ML20245L032
| ML20245L032 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 05/01/1989 |
| From: | Bailey J WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 89-0079, 89-79, NUDOCS 8905050247 | |
| Download: ML20245L032 (7) | |
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LF CREEK W8) NUCLEAR OPERATING wnn A. Bailey Vlce Prosht Mily 1,'1989 Nuclear Operatons NO 89-0079 U. S. Nuclear Regulatory Commission ATTN:
Document Control Desk Mail Station F1-137 Washirgton, D. C. 20555
Reference:
Letter dated January 31, 1989 from G. M. Holahan, NRC, to B. D. Withers, WCNOC Subj ect :
Docket No. 50-482:
Response to Request for Information Regarding Bunker Ramo Assemblies Gentlemen:
.The purpose of this letter is to respond to the Staff's request for additional information regarding the environmental qualification of Bunker Ramo containment electrical penetration assemblies (EPA) installed at Wolf Creek-Generating -Station (WCGS).
The attachment to this letter contains information regarding the similarity of the installed instrumentation circuits and the circuits which were tested and information on the.
insulation. resistance values on control circuits installed at. WCGS.
In
-addition, information is present.ed regarding the plans and schedules for
[
obtaining supplemental qualification testing information for Bunker Ramo BPA's at WCGS.
The. environmental qualification documentation currently in place at WCGS
-supports the qualification of the Bunker Ramo EPAs as required by l:
If you have any questions concerning this submittal, please contact me or Mr. O. L. Maynard of my staff.
Very truly yours,
- 0. &
I John A. Bailey Vice President I
Nuclear Operations JAB /j ad Attachment cc:
B. L. Bartlett (NRC), w/a E. J. Holler (NRC), w/a R. D. Martin (NRC), w/a
[b D. V. Pickett (NRC), w/a i \\
8905050247 890501 PDR ADOCK 05000482 P
PDC P.O. Box 411/ Buriington, KS 66839 / Phone: (316) 364-8831 An equal Opportunity Emp! oyer MF/HCNET x_______-___--____-..
Attachnent to NO 89-0079 Page'l of 6 1.
Provide additional information regarding the similarity of the tested configuration and the installed configuration for instrument circuits (Test Report Nos. 123-2202 and 123-2222, Rev. 3).
The instrumentation modules used at Wolf Creek Generating Station (WCGS) are shown on drawing E-035-00134 (Bunker Ramo drawing 50026707, sheet 1), included as Figure 1.
Als-an isometric cutaway view of the-modules is included as Figure 2.
The nonmetallic used in the instrumentation modules at WCGS are given in Table 3.1 of Reference 2 and are as follows:
1 Dwg Table No.
No.
Description Bunker Ramo Part No Vendor & Part No 1
41 Module Epoxy Unknown Amphenol 2
36 Heat Shrink 50009729-04 Raychem RFR 3
1
- 16 TQS Wire 44428-EP-35 B1W 12341-H-004 2
- 16 TTS Wire 44428-EP-36 BIW 12341-H-003 3
- 16 TPS Wire FF2TC16B6-C1 Raychem Flamtrol 4
- 16 AWG Wire 50003482-03 BIW 12198-H-G-16 18 36 Heat Shrink 50009729-01 Raychem RFR The module epoxy of the WCGS modules are a Type 2 (Glass F'11ed Epoxy, bisphenol) with a Type B Secondary Seal Insulating Material (which is also a Glass Filled Epoxy).
This arrangement has been referred to as the "hard seal".
These materials are identical to those tested.
Note that terminal Aug heat shrink (items 22A and 22B of E-035-00134) is not used on inside containment safety related instrumentation modules at WCGS, as it was removed along with the terminal lugs prior j
to commercial operation.
Also, items 16A and 16B do not perform a l
safety related electrical function.
As can be seen on the E-035-00134
- drawing, their function is simply to provide strain relief where the individual conductors exit a jacket.
It should also be noted that all the wire used on the instrumentation modules have been qualified by the wire manufacturers, therefore the purpose of the Reference 1 testing was to qualify the module epoxy and the Raychem RFR heat shrink.
The instrumentation modules at WCGS are qualified by Bunker Ramo Test Report No.
123-2222, Revision 3 (Reference 1).
In addition, Bunker Ramo Test Report No.
123-2222, Revision 4 (Reference 2),
which was prepared specifically for the SNUPPS utilities, provides additional explanation of the testing reported on in Reference 1.
The insulation resistance (IR) valuee given in Table 5 of Reference 1 for the 69#14 (WCSF) sample are acceptable for all WCGS safety related instrumentation circuits.
The following discussion will provide additional information regarding the similarity of the 69#14 (WCSF) module of Reference I to the installed instrumentation modules at WCGS.
Attachrent to NO 89-0079 Page 2 of 6 The test module which qualified the WCGS instrumentation modules was the 69#14 (WCSF) module listed in Table 5 of Reference 1.
Per Bunker Ramo drawing NPD-1242-02 (page 38 of 161 of Reference 2),
the 69#14 module was one of 6 used in electrical penetration assembly IV (EPA IV) of the Bunker Ramo test 123-2222 (one header location was left blank).
The other five modules (Twinax, 85#16 (special desiga with thermocouple wires), 3x350 low voltage power, Triax and Coax) are not applicable to WCCS instrumentation circuits.
Note that Table 5 of Reference 1 l!4ts 9 modules.
This is because 1. includes the medium voltage module, which was not part of EPA IV (the only EPA to go through the LOCA test),
- and, very importantly, it lists the 69#14 module 3 times.
Although it was previously assumed (in error) that there were three 69#14 modules, in actuality, there was only one.
