ML20133B148

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Requests Extension to Schedule for Final Environ Qualification of Electrical Cables,Per Generic Ltr 85-15, for Continued Operation Up to & Beyond 851130
ML20133B148
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 09/27/1985
From: Parris H
TENNESSEE VALLEY AUTHORITY
To: Harold Denton
Office of Nuclear Reactor Regulation
References
CON-#485-310 GL-85-15, OL, TAC-61274, TAC-61275, TAC-61276, NUDOCS 8510030045
Download: ML20133B148 (16)


Text

e TENNESSEE VALLEY AUTHORITY CHATTANOOGA, TENNESSEE 37401 6Mll B Missionary ~ Ridge place September 27, 1985 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Convaission Washington, D.C.

20555

Dear Mr. Denton:

In the Matter of the

)

Docket Nos. 50-327 Tennessee Valley Authority

)

50-328 Our present environmental program and cable test schedule for Sequoyah should establish cable qualification near the end of November. However, even a moderate sli'ppage in the schedule or an anomaly found in our on-going field verification of equipment in the environmental qualification program could impact our ability to establish cable qualification by November 30, 1985.

Therefore, in accordance with the requirements of 10 CFR 50.49 and the August 6, 1985 letter to ALL LICENSEES OF OPERATING REACTORS which transmitted Generic Letter 85-15. "Information Relating to the Deadlines for Compliance with 10 CFR 50.49," we are requesting an extension to the schedule for final environmental qualification of electrical cables for' units 1 and 2 of our Sequoyah Nuclear plant. This extension request applies to two periods of operation.. The first period is from restart of each unit until November 30, 1985,and the second period is'for operation beyond November 30, 1985.

This extension request is needed for only one category of components, i.e.,

electrical cables. previously, we had requested an extension for terminal blocks. Based on the preliminary test program results at Wyle Laboratories,.

terminal blocks, both coated and uncoated, performed satisfactorily during testing. Full qualification of the terminal blocks will be established prior to restart of a Sequoyah unit. provides a justification for centinued operation (JCO) for both periods of time, up to and beyond November 30, 1985 for the electrical cables. We are presently reverifying that we have properly identified all of.the electrical cables. The JC0 provided-in the enclosure is for those cables identified to date. Following complete cabic identification we will amend the enclosed JC0 if any additional cable-related issues are identified.

.By our. March 27, 1985 letter to NRC we indicated that unit 1 at Sequoyah lacked environmental qualification on approximately 166 components because of procurement, delivery, and installation-ralated problems. TVA has put forth a major effort and has completed replacement of all components identified in the March 27 letter.

85100i0045 B W 5000327 r.

nom em P

An Equal Opportunity Employer cf

N

-- Mr. Harold R. Denton September 27, 1985 Requesting our extension now avoids the possibility of the need to submit an untimely request af ter September 30, 1985. We believe that our substantial progress toward replacement of all unqualified equipment at Sequoyah and our determination to ensure proper documentation of the qualification of electrical equipment, as well as the fact that the cables are in a test program to establish qualification prior to November 30, 1985, supports our request for an extension.

In accordance with 10 CFR 170.21 enclosed is an application fee of $150 for the review of this request. The fee is being wired to the Nuclear Regulatory Commission Attention: Licensing Fee Management Branch.

If you have any questions or need any additional information in your evaluation of this extension request, please get in touch with R. E. Alsup at FTS 858-2725.

Very truly yours, TENNESSEE VALLEY AUTHORITY H. G. Parris, Manager Power and Engineering (Nuclear) d subscribed day of o d @ >pefore me Sworn this 1985 i

Notary Public j

My Commission Expires o -

Enclosure cc (Enclosure):

U.S. Nuclear Regulatory Commission Region II Attn:

Dr. J. Nelson Grace, Regional Administrator I.

101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. Carl Stahle Sequoyah Project Manager U.S. Nuclear Regulatory Commission I

7920 Norfolk Avenue Bethesda, Maryland 20814 l

i Sheet 1 cf 3 s

l JUSTIFICATION FOR CONTINUED OPERATION (JCO)

TVA PN. PJ, PNJ. and PJJ Cable Tynes These cables have polyethylene insulation.

