTDs are qualified to 3.8E8 rads.
9 10 The vendor qualification envelopes the bounding 60-year Rosemount RTD service conditions 11 indicating that the existing Rosemount RTDs qualification analysis remains valid for the period 12 of extended operation. The vendor qualification is based on appropriate considerations such as 13 materials of construction, service environment, and testing. The vendor qualification and 14 documentation has been checked and meets all Oconee quality assurance requirements.
15 16 The Rosemount RTDs radiation dose used in the comparison is bounding Reactor Building 17 60-year total integrated dose. Design radiation values are used and no additional radiation 18 measurements were taken or calculated.
19 20 The process and data used in the comparison of vendor qualification documentation to the 21 Rosemount RTDs service conditions is in accordance with regulatory and industry standards and 22 provides adequate basis upon which to conclude that the existing analysis is valid for the period 23 of extended operation.
24 25 26 RAI 5.6-2 (11-25-98A) 27 Sections 5.6.2 (Limitorque actuators), 5.6.10 (Okonite EPR/neoprene cables), 5.6.11 (Samuel 28 Moore EPDM/Hypalon cables), 5.6.12 (Scotchcast 9 and Swagelok quick-disconnect 29 assemblies), 5.6.23 (D.G. O'Brien penetrations), 5.6.32 (Barton 764 transmitters) are based on DRAFT RAI Response Page 12 of 20 DRAFT RAI Response
DRAFT Response to Oconee RAls for Section 5.6 of Exhibit A of the Application 1
option (ii) of 10 CFR Part 54.21 (c)(1) to demonstrate that the analyses have been projected to 2
the end of the period of extended operation.
3 4
To illustrate the basis upon which you extended the analyses for the period of extended 5
operation, provide the calculations that document the qualified life for the above items as follows 6
7
- a. Limitorque Actuators - Calculation OSC -7167 8
- b. Okonite EPRINeoprene Cables - Calculation OSC - 6530 9
- c. Samuel Moore EPDM/Hypalon cables - Calculation OSC - 7055 10
- d. Scotchcast 9/Swagelok Assemblies - Calculation OSC 7095 11
- e. D.G. O'Brien penetrations - Calculation OSC - 7153 12
- f. Barton 764 transmitters - Calculation OSC - 7096 13 14 15 Response to RAI 5.6-2 (11-25-98A) 16 Per clarification of this RAI with the staff, a summary description of the basis of the analyses for 17 two of the listed equipment types is provided to illustrate the process. The analysis for other 18 equipment was performed in a similar manner.
19 20 The method of reanalysis is described under the EQ program summary description section 21 Reanalyze the qualified life calculation.
22 23 Limitorque Actuators (Motor Operated Valves, MOVs) 24 Section 5.6.2 of Exhibit A of the Application compared the vendor thermal and radiation 25 qualification values to the Limitorque MOV service conditions. The basis of these values, 26 including a description of the process, analysis method, and any assumptions and boundary 27 conditions, is given in this RAI response. The vendor qualification is based on appropriate 28 considerations such as materials of construction, service environment, and testing. The vendor DRAFT RAI Response Page 13 of 20 DRAFT RAI Response
DRAFT Response to Oconee RAls for Section 5.6 of Exhibit A of the Application 1
qualification and documentation has been checked and meets all Oconee quality assurance 2
requirements.
3 4
Limitorque qualified their MOVs for inside containment and outside containment applications 5
with the basic difference being motor insulation class; Classes H, RH and LR for inside 6
containment and Class B for outside containment.
7 8
Inside containment Limitorque MOVs were thermally aged under several Limitorque 9
qualification tests. Under these tests, MOVs were aged at 180 0C (356 0F) for 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />. This is 10 equivalent 135 years at a 140 0F (60 0C) average temperature. The establishment of the aging 11 parameters was based on the Class RH motor insulation system which has an activation energy 12 (1.02 eV) lower than or equal to the activation energy for all other materials in the inside 13 containment Limitorque MOVs. The worst case measured inside containment average ambient 14 temperature is 136oF (57.78 0C). Since the worst case inside containment ambient temperature is 15 less than 600C, the inside containment MOV 60 year life is established. The ambient 16 temperature used in the comparison is the yearly average ambient temperature which was 17 obtained from actual temperature readings in the hottest areas inside containment where 18 Limitorque MOVs are installed.