The reason it was listed 3 times is because the pigtail leads were terminated 3 different ways (twice with terminal blocks and once with Raychem WCSF heat shrink).
As noted on page 6-of Ref(rence 2, "some of the low-voltage Control Circuits of Module 69#14 were terminated to vertically mounted terminal blocks" (and, of course, some were terminated using Raychem WCSF heat shrink).
The low-voltage modules installed at WCGS have the identical physical dimensions and module materials as the 69#14 module used in EPA IV of the Bunker Ramo test.
Only the size of the conductors that go through the modules differs in configuration, but not the basic design.
2.
Provide additional discussion concerning the effects of extremely low IR values on control circuits (Test Report Nos.
123-2202 and 123-2222, Rev. 3)
As discussed above, there was only one 69#14 module in the Bunker Ramo qualification test with the wires being terminated by three different
- methods, two vith terminal blocks and one with Raychem WCSF heat shrink.
It follows that the reasons for the low IR values in the two 69#14 groups of wires terminated with terminal blocks were not due to the problems with the module (since there was only one module), but due to the differences in the termination methoda, i.e.,
terminal blocks, versus Raychem WCSF heat shrink.
- However, since E-035B-00021 (Reference 4 ),
establishes that Kulka terming 1 blocks ds not exhibit low irs in a LOCA environment, it follows that the low values were due not to the tested equipment, but were caused by other events.
The only reasonable event which could have caused this situation was the flooding of the chamber.
While flooding of the LOCA chamber would certainly be considered an anomaly in a test conducted in today's environment, since the 1979 test did not violate the acceptance criteria, flooding of the chamber would not have been considered an anomaly at that time, and its lack of inclusion in the report would be expected.
Chamber flooding,
- however, is evident when one compares the Table 5 IR readings of those circuits with heat shrink over the terminations (i.e.
the 69#14 (WCSF) and the 3x350) versus those circuits with no heat shrink.
i b
g.
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Attachrent to.!K) 89-0079 Page 3 of 6 In. contrast'to th
'sted conditions, the WCGS electrical penetrations are ' located weix above.f]ood level, and are provided with drainage l
. holes to prevent buildup of fluid.
Since the WCGS modules will not j
- flood, the IR readings of the 69#14 circuits with terminal blocks are j
not applicable'to WCGS.
In summary then, the only module relevant to WCGS control circuit applications in the Reference 1 report is the' 1
69014 (WCSF) module, which during the entire 30 day LOCA test, had a minimum IR reading of 1.8E4 ohms.
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An IR reading of 1.84E4 ohms translates to a maximum leakage current of less than 8 millampere, assuming a control circuit voltage of 140V.
This is well below the leakage previously analyzed to be acceptable for control circuits at WCGS.
Therefore, the Reference 1 testing establishes the qualification of the Bunker Ramo modules for use at WCGS.
Bunker Ramo Qualification Test Report 123-2202 (contained in Reference 3) is used by WCCS to provi.de supplemental information i
related to the qualification of control circuit modules.
Although the 1R readings were taken post DBA, the modules were protected with a 100 milliampere fuse throughout the LOCA tert. The applied voltage was 500 volts.
Even though the Reference 1 test has demonstrated trat the 3
leakage on a control circuit module at WCGS is less than 8 milliampere, an ' analysis of control circuits was performed assuming the leakage current had been 100 ma.
The analysis demonstrates that all control equipment which must perform a safety related. function will work properly.
While some indicating lights which provide valve position indication could glow dimly or possibly flicker, it does not affect the qualification of the electrical penetration modules since this will not mislead the operator.
3.
Provide a description of plans and schedule to either qualify, test or replace the' Bunker Ramo penetration assemblies with qualified l
assemblies.
l The above discussion provides qualification information in addition to that previously reviewed by the NRC.
This new information includes data supporting the similarity of the configuration of the WCGS instrumentation modules compared to the tested modules, as well as additional test information on the cont.rol circuit modules at WCGS.
The information establishes that both the Reference 1 and Reference 3 j
tests provide sufficient information for establishing qualification of
-Bunker Ramo modules for use at WCGS.
Please note that the bases for qualif1 cation are in no way dependent on the Perez affidavit which was presented to the Staff by the Nuclear Utility Group on Equipment Qualifics'. ion.
The information supporting the conclusions in this letter will be added to the qualification documentation for the Bunker
c, 0.
Attachment to N0 89-0079 Page 4 of 6 Ramo modules by June 30, 1989.
In addition, WCGS is aware of additional testing performed by Wyle Labs for Commonwealth Edison on Bunker Ramo modules identical to the WCGS modules. The results of this testing -support the data presently in the WCCS files and, while not l
required to demonstrate qualification of Bunker Ramo modules for WCGS applications, it will be added to the qualification files to provide additional qualification assurance, also by June 30, 1989.
References:
i 1.
E-035-00123, Design Qualification Report for Electrical Penetration Assemblies, Bunker Ramo Report No. 123-2222, Revision 3.
2.
E-035-00148, _ Addendum No.
1 to the Design Qualification Report for Electrical. Penetration Assemblies.
Standardized Nuc1 car Unit Power
- Plants, Wolf Creek and Callaway.
Bunker Ramo Report No.
123-2222, Revision 4.
3.
E-035-00144,- Addendum No.
1 to the Generic II Qualification Testing of Electrical Penetration Assemblies per Amphenol Test Plan 123-2200.
4.
E-035B-00021, Test Report for Kulka Terminal Blocks made with CDI-30F Glass-Filled Diallyl Phthalate for Class 1E Service in Nuclear Power Plants, Conax No. IPS 675.
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