ML20096B820
| ML20096B820 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 08/31/1984 |
| From: | Prunty R, Yandow P CAROLINA POWER & LIGHT CO. |
| To: | |
| Shared Package | |
| ML20096B797 | List: |
| References | |
| OL, NUDOCS 8409040364 | |
| Download: ML20096B820 (18) | |
Text
{{#Wiki_filter:p -
]
~ \
attfdED CG L'C' August 31,-1984 UNITED STATES OF AMERICA 00CKETE0~ NUCLEAR REGULATORY' COMMISSION US"PC Before the Atomic Safety and Licensing IS$aff? -4 Ali i5 In the Matter of )
)
CAROLINA' POWER & LIGHT' COMPANY -) Docket No. 50-400~OL and NORTH CAROLINA EASTERN ') MUNICIPAL POWER AGENCY )
)
(Shearon Harris Nuclear Power ) Plant) ) APPLICANTS' TESTIMONY OF ROBERT W. PRUNTY AND PETER M. YANDOW IN RESPONSE TO EDDLEMAN CONTENTION 9B (LIMITORQUE VALVE OPERATORS)
~
8409040364 B40831 .,
.PDR.ADOCM 05000400 T PDR
_ _ a
e
.$ _ 1 I
Q.1= Please state your names. A.1 Robert W. Prunty and Peter M. Yandow.
-Q.2 Mr. Prunty and Mr. Yandow, are your addresses, occu-pations, employers, educational backgrounde and professional work experiences described elsewhere in the record of this pro-ceeding?
A.2 (RWP, PMY) Yes, the relevant information is provided in " Applicants' Testimony of Robert W. Prunty and Peter M. Yandow in Response to Eddleman Contention 9 (Environmental Qualification of Electrical Equipment)." Q.3 What is the purpose of this testimony? A.3 (RWP, PMY) The purpose of this testimony is to re-spond to Eddleman Contention 9B, whien' states: There is not sufficient assurance that the concerns with Limitorque valve operators identi-fled in IE Information Notice 83-72 (except for Items C2, C5 and C7) have been adequately addressed. Q.4 How is your testimony organized? A.4 (RWP, PMY) First, we provide background information on Limitorque valve operators, including a description of a valve operator and an explanation of the safety functions per-formed by Limitorque valve operators at SHNPP. Second, we sum-marize the concerns relating to Limitorque valve operators containcd in IE Information Notice 83-72, and describe general-ly CP&L's field verification program to address those concerns referenced in Eddleman Contention 9B. Third, we discuss in turn each of the following concerns about Limitorque valve 9 O
.2, operators? reference'd in Eddleman Contention 9B: (1) qualifica-tion and-rating of terminal blocks, (2) qualification of motor insulation material,-(3) installation orientation,-(4) instal-lation of drain plugs, (5) lack of agreement ~between purchase
-order and qualification files and installed components, an'd (6)
~
- qualification of'O-rings. With respect to each of these con-cerns, we describe the concern and the actions CP&L is taking-
- to resolve it.
Q.5 Mr. Yandow,'what'is a valve operator? A.5 .(PMY) A valve operator (or actuator) is a component of a valve.which causes it to open or close. Limitorque valve operators contain electrical motors which, through a series of mechanical gears, cause the valve to change position. Examples of types of valves which use Limitorque operators at SENPP are globe valves, butterfly valves and gate valves. A typical gate valve with a Limitorque operator is shown in Figure 1 (attached hereto). Figure 2 (attached hereto) provides a'more detailed picture of a Limitorque operator. Q.6 Are Limitorque valve operators used at SHNPP? A.6 (PMY) .Limitorque valve operators are used on a num-ber of valves which perform safety-related functions at SENPP.
' Those functions include: isolation of the reactor containment,
' isolation of the reactor coolant system pressure boundary, operation of the emergency core cooling system, and operation of emergency safeguard systems. Limitorque valve operators are found in various locations in the reactor containment and the reactor auxiliary building.