19 20 Outside containment Limitorque MOVs were thermally aged at 165 0C (3290 F) for 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br />.
21 Based on the Class B motor insulation system which has an activation energy lower than or equal 22 to the activation energy for all.other materials in the outside containment Limitorque MOVs (.93 23 eV), an equivalent age of 60 years at a 138 0F (58.9 0C) average temperature was established.
24 Since the worst case outside containment ambient temperature is 122*F (500C), the outside 25 containment MOV 60 year life is established. The ambient temperature used in the comparison is 26 the bounding design temperature for the areas where outside containment Limitorque MOVs are 27 installed. Design temperatures (documented in the EQ criteria manual) are used and no additional 28 measurements were taken or calculated.
29 DRAFT RAI Response Page 14 of 20 DRAFT RAI Response
~&-A DRAFT Response to Oconee RAls for Section 5.6 of Exhibit A of the Application 1
The Arrhenius method was used to determine the equivalent aging for both the inside and outside 2
containment Limitorque MOVs. Choosing the lowest activation energy yields conservative 3
results for all other materials with a higher activation energy.
4 5
The bounding Reactor Building 60-year total integrated dose used in the comparison for inside 6
containment and outside containment was obtained by multiplying the highest design radiation 7
dose for areas where Limitorque MOVs are installed (documented in the EQ criteria manual for 8
a 40-year dose) by 1.5 to obtain a bounding 60-year dose and adding the LOCA (accident) dose 9
to the result. Design radiation values are used and no additional radiation measurements were 10 taken or calculated.
11 12 The worst case Reactor Building 40 year radiation dose is 3.0E7 rads. For 60 years the dose 13 equals 4.5E7 rads. The worst case LOCA dose is 6.1E7 rads. The Total Integrated Dose (60 year 14 normal dose plus.accident dose) is 1.06E8 rads. The Limitorque MOVs were tested and qualified 15 to 2.04E8 rads.
16 17 The worst case outside containment 40 year radiation dose is 1.0E6 rads. For 60 years the dose 18 equals 1.5E6 rads. The worst case LOCA dose outside containment is 6.0E6 rads. The Total 19 Integrated dose (60 year normal dose plus accident dose) is 7.5E6 rads. The Limitorque MOVs 20 were tested and qualified to 2.0E7 rads.
21 22 The process and data used in the comparison of vendor qualification documentation to the 23 Limitorque MOV service conditions is in accordance with regulatory and industry standards and 24 provides adequate basis upon which to conclude that the existing analysis is valid for the period 25 of extended operation.
26 27 Okonite EPR/Neoprene Cables 28 Section 5.6.10 of Exhibit A of the Application compared the vendor thermal and radiation 29 qualification values to the Okonite EPR/neoprene cable service conditions. The basis of these 30 values, including a description of the process, analysis method, and any assumptions and DRAFT RAI Response Page 15 of 20 DRAFT RAI Response
DRAFT Response to Oconee RAIs for Section 5.6 of Exhibit A of the Application 1
boundary conditions, is given in this RAI response. The vendor qualification is based on 2
appropriate considerations such as materials of construction, service environment, and testing.
3 The vendor qualification and documentation has been checked and meets all Oconee quality 4
assurance requirements.
5 6
Okonite EPR/neoprene cables are used in EQ applications of actuators, motors, switches and 7
solenoid valves. The worst case application (maximum application current is the largest percent 8
of cable rated current) of Okonite EPR/neoprene cable was determined to be the Reactor 9
Building cooling unit (RBCU) fan motors.
10 11 Okonite constructed actual jacketed cable samples and aged the samples at 3 different times and 12 temperatures: 150 0C for 2500 hours0.0289 days <br />0.694 hours <br />0.00413 weeks <br />9.5125e-4 months <br />, 165 0C for 960 hours0.0111 days <br />0.267 hours <br />0.00159 weeks <br />3.6528e-4 months <br />, 180 0C for 360 hours0.00417 days <br />0.1 hours <br />5.952381e-4 weeks <br />1.3698e-4 months <br />. After aging, the 13 samples were tested for retention of elongation. All samples retained greater than 40%
14 elongation (established by Okonite as the end of life) thus demonstrating a 40 year life at 194oF 15 (90aC).