The cables are rated for 600V; how ev er, the WA syst em voltage s are 120V ac, 250V de, and 480V ac.

All cables of this type were constructed, tested, and accepted for use in

. accordance with WA Standard Specification 25.013 - Standard Specification f or Poly 4thylene - Insulated Wire and Cable.

WA Standard Specification 25.013 invokes the applicable portions of IPCEA S tandards (such as physical properties s:;, methods of testing for tensile strength and elongation of the insulatics and j acket material s). The WA Specification included provisions for source. inspection of f actory testing and required suhaittal of certified t est reports to assare compliance with the specification.

The se cables are used outside contalment only.

The f ollowing qualification tests are representative of the polyethylene cable s which are pre sently installed:

Wyle Laboratory Test Report 17503-1 da ted J anua ry 6,1984,

" Nuclear Enviromental Qualifica tion Te st Program on Sequoyah Nuclear Power Station Control Equipment and Cables."

The te st included cable manufactured by Plastic Wire and Cable Cor po r ation.

The test included the f ollowing:

Tamperatur e

- 3 40 F Pressure

- 72 psig Ra dla tion

- 1.1x10 Aging

- 40 years equivalent aging ba sed on 75 C conductor temperature Pa s sed po st-accident hipo t in wa ter of 4 80V ac, 960V ac, and 2500V ac.

(Esch voltage level was held for 5 minutes.)

Wyle Laboratory Te st Report 17501-1 dated March 12, 1982,

" Nuclear Environmental Qualification Test Program on Four Sets of Polye thylene/ Polyvinyl-Chloride Insulated Control Cabl e."

The test included cable manuf actured by Plastic Wire and Cable Corpora tion. The ' te st include d the f oll owing :

Ra dia tion

- 1x10 Aging

- 40 years equivalent aging ba sed on 90 C conduct or tempe ratur e

9 Shset 2 cf 3

'IVA PN. PJ, PNJ. and PJJ Cable Troes Pa ssed po st-accident hipo t in wa ter of 4 80V ac, 960V ac, and 2400V ac.

(Esch voltage level was held for 5 minutes.)

'1VA Central Laboratory Te st Report 85-E03-4910.

Ihe te st included the f ollowing cable:

1.

He actual test specimen f rom Wyle Test Report 17501-1 dated March 12, 1982, as ref erenced above.

2 Polyethylene insulated cable manuf actured by Triangle PWC and Okonite taken from Browns Ferry Nuclear Plant Unit 2 containment, ne se cables, which were deenergized, have been in contalmeent f or 6.75 years as part of an ongoing qualifica tion te st.

Thg design service ambient temperature f or in containment is 147 F and the calculated 7

total accumulated radia tion do se wa s approximately 1x10 rads.

Both of those parameters exceed the outside containment parameters in which the a ctual 1E polye thylene cable s are installed.

Test specimens fgon 1 and 2 above were placed in an oven which was preheated to 360 F and mantained at this temperature f or 30 minutes.

The oven temperature was reduced to 300 F and maintained at this temperature f or 30 minute s.

The test specimens were then placed in water and passed a hipot test at the f ollowing voltage levels:

487V for 1 minute 965V f or 1 minute 2200V for 5 minutes Test specimens f rom 2 above were also subj ected to elongation tests with the f ollowing results :

ICEA Requirements Samnle For New Cables Test Results Triangle PWC 350%

520%

i Okonite 350%

379%

The elongation test results show that af ter exposure to a much harsher environment than the enviroueent in which the cables are actually installed, the cables still have more elongation than ICEA minimum requirements for new ca bl e.

In addition, one of the recognized industry standards for end of life for cable is 40 to 60 percent elongation.

The elonga tion te st results indicate a considerable margin of saf ety for the elongation parameter.

Wyle Laboratory Te st Report 17513 -1 dated January 8,1984, a Containment Accident Test Program on Electrical Cabling and Splice s f or U se in Browns Ferry Nuclear Power Genera ting Station." The test included polyethylene insulated cables manufa ctured by Rockbe sto s.