~
0
f. Q.7 How did CP&L become aware of the concerns about Lim-itorque valve operators reported in IE Information Notice 83-72? A.7 (RWP) CP&L, as the holder ofta construction permit for SHNPP, receives IE Information Notices issued by the NRC. IE Information Notice 83-72 was received by DP&L's Nuclear Li-censing Department and was distributed to the Harris Plant En-gineering Section ("HPES") for evaluation. Q.8 What were the results of CP&L's evaluation of the con-cerns raised in IE Information Notice 83-72? A.8,(PMY) Equipment Environmental ~Qua'lification Notice No. 24 of IE Information Notice 83-72 (October 28, 1983) pro-vides information on deficiencies related to Limitorque valve operators at Consumer Power Company's Midland Plant, Units 1 and 2 (" Midland"). These deficiencies were construction deficiencies reported to the NRC Staff pursuant to 10 C.F.R. S 50.55(e) by The Bechtel Associates Professional Corporation ("Bechtel"), the Architect / Engineer for Midland. After reviewing the Information Notice, CP&L contacted the Limitorque Corporation ("Limitorque") for additional informa-tion in order to determine possible applicability of the Infor-mation Notice to SHNPP. Limitorque in its written response stated that, with one possible exception, all of the deficiencies found at Midland were plant specific. Most of the Midland ~ specific deficiencies were the result of lack of infor-mation concerning qualification of the operators on the part of
- j l - _ d
[?;. .
. I Midland personnel,'rather than hardware deficiencies. The' l
other Midland specific deficiency was a field related problem.
'The only deficiency which possibly was not' limited to Midland was the use of unqualified terminal blocks in some operators supplied to Westinghouse. However, Limitorque indicated that Westinghouse had undertaken to identify and ' replace all unqual-ified terminal blocks. Therefore, Limitorque did not recommend that any corrective action be taken by CP&L as.a result of IE Information Notice 83-72.
Nevertheless, CP&L is in the process of implementing a field varification program for the 16 active, safety-related valves with Limitorque operators located inside containment at SHNPP. The inspections will be conducted by equipment qualifi-
. cation personnel. The field verification program will provide additional assurance that unqualified terminal blocks, and each of the other concerns raised in Eddleman Contention 9B, have been adequately addressed for SHNPP. The results of the field verification program, and CP&L's evaluation of the those re-sults, will be documented in the environmental qualification packages for the valves of concern.
Q.9 Please describe the concerns at Midland relating to Limitorque terminal blocks. A.9 (PMY) Items A, B and C9 of IE Information Notice 83-72 were all deficiencies at Midland relating to Limitorque terminal blocks. Item A concerns underrated terminal blocks. While replacing a damaged terminal block on a Limitorque G '
. :. O
e operator,'Bechtel discovered that some of the terminal blocks used for the termination of the leads from the 460-volt motor were rated'less than 460 volts. The underrated terminal blocks could have prevented the valves from performing their safety function, and also posed a safety hazard to plant personnel. According.to Limitorque, Bechtel in 1979 had re-quested that Limitorque replace the terminal blocks in a cer-tain group of operators for the purpose of providing additional terminal points. When the Limitorque field service representa-tive ran out of factory supplied terminal blocks, he obtained additional' terminal blocks locally. These terminal blocks were 1 i not rated for 460 volt service. Following identification of the error, Limitorque inspected all the operators whose termi-nal blocks had been replaced, and replaced those that were un-derrated with terminal blocks rated for 460 volts. To confirm that the underrated terminal blocks were limited to this par-ticular group of operators, Limitorque inspected a random sam-ple of its other operators at Midland and found no other in-I stances of underrated terminal blocks. Item C9 of IE Information Notice 83-72 involved Mid-land personnel's inability to identify terminal blocks in the i low voltage control circuits of Limitorque operators. Lim-itorque conducted a random inspection of its operators at Mid-land and found all control terminal blocks inspected to be identifiable and suitable for their application. Limitorque then instructed Midland personnel on how to identify the terminal blocks by using vendor supplied catalog data sheets. t
d I l
+-
-Item-B of IE Information Notice 83-72 was a deficien-cy at Midland' involving the use of unqualified terminal blocks in some'Limitorque operators. The terminal blocks in question were Buchanan G824 nylon terminal blocks, which have never been type tested. In addition, tests have shown that nylon experi-ences 25 percent degradation at a radiation dose of 4.7 x 10E6 rads. Some Limitorque operators at SENPP are located in areas that could receive a total integrated dose of greater than 4.7 x 10E6 rads. Limitorque has stated that Buchanan 0824 terminal blocks were used exclusively on operators provided to Westinghouse. Westinghouse has supplied valves with Limitorque operators to SENPP. However, Westinghouse has notified CP&L that none of those operators has Buchanan 0824 terminal blocks.