16 17 The 194 0F (900C) rating is a combination of heat rise in the conductors and ambient temperature.
18 Assuming that the RBCU fan motors operate continuously at full load (135 amps) and assuming 19 a 1220F (500C) ambient temperature, the temperature of the conductor due to ambient and self 20 heating temperature rise was calculated to be 157.90F (69.930 C). The assumed ambient 21 temperature of 122oF (500C) is a significant conservatism included in the analysis. Temperature 22 measurements indicate that the average ambient temperature at the elevation where the RBCUs 23 are located is about 1000F (37.8 0C). Plotting 157.90F (69.930 C) on the 40% retention of 24 elongation graph establishes a qualified life in excess of 60 years with at greater than 40%
25 elongation.
26 27 The bounding Reactor Building 60-year total integrated dose used in the comparison for inside 28 containment and outside containment was obtained by multiplying the highest design radiation 29 dose for areas where Okonite EPR/neoprene cables are installed (documented in the EQ criteria DRAFT RAI Response Page 16 of 20 DRAFT RAI Response
DRAFT Response to Oconee RAIs for Section 5.6 of Exhibit A of the Application 1
manual for a 40-year dose) by 1.5 to obtain a bounding 60-year dose and adding the LOCA 2
(accident) dose to the result. Design radiation values are used and no additional radiation 3
measurements were taken or calculated.
4 5
The worst case Reactor Building 40-year radiation dose is 3.0E7 rads; equals 4.5E7 rads for the 6
60-year dose. The worst case LOCA dose is 6. 1E7 rads. The total integrated dose (60-year 7
normal dose plus accident dose) is 1.06E8 rads. The Okonite EPR/neoprene cables were tested 8
and qualified to 2.0E8 rads.
9 10 The process and data used in the comparison of vendor qualification documentation to the 11 Okonite EPR/neoprene cable service conditions is in accordance with regulatory and industry 12 standards and provides adequate basis upon which to conclude that the existing analysis is valid 13 for the period of extended operation.
14 15 RAI 5.6-3 (11-25-98A) 16 The following sections in the application are based on option (iii) of 10 CFR Part 54.21 (c)(1) to 17 demonstrate that the effects of aging on the intended function(s) will be adequately managed for 18 the period of extended operation:
19 20 5.6.3.
Rotork Actuators 21 5.6.16 EGS Grayboots 22 5.6.17 EGS Connectors 23 5.6.18 Joy/Reliance Motors 24 5.6.19 Louis - Allis Motors 25 5.6.20 Reliance Motors 26 5.6.21.1 Westinghouse BS pump motors 27 5.6.25 Conax RTDs 28 5.6.27 Weed RTDs 29 5.6.28 Valcor Solenoid valves 30 5.6.29 Barton/Westinghouse switches DRAFT RAI Response Page 17 of 20 DRAFT RAI Response
DRAFT Response to Oconee RAls for Section 5.6 of Exhibit A of the Application 1
5.6.31 Gems Delaval transmitters 2
5.6.33 Rosemount transmitters 3
4 For each of the above items, provide the following information for the option chosen:
5 6
Replacement - Describe the activities for replacement [of] equipment qualified to 10 CFR 50.49 7
and any sound reasons to the contrary (Regulatory Guide 1.89, Rev. 1) that will be used for 8
replacement equipment.
9 10 Refurbishment - Describe the activities that will result in the equipment being returned to its 11 original (like new) qualified condition.
12 13 On going Qualification/Retesting -Describe the ongoing qualification test program in accordance 14 with IEEE Std. 323-1974, that is being used.
15 16 Reanalysis - Provide the analytical methods, data collection and reduction methods, underlying 17 assumptions, acceptance criteria, corrective actions if the acceptance criteria are not met, and the 18 period of time prior to the end of qualified life when reanalysis will be completed.