The te st include d the f ollowing:

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TVA PN, PJ, PNJ, and PJJ Cable Tynes Temperat ur e

- 330 F Pressure

- 108 psig Ra dia tion

- 1.63x10 ra ds Aging

- 40 years equivalent aging ba sed on 90 C conductor temperature Since the polyethylene cables successfully pa ssed the above te st s, it is reasonable to predict that the same types of insulation furnished by other manufacturers will perf orm similarly and without f ailure.

Futh ermor e, though these cables have been designed and tested for a 40 year service lif e temperature of 75 C, studies have shown that none og the subj ect cables experiences a service temperature in excess of 60 C.

This reduced service temperature results in a significantly lowered rate of thermal degradation as compared to the successfully tested varieties.

In view of the above, we cor.clude that the results show that the polyethylene cables will perf orm their saf ety functions sa tisf actorily.

The cables are undergoing testing at Wyle Labs.

Upon completion of those te st s, the cable will either be deemed fully qualified or replaced with fully qualified cables, i

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Sheet 1 of 2 JUSTIFICATION FOR CONTINUED OPERATION (JCO)

CP Family ( CPJ, CPJJ. and CPSJL The CP f amily of cables consist of cross-linked polyethylene insulation and polyvinyl-chloride j acketing.

All cable of this type.was constructed, te st e d, and accepted for use in accordance with WA S tandard Specification 25.016 - Standard Specification for Cross-linked Polyethylene Insulated Wire and Cable.

WA S tandard 25.016 invoke s the applicable portions of IPCEA Standards (such as physical prcperties, and methods of testing f or tensile strength and elongation of the insulation and j acket materials).

The WA Specification included provisions for source inspection of f actory testing and required submittal of certified test reports to assure compliance with the specification.

Cable manuf actured since 1971 was controlled by a WA approved QA program.

The f ollowing LOCA/SLB tests are representative f or the CP f amily of cables which are pre sently installed.

Wyle Laboratory Test Report 43854-3 dated April 26,197 8, Quali-fication Test on Eight Cable Splice Assemblies (cable assemblies comprised of CPJ cable).

Wyle Laboratory Test Report 17513-1 da ted J anua ry 24, 1984, Containment Accident Te st Program on Electrical Cabling and S pl ice s.

The test reports show a baseline functional test was first performed and pa s se d.

Then functional tests were perf ormed and passed af ter the radiation test, af ter the temperature aging test, and af ter the LOCA/SLB tost.

The te st s include d radia tion at 1.13 x 10 ra ds.

The te sts included tanperature aging at 130 C f or 2576 hours0.0298 days <br />0.716 hours <br />0.00426 weeks <br />9.80168e-4 months <br />.

The tests included a LOCA/SLB at 325 F, 55 psig,100 percent humidity.

NOTE: One sample of CPJJ (Plastic Wire and Cable) received 1.68x10 rads and temperature a ging at 130 C f or 5152 hours0.0596 days <br />1.431 hours <br />0.00852 weeks <br />0.00196 months <br />.

The tests included cable samples from General Electric, Okonite Company, and Plastic Wire and Cable.

This cross section of cable manuf acturers represented in the tests adequately demonstrated that the CP f amily of cables will perf orm similarly in the given DBE.

The variety of vendors used also proved that successful completion of the test is a function of i

the chemical. properties of the insulation and j acketing compound and is not dependent on the manuf acturer.

Consistency in the chemical properties

i Sheet 2 of 2 CP Faully ( CPJ. CPJJ. and CPSR has been demonstrated by successfully completing the requirements of TVA Standard Specifica tion ~ 25.016.

This approach to generic cable qualification follows the general guideline s for type testing as outilned by IEEE 3 83-1974.

All cables of the CP f amily met or exceeded the construction, te st ing, and acceptance requirements of TVA Standard specification 25.016.

In addition representative samples of the CP f aally of cables supplied to IVA by diff erent manaf acturers successfully pa ssed LOCA/SLB testing.