Q.10 Is CP&L taking any' action to address terminal blocks in Limitorque operators? A.lO (PMY) As discussed above, CP&L has developed and is in the process of implementing a field verification program for Limitorque valve operators. Active,-safety-related Limitorque valve operators located inside containment at SHNPP will be in-spected. Limitorque has provided CP&L with the particular.di-mensions of the types of terminal blocks which were tested with the valve operators supplied to SENPP. Those terminal blocks include Buchanan types 0524 and 0222, Marathon types 300 and i 1600, Curtis type L, and General Electric type EB-5. Field l verification of the terminal blocks consists of measuring the l l 1 O
p ' ~ idimensions of the power and nonpower lead terminal blocks,
-including the point-to-point distances of the terminal screws, and comparing.these measurements with the vendor supplied information. (See, for example,. Figures 3 and 4, attached hereto.) To date, all terminal blocks inspected have been en-
. vironmentally qualified. Any unqualified terminal blocks found-
.will be: replaced with qualified terminal blocks.
Q.11 Please describe the concern at Midland involving Lim-itorque motor' insulation material. A.11 (PMY) Item Cl of IE Information Notice 83-72 con-cerns identification by Bechtel of Class H insulated motors in-side the containment at Midland, for which the motor nameplate ambient temperature. rating was 50 C. Bechtel stated that it was not aware that Class H insulated motors had been type test-ed and found environmentally qualified for inside containment in accordance with the applicable IEEE standard. Limitorque has explained that prior to the adoption of the Class RH nomenclature for motors whose insulation mate-rial is qualified for inside containment, motors of this design characteristically were nameplated as Class H. However, Lim-itorque must review its records on each Class H insulated motor to confirm.that the motor is constructed with a Class RH insu-lation system. The results of Limitorque's review for Midland Class H motors located inside containment showed that all the motors were properly qualified. 9 L____._-__._.____
^
1 F. -
.Q.12 What action is CP&L taking to address Limitorque motor insulation material?
'A.12.(PMY) CP&L requested Limitorque to conduct a review of its: records on valve operators located inside containment at SENPP. Limitorque's review indicated that the valve operator.
motors-for SHNPP have qualified insulation. In addition, CP&L is checking Limitorque motor rat-ings on the nameplates as part of its field verification pro-gram. Serial numbers for any motors indicating Class H insula-tion will be provided to Limitorque in order that Limitorque can confirm that RH insulation was used. To date, all motor insulation material has been identified to be RH. Any valve operator motor found to be unqualified for inside containment will be replaced with a qualified motor. Q.13 Please describe the concern relating to installation orientation of Limitorque valve operators at Midland. A.13 (PMY) Item C3 of IE Information Notice 83-72 was based on Bechtel's observation of Limitorque operators in-stalled in various orientations at Midland. Bechtel did not know whether the operators were qualified for all' installation orientations. Limitorque Qualification Report B-0058 provides rec-ommendations for installing Limitorque valve operators. Lim-itorque recommends against mounting the operator in a position where either the motor or the limit switch compartment is di-rectly beneath the gear case. There is a remote possibility _g. 4
b,3 that a random seal failure could occur, resulting in lubricant
-leaking into the electr'ical enclosures and possibly impairing the operability of the equipment.