19 20 21 Response to RAI 5.6-3 (11-25-98A) 22 As an introduction to responding to this RAI, additional information is given regarding the 23 TLAAs related to the equipment listed in this RAI. The use of TLAA demonstration option (iii) 24 for the TLAAs associated with the listed equipment fall into the two categories which are 25 described below:
26 27
- 1. The Rotork Actuators, Joy/Reliance Motors, Louis-Allis Motors, Westinghouse BS pump 28 motors, Gems Delaval transmitters and Rosemount transmitters are original plant equipment 29 that have a 40-year qualified life. There are no current plans to reanalyze and extend the DRAFT RAI Response Page 18 of 20 DRAFT RAI Response
DRAFT Response to Oconee RAIs for Section 5.6 of Exhibit A of the Application 1
qualification lives of this equipment. This means this equipment will be replaced at some 2
time before their qualified life expires in accordance with the Oconee EQ program.
3
Solenoid valves and Barton/Westinghouse switches are not original plant equipment and are 5
replacements for equipment removed from service in the years 1986 through 1994. These 6
replacements all have 40-year qualified lives so the qualifications of this equipment expires 7
in the years 2026 through 2034. The Oconee extended operating licenses will expire in the 8
years 2033 (Units 1 and 2) and 2034 (Unit 3). The earliest of these equipment qualified lives 9
expires 7 to 8 years before the end of the extended period of operation. This means this 10 equipment will be replaced in accordance with the Oconee EQ program at some time before 11 their qualified life expires unless Oconee performs a reanalysis that extends the life.
12 13 In both of these categories, the EQ program and its associated site administrative controls will 14 ensure that qualified equipment performs the required intended functions for the life of the plant.
15 It is premature at this time to specifically identify all of the activities that will take place with 16 regards to these specific EQ components. The descriptions below, in conjunction with the EQ 17 process described earlier, provides information on how the current EQ program deals with each 18 of the activities.
19 20 Replacement 21 Replacement is the default action for the EQ equipment as the end of its qualified life 22 approaches. The equipment listed in this RAI is scheduled for replacement prior to the end of its 23 qualified life. Replacement of EQ equipment at Oconee is described in more detail in the Oconee 24 EQ program summary description under section Replacement of EQ Equipment.
25 26 Refurbishment 27 Of the specific equipment listed in this RAI, only Valcor Solenoid Valves are currently 28 refurbished. Refurbishment of EQ equipment at Oconee is described in more detail in the 29 Oconee EQ program summary description under section Refurbishment of EQ Equipment.
DRAFT RAI Response Page 19 of 20 DRAFT RAI Response
DRAFT Response to Oconee RAls for Section 5.6 of Exhibit A of the Application 1
2 On-going Qualification/Retesting 3
On-going qualification or retesting as described in IEEE Std. 323-1974, Section 6.6(1) or (2) is 4
not currently considered a viable option at Oconee and there are no plans to implement such an 5
option. If this becomes a viable option in the future, on-going qualification or retesting would be 6
incorporated into station directives administering the EQ program and the associated activities 7
would be performed in accordance with accepted industry and regulatory standards.
8 9
Reanalysis 10 Reanalysis of the qualified life calculation is described in more detail in the Oconee EQ program 11 summary description Reanalyze the qualified life calculation. The analytical methods, data 12 collection and reduction methods, and underlying assumptions for reanalyzing an equipment 13 qualified are described there or are embodied in the industry guidance outlined in EPRI TR 14 104873, Methodologies And Processes To Optimize Environmental Qualification Replacement 15 Intervals. There is no set period of time prior to the end of an equipment qualified life when 16 reanalysis will be completed. Reanalysis may be performed (as in the case of the equipment 17 reviewed for §54.21(c)(1)(ii)) ten or more years prior to expiration of the qualified life. It is 18 premature to define specific future times or even if reanalysis will ever be performed for the 19 equipment identified in this RAI.
20 21 Acceptance criteria associated with the reanalysis of a qualified life is the documented 22 confirmation that the equipment is qualified for some period beyond the previously existing 23 qualified life. Corrective action is not applicable to reanalysis of a qualified life calculation. If 24 the equipment qualified life can not be extended, the equipment will be replaced as currently 25 scheduled prior to the expiration of it existing qualified life.