Futh ermor e, the cables are exclusively used outside of containment.

Whereas cables of this f amily are designed and tested for a 40 year service life temperature of 90 C, design studies have shown that none of the cables from these contracts experiences a service temperature in excess of 60 C.

This reduced service temperature results in a significantly lowered rate of th erm al de gr ada ti on a s compa red t o. th e succe s sf ully te st e d v ari e ti e s.

In vsew of the above, we conclude that the results show that the CP f amily of cables will perf orm their saf ety functions satisf actorily.

The cables are undergoing testing at Wyle Labs.

Upon completion of those te st s, th e ca bl e will either be deemed fully qualified or replaced with fully qualified cable s.

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' Sheet 1 of 2 JUSTIFICATION FOR CONTINUED OPERATION (JCO)

PI Family (PXJ and PIMJ) - American Insulated Wire ( AIW)

The PI cables covered by this J00 were manuf actured by AIW and consist of cross-linked polyethylene with a chicrosulfona ted-polyethlene j acket.

All cable of this type was constructed, tested, and accepted for use in accordance_ with WA S tandard Specification 25.016 - Standard Specification for Low-Vol tage Wire and Cabl e with Flame-Retardant, Cros s-Linke d Polyethylene or Ethylene-Propylene Rubber insulation.

WA S tandard Specification 25.016 invokes the applicable portions of IPCEA S tandardsp such as, physical properties, and methods of testing for tensil e strength and elongation of the insulation and J acketing materials.

'Ihe 'IT A Specification included provisions f or source inspection of f actory testing and required submittal of certified test reports to assure compliance with the specification.

Manuf acture of all installed cable was controlled by a WA approved QA pro gram.

The f ollowing LOCA/SLB tests are representative of the PI f amily of cables which are. pre sently installed.

Franklin Institute Test Report F-C4113 dated May 1975. ( Brand-Rex Company)

Rockbestos Company Test Report dated July 1977 and revised Nov ember 26,1977, " Qualification of Firewall III Class 1E Electric Cables ( Ch emi ca117 Cro s s-linke d Ins ula tion)'.'

Franklin Institute Test Report No.- F-C5120-1 dated August 19, 1980, (Brand Rex Company) " Qualification Tests of Electrical Cables in a Simulated Steam Line Break (SLB) and Loss-of-Coolant Accident (LOCA)

Environme nt" Essex Proj ect Report Number PE-53 dated May 7,1980 " Main Steam Line Break (MLSB) Te st on Aged and Irradiated Cable Specimens" The Okonite Company Engineering Report No. 355 dated September 17, 1981, ". Main Steam Line Break Qualification Test on Okonite, Okoni te-FMR, I-01ene-FMR and Oko guard Insula tions'.'

The test reports demonstrate the PII and PIMJ cables manuf actured to meet the requirements of WA S tandard Specification 25.016 are suitable f or Class IE service in accordance with appropriate guideline s presented in IEEE Standards 3 23-1974 and 3 83-1974.

Sheet 2 of 2 PI Family (PXJ and PXMJ)

The te st s include d radia tion of 2x10 rads.

The tests also included a LOCA/SLB at 346 F,113 gsig 100 percent humidity and MSLB's a t 455"F, 32 psig (Okonite) and at 440 F (Essex).

These-tests included cable sonples from Brand-Rex Company, Rockbestos Company, Esser International. Inc.,

and The Okonite Company.

This cross se ction of cable manuf acturers represented in the test s a dequa tely demonstrated that the PI f amily of cables will perf orm similarly in the given DBE.

The variety of vendors used also proved that succe s sf ul completion of the tests is a f unction of the chemical properties of the insulation and'j acketing compound and is not dependent on the manuf acturer.

Consistency in the chemical properties has been demonstrated by success!ully completing the requirmnents of TVA S tandard Specification 25.016.

This approach to generic cable qualification follows the general gui'delines f or type te sting a s outlined by IEEE 3 83 -1974.