Q.'14 What. action is CP&L taking to address installation
-. orientation of Limitorque valve operators?
A'.14 (PMY) CP&L and its Architect / Engineer follow
- specified procedures to assure proper installation orientation of safety-related electrical equipment, including Limitorque valve operators.
CP&L's field ~ verification program for Limitorque valve operators also includes a check of installation orienta-tion. So far, no deviations from Limitorque's recommended ori-entations have been identified. Orientation of any valve oper-ators installed incorrectly will be modified to conform to Limitorque's recommendations. Q.15 Please describe the concern relating to installation of drain plugs in Limitorque valve operators at Midland. A.15 (PMY) Item C4 includes two-related concerns having to do with proper drainage of the valve operator motors. The first was that motor drain plugs (T-drains) were not always in place. The second was that orientation of the operators did not always result in the drain holes being at the lowest point of the operator as installed. Bechtel did not know whether ei-ther of these facts was relevant to the environmental qualifi-cation of the operators. I m
r7 V ,, 7 Limitorque has informed CP&L that valve operators qualified for.inside containment require the installation of ,- motor: drain plugs inLorder to prevent possible moisture buildup in the motor. The drain plugs must be installed in the two
~ lowest drain plug locations. These locations will vary de-
_pending on the installation orientation, as ' determined by SHNPP installation design drawings. Therefore, the drain plugs are placed in the limit switch compartment, with installation in-structions, at time of shipment of the operators by Limitorque. Q.16 What action is-CP&L taking to address installation of motor drain plugs? A.16 (PMY) Installation orientation of Limitorque valve operators is addressed above with respect to Item C3. To ensure the proper documentation and inspection of the drain plugs, CP&L HPES has specifically instructed con-struction personnel via a site design document to install the drain plugs. The design document is now part of the work package used to install the equipment. A special note also has been added to the installation design drawing used along with the work package by construction personnel. This note directs the person installing the drain plugs to install them at the lowest oriented points in the motor. Proper installation of the drain plugs will be independently verified in the field by the on-site quality inspection organization. In addition, proper installation will be checked as part of the field veri-fication program for Limitorque valve operators.
b.) . e Q.17_Maat was the concern at Midland relating to purchase order and' qualification files agreeing with installed compo-nents, and what action is CP&L taking to address it? A.17 (PMY) Item C6 of IE Information Notice 83-72 simply states that "(ijnformationLobtained from purchase order files and qualification files does not agree with 'the installed com-ponents." As part of the procurement process for safety-related electrical equipment at SHNPP, the design engineering organiza-tions at Ebasco and CP&L review the equipment qualification documentation against the requirements contained in the pur- , 1 chase order and specifications for the equipment in order to l 1 determine compliance with those requirements. The equipment itself is inspected: (1) prior to shipment, (2) upon receipt at the site, and (3) after installation, in order to verify that the equipment agrees with the purchase order, specifications and other design documents. CP&L's field verification program for Limitorque valve operators will provide additional assurance that the in-stalled valve operators are identical to those which have been environmentally qualified for SHNPP, as documented in the pur-chase orders and environmental qualification packages. Q.18 Please describe the concern regarding qualification of O-rings. A.18 (PMY) Item C8 of IE Information Notice 83-72 ques-tions the qualification of 0-rings used in the Limitorque valve operators at Midland. e n
4- 1 1 I The vendor test reports which describe qualification
! testing o'f Limitorque valve operators, both for inside and out-side containment, identify 0-rings as components included in the tests. rings thus are qualified as an integral part of the_ equipment.
Limitorque's. valve operator assembiy= control system, as described to CP&L by Limitorque, assures that.the proper 0-rings are used in the assembly of each type of valve opera-tor. All components for an operator being assembled are col-
~
lected in one assembly area. Each component is inspected to affirm that it is the correct type. O-rings are marked by Lim-itorque with a color code, which facilitates proper identifica-tion. Q.19 What action is CP&L taking to address qualification of O-rings? A.19 (PMY) For the reasons stated above, CP&L does not believe that Item 8 of IE Information Notice 83-72 raises a potential concern for SHNPP. Further, 0-rings cannot be iden-tified without disassembling the operator. However, if the field verification program identifies any components of an op-erator for which qualification appears questionable, the opera-tor will be disassembled and all questionable components of the operator, including any unidentifiable O-rings, will be re-placed. Q.20 In conclusion, is there reasonable assurance that the above concerns with Limitorque valve operators identified in IE 4 k.
[5,;. ,- ) t P'__ *i
- Information Notice.83-72.have'-been adequately addressed by the i
environmental' qualification program for~SHNPP? 1
-A.20)(RWP,:PMY)_Yes.
~.
j ;' f t - i 4 i e 9 r- ';
.m . .- , __
b
\1
,....r~~~~~~
~'
~
- I (J/ // LJ
. ,y ,e'w'V i 19 1 8
l - 1.ll.g t i - lli l f5Ig l-
'g - j8 :1 t gi u liit fi!.!si ! 9 mili!mai l li,l
.,gg nj b
i i g . - -
, , .1 sti,Is;istat ice ,I p ! -
v! ! l I !,lA!a!!!!1!;a!!I!!!!I !1!,1 i ! !!!! ! I l aka! s s>> > . . no
..!<xs'.:jp<M < <
w a ss u p y yia.p' - - - 1 - D: q g)'~'
' ~
d7 ?h ? 5 t
~I f! !! I .'
i s I *3 I I'r s ti !!! ! si lpr i i E 1<,d-+ f.; -f x g .<
- 3 55 85 !' ; L
[.l E h :: :
- } s , l<9ie r r i.
e , r j +-
?
~
l g . q:. gm.!g jrjg l.a g
. .i il l, Iu' rr gs ge 1p- 8 s g, I h !!
h - h!E !y I! ! ! !h j N! !h! q .......W,;...il!'!il gg!!'i pl;jj! l ;, .3 3
. ~ . .. . . . . . . . .
.j. ~ . .
. i iji.iiii dI j
- :,: :: g'j;=i' ; jp'
. . - .. v g r s jl 19 1 : I5 ; i : i: " Is a a s t iitt i'.s g g!:, j i<h L
, e 'p lIs# l e j d! !
- p-s,g -
a..
/ll;1:
i
- - ;.i iiii$l!i gig i
~-
J b ' ppg ,' T i ,
. m. r_ fi j .
1 ,
. ,= ,
E-
,f h' I ut-1, < I I 5 ,
$s.2 mz ; il M g [
,' d_)s I i i
- }4.- ~
- a- p ., /
f
- m fr. /
ji
. ~ in i ~
~
[N c i 6 3 1: Eiil ~ ",,/ "2 - o c u. gg 9 5 a (NMr1 i ts e: 7* m\ - t )
' \
f-
- 4,,
\ .y.?. p_ .! y}W] n.gw .
p e^ s 43 p, 4e ll
,! i l- .
\v 1 3f a
/ ,
KI, '
"a6;;:eisilaoeI$! .
L eu '
/ l
-)
;'s;s.,
\
ff
%>d .' -
x
- 2
,,+x ~ y <
!x s ,,
- .D y,ll>*. ~-.