All cables of the PX f amily met or exceeded the construction, te sting, and acceptance requirement s of TVA Standard Spe cifica tion 25.016 Representative smaples of the PI f amily of cables supplied to TVA by diff erent manuf acturers successfully pa ssed LOCA/ SLB testing.

The AIW cables are exclusively used outside of containment.

In addition, whereas cables of this f amily are designed and tested for a 40 year service lif e temperature of 90 C, design ~ studies have shown that none of the. cableg from these contracts experiences a se rvice temperature in exce ss of 60 C.'

This reduced service temperature resul ts in a significantly lower rate of thermal degradation a s compared to the succes sf ully to t ed varieties. 'In view of the above, we conclude that the resul ts show th a t tb e PI f amily of cables will perf orm their saf ety functions sa tisf actorily. The subj ect AIW PX cables are undergoing testing at Wyle Labs.

Upon compl etion of those test s, th e ca bl e will ei th er be deemed fully qualified or replaced with fully qualified cables.

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Sheet 1 of 2 JUSTIFICATICN FOR CCNTIhUED OPERATION (J00)

Rockbestos Firewall Silicone Rubber (TVA Type SR)

The silicone rubber cables are made of methyl phenyl vinyl silicone rubber.

The cables are used exclusively inside containment in 480V or less power and control cigcuits.

The actual conductor operating temperature is equal to or less than 50 C.

The cables are required to be qualif ed to the f ollowing parameters:

Normal Abnormal Accident Tempera ture :

120 F 130 F 3 27 F f or 33 minute s Relative Humidity:

80%.

100%

100%

Pressure:

14.7A 14.7A 26.4 Ra dia tion:

2.5x10 NA 1x10 Chemical Spray:

NA NA The f ollowing qualification test s a re representa tive of Rockbe stos Firewall SR cable s which are pre sently installed.

1.

Franklin Institute Research Laboratories, Final Report F-C2857, Test of Electrical Cables Under Simulated Post-Accident Reactor Containment Service, September 1970.

"Ihe te st include d the f ollowing:

Temperature / Time:

276 F f rem t=15 se conds to t = 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Rela tive Humidity:

100%

Pressure:

50 psig Ra dia tion:

2.34x10 rads Chemical Spray:

1720 ppn borated water Aging :

Minimum of 10 years at 50 C (equivalent)

  • 2000 ppm boron, 8.35 ph, 0.1847 molar H B0, 0.033 molar Na01 3

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Sheet 2 of 2 Rockbestos Firewall Silicone Rubber (TVA Tyne SR)

A summary of F-C1857 to show applicability, to the actual plant conditions is a s f ollows :.

The actual accident profile is a 327 F peak for 33 minutes.- The te st profile maintained 276 F f or approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> which provides % much greater thermal saturation of the insulation material than.the 327 F for 33 minutes;r th eref or e, the test time temperature profile is more severe than the actual conditions. The relative humidity, pressure, and radiation parameters all exceeded the actual plant pa ram eter s.

All cables inside containment are completely enclosed in conduits, junction boxe s, or l ead shields which protects the cable f rom chemical spray; therefore, the use of chemical sprays during the test provides additional conservatism.

The testod specimens were not thermally aged prior to testing; however, REIC report No.' 21 dated September 1,1961, ("The Effects of Nuclear Radiation on Elastomeric and Plastic Materials," R. W. King, ET AL., Battell e Radiation Effects Center) states that the material is not susceptabic to degradation at the temperatures which the cable actually operates.

Consequently, th e una ge d t e st e d sam pl e i s r epr ese nta tiv e of a m inimum 10-

. year sampl e f or the pl ant specific application.

He test specimens were energized with 480VAC, at 10 anps during the time temperature profile and passe d a five minute 6000VAC po st-accident hipot te st.

1 2.

Addi ti onally, Rockbestos Firewall Silicone Rubber was again tested by Rockbestos a s stated in their Qualification of Firewall SR Class 1E Electrical Cables dated March 2,1978, and Addendum dated February 13, 1980.