.o I
e ',, . 7[ ,
/
'N A
/
I 4 6 k
. Figure 3 RufA44NA" O Dim:nxirn3%
FLAT BASE J c 3
// i t1_ t1_d_ 1/~~ -
G Accessories / 0.63,,,,,,,,/h ,,, -,,,-,, ,- ( Vinyt Martung Stnp ' CcM = .437 + (N x .437) Use #65 fop 9 25 ft. Lcw = C55 + (N x 437) plug Cal 50 ] 7:7 rl7 T,T f N = Number of Circuits
- 0.44 Elevated - 0.33 Ek ' 9 '"~ '
Eg g: 5, @ g Nylon Holding Plug 1.05 r , ,, , IM 65
" 0.13 For marneg y[,) plugs stne fr 7 7 7 11 I i i i S Marking Pen 12 99 1.13 j O pens L
.c Q.
DOVETAIL B ASE MOUNTED ON STANDARD #60 CHANNEL CCM
-{
.L,J, .L p. I m 'O'-- 'C,J, C_ e{:: Mount with #10 h ' '
f
. ., u '
(, ,- g if7 (7')TT'T h::
\
g g CcM = 2.155 - (N 437) LCM = 2 905 * (N x 437) N = Numcer of Circuits f h033 -! 0.44 f- ! O 38 f 0 33
-l
~
g:g: : 53 %'TOS'" @
"Ja "s'i rW ,3
\
T7 7 7 If N
^ . N LCM -
1.19 l g j' SECTIONAL FANNING STRIPS OO l 1.16 1.05 L )
)
g' O.38 n .~ 1 l l 1.19 1 94 y
~
Scale 1:1 e 1 m
. Figure 4 hwa BULLETIN MA5NErHON O specialproducts DIMENSIONS: 300 Series
-wh* *d*
l 6 DIA. 8 8-32 xf6'N & h B D. H D. 5 CREW h- -- {
> e '
@ .Q G &._st-i*
. Q I a l
- -: B =
wh
- I c A = +
h+ ' DIAGRAM DIMENSIONS OlMENilONS NO.Op OlMENilONS NO.OF T E RM. A 5 II"- A 8 1 1 17/32 11/8 13 89/32 77/8 2 2 3/32 1 11/16 14 3 27/32 8 7/16 2 21/32 21/4 15 9 13/32 9 3 4 3-7/32 2-13/16 16 9 31/32 9 9/16 5 325/32 33/8 17 10 17/.,2 101/8 6 4 11/32 3 15/16 18 11 3/32 10-11/16 7 4-29/32 41/2 19 11 21/32 11 1/4 8 5-15/32 5-1/16 20 12 7/32 11 13/16 0 6 1/32 55/8 21 12 25/32 123/8 10 6 19/32 6-3/16 22 13 11/32 12 15/16 11 7 5/32 63/4 23 13 29/32 131/2 12 7 23/32 75/16 24 14 15/32 141/16 g (Catalog dimensions are for guidance only and are not to be construed as inspection standards-) j DIMENSIONS ON STANDARD MODIFICATIONS FI F2 F3 5 HS
~I~ "'~~ Y nn- Ph i c cg y i.? g :i,_h7 _.
? ;[ 7 hug=]$ usurg n,.
h - t y a ,1 AJ ei ..- h._ r __z
-i
-- l 4
'3L-ik
-' L.a. .c.u.a i i
HF1 HF2 HF3 L LWW
- I -= - ;} 1 rfj IhU Mhts " a
, ac &{ - >
~
ps ~"s , r r~aB t a ay gri ( w 2 SPECIAL ORDER MODIFICATIONS SPECIAL ORDER MODIFICATIONS DEFINITIONS' (Consult Factory) l g D ' _n...,In.,_- PRINTED SLOCKS, MARMING STRIPS AND COVERS I g REFER TO SULLETIN 4 20. ; l MARATHON SPECIAL PRODUCTS I DIVISION OF MARATHON ELECTRIC BOWLING GREEN. Ot110,43402
. - . . . -}}