This report has been questioned because of QA concerns (ref erence 1E Bulletin 84-44); how ev er, the cable was tested and proven to be acceptable.

The test included the following:

Temperature / Time:

Sam e as IEEE 323 -1974, Appendix A Rela tive Humidity:

S ame a s IEEE 323-1974, Appendix A Pressure:

S am e as IEEE 323-1974, Appendix A Chemical Spray:

S ame as IEEE 323-1974 Appendix A Ra dia tion:

2x10 rads Aging:

40 years a t 125 C (equivalent)

Due to concerns noted by IE Bulletin 84-44, Rockbestos is currently planning to rete st the Firewall SR cable s in mid 1986.

B ase d o n th e abov e da ta, we conclude th at the above cables are adequa tely qualified to the plant specific applications for a minimum of 10 years.

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Sheet 1 of 5 JUSTIFICATION FOR CONTINUED OPEl:ATION (JCO)

MS CABLES Belden Corporation (contract 85259)

This cable is ILPE insulated with a CPE j acket. The qualification r epo'rt that applies is Isomedix (Component Test Division) test report dated February 1976, " Qualification Test of Electric Cables Under a Simulated LOCA/DBE by Sequential Exposure to Environments of Radiation, Steam, and Chemis:al-Spray." _ The te at showed that the cab 1e.1s qualified f or the f ollowing conditions :

a.

Tamperature : 346 F b.

Pressure: 113 psis c.

Ra dia tion:

2x10 rads gamma 4

d.

Hasidity: 100%

e.

Chemical Spray: 3000 ppm boron, pH 9.0-11.0 Although no thermal aging was performed on the cable samples prior to the test, the ILPE was thermally aged during standard f actory test as required by the TVA procurement spe cif ica tion.

The standard f actory testing on aged 4

samples included tensile and elongation test.

The aging perf ormed during the standard f actory testing equates to approximately 25 years of incontairmnent lif e.

The results of the test indicate that the cable has a substantial amount of lif e lef t af ter the aging (greater than 75% of the original elonga tion). The accepted industry standard to predict the end.of lif e is 40 to 60 percent of the original elongation.

The above conditions envelope all areas of the plant in which the cables are located and perform safetyrelate d f unctions.

In addition, the cables are undergoing a test program at Wyle Labs which includes thermal aging.

It should be noted that the cables are used exclusively as signal cables both inside and outside contair_ent.

MS cables are designed and tested-for a 40 year service lif e temperature of 90 C.

Because of their service as signal cables ohmic heating is not a consideration and their 40 year service lif e is the 50 C plant containment ambi ent. ' This reduced service temperature results in a significantly lower rate of thermal degradation as compared to its rated conditions.

Based on the above we conclude th at th e te st on a n una ge d s ampl e i s justified until testing currently in progress a t Wyle Labs is completed.

Upon completion of those tests, the cables will either be deemed fully qualified or replaced with fully qualified cables.

Shast 2 of 5 JUSTIFICATION FOR CONTINUED OPERATION (JCO)

MS CABLES Okonite Company (contract 72C7-74910-2)

This cable is insulated with crosslinked polyethylene and J acketed with chlorosulfona ted polyethylene.

The f ollowing test report is representative of the insulation material of the cable: The Okonite Company Engineering Report No.

355 dated. September 17,1981, " Main Steam Line Break i

Qualification Test on Okonite, Okonite-FMR, X-Olene-FMR, and Okoguard Insul ator s."

The test results showed that the cable is qualified for th e f ollowing conditions:

a.

Tampera ture :

470 F 4

b.

Pressure: 75 psia c.

Humidity:

1005 d.

Chemical Spray: IEEE 323-1974 Appendix A j

e.

Ra dia tion: 5.5x10 rads gamma f.

Qualified Life:

40 years at 90 C conductor tesiperature The MS cables are used exclusively outside of contaimmient.

Cables of this f agily are designed and tested for a 40 year service lif e temperature of 90 C.

Since these cables are signal cables ohmic heating is not a consideration and their 40 year service lif e temperature is the 40 C plant.

ambient.

This reduced service temperature results in a significantly lower rate of thermal degradation as compared to the successfully tested varie tie s.

Based on the above, we conclude that the above Belden and Okonite cables will perf orm their saf ety functions sa tisf actorily.

Cables frem this contract are undergoing testing at Wyle Labs.

Upon completion of those te st s, the cables will either be deemed fully qualified or replaced with f ally qualifled csbles.

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Sheet 3 cf 5 JUSTIFICATION FOR CONTINUED OPERATION (JCO)

MS CABLES Rockbestos (contract 826961 and 823265)

Signal cables, ' type NS, are used both inside and outside of containment.

The insulation is a chemically-crosslinked polyethylene with a hypalon Jacket.

The cables have been the subj ect of the f ollowing test programs:

1.

Sandia Report - SAND 81-2027/1 of 2, " Equipment Qualification Research Test' of Electric Cable with Factory Splices and Insulation Rework Test No. 2, Re por t No. 1, " Se pt emb e r 19 82.

2.

Rockbestos Report No. QR 5804 " Report on Qualification Tests for Firewall III Chemically Cros: linked Polyethylene Constructions for Class IE Service in Nuclear Genera ting Sta tions."

The wor st ca se accident condition parameters at SQN are as follows:

Tempera ture : 327'F Pressure: 26.4 psia Humidity: 1005 a

Radation:

1.2 EB Chemical Spray:

( se e b el ow)

In test report number 1, samples were subj ected to the f ollowing:

Aging:

40 years at 90 C Tempera ture : 346 F Pressure: 125 psig Humidity:

100%

Radiation: 1.96 EB Chemical Spray:

IEEE 323-1974 The following conditions were applied in test report 2.

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Shset 4 of 5 JUSTIFICATION FOR CONTINUED OPERATION (JCO)

MS CABLES Aging:

47 years at 90 C Tamperature: 342 F Pressure:

greater than IEEE 323-1974 Humidity: 100%

Radiation:

2.0 E8 Chemical Spray: YES (as ref erenced in the test report)

As can be seen from the above, both of the ref erenced test reports envelope the service conditions of the subj ect cable.

In addition, there are a number of other test reports conducted by Franklin Labs for Rockbe stos.

Though the validity of these reports has been brought into question by IE Notice 84-44 (because of Rockbestos' QA) it is significant to note that chemically crosslinked polyethylene manuf actured by Rockbestos has been successfully te sted a number of times.

TVA's specific application of these cables is f ar less severe than that demonstrated in the above tegts.

Whereas those cables were aged for 40 and 47 years respectively (at 90 C),

because we utilize these cables exclusgvely in signal circuits with no ohgic heating our service conditions are 50 C f or cables in containment and 40 C for those outside of cont ai rmie nt.

This service temperature, well below the cables design rating, results in a significantly lowered rate of thermal degradation a s compared to the succe ssf ully te sted varie tie s.

In t e st number 2 there were a number of variances due to the conductor insulations sticking to the mandrel.

The test specimens were individus1 conductors taken from a multiple conductor cable.

As the individual conductors were removed from the mandrels for further testing portions of the insulation were torn away.

Handling of the cables in this f ashion is not indicativ e of their true. service requirements.

In addition, all of our cable constructions are multiconductor, shicided and j acketed varieties.

As such, adhesion of the primary insulation to adj acent' structures is z.at cre dibl e.

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Shast 5 of 5 JUSTIFICATION FOR CONTINUED OPERATION (JCO)

MS CABLES Finally, it should be noted that both of the subj ect test programs subj ected the cables to direct impingement of a chemical spray solution.

At SQN all cables inside of containment are in conduits so that no direct spray is credible. The presence of this spray in other successful programs give s a further measure of conserva tism.

In light of the above, we conclude that the NS cables a s supplied by Rockbe stos will perf orm their saf ety functions sa tisf actorily.

Upon f ull evaluation of Rockbestos report QR-5: 04 and discussion of its variances with Rockbestos the cable will either be deemed fully qualified, another test program will be initiated, or the cable will be replaced with fully qualified cable.

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