ML18018B754

Forwards Responses to Written & Verbal Questions Raised by Equipment Qualification Branch Reviewers During Insp Conducted on 840809 & 10

ML18018B754
Person / Time
Site:	Harris
Issue date:	08/24/1984
From:	Zimmerman S CAROLINA POWER & LIGHT CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
NLS-84-376, NUDOCS 8408300243
Download: ML18018B754 (18)

Text

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REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR: 8408300243 . DOC ~ DATE: 84/08/24 NOTAR I ZED: NO DOCKET FACIL:50-400 Shearon Harris Nuclear Power Plant~ Unit 1< Carolina 05000400 AUTH, NAME AUTHOR AFFILIATION ZIMMERMANiS ~ RE Carolina Power L Light Co.

REC IP ~ NAME RECIPIENT AFFILIATION DENTON~H ~ Ri "

Office of Nuclear Reactor Regulationi Di,rector

SUBJECT:

Forwards responses to written L verval questions raised by Equipment Qualification Branch reviewers during insp conducted on 840809 L 10.

DISTR I BUT I ON CODE A 048D COP IES RECEI VED LTR Ef<CL S I ZE ~

TITLE: OR/Licensing Submittal: Equipment Qualification NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL NRR LB3 BC 12 1 0 BUCKLEYiB 01 1 1 INTERNAL: ADM/LFMB 1 0 ELD/HDS1 12 1 1 GC 13 1 IE FILE 09 1 1 NRR KARSCHiR 1 1 NRR/DE/EQB 07 2 2 NRR/DL DIR 14 1 1 N RAB 06 1 NRR/DSI/AEB 1 1 G FILE 04 1 RGN2 1 1 EXTERNALS AC'RS 15 8 8 LPDR 03 NRC PDR 02 1 1 NSIC 05 NTIS 31 1 1 TOTAL NUMBER, OF COPIES REQUIRED:, LTTR 26 ENCL 24

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S f CXQE, Carolina Power & Light Company NJG 3 4 t984 SERIAL: NLS-84-376 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT UNIT NO. 1 DOCKET NO. 50-400 ENVIRONMENTAL QUALIFICATION PROGRAM

Dear Mr. Denton:

Carolina Power & Light Company hereby provides responses to the written and verbal questions raised by the Equipment Qualification Branch reviewers during the inspection conducted on August 9 and 10, 1984 at the Shearon Harris site. The questions and responses are contained in the attachment.

Should you have any questions with regard to this issue, please contact Mr. Pedro Salas at (919) 836-8015.

Yours very truly, S. R. immerman Manager Nuclear Licensing Section PS/pgp (496PSA/pgp)

Attachment Cc1 Hr. B. C. Buckley (NRC) Hr. Wells Eddleman Mr. Armand Masciantonio (NRC-NRR/EQ) Hr. John D. Runkle Hr. Bob Legrange (NRC-NRR/EQ) Dr. Richard D. Wilson Mr. G. F. Maxwell (NRC-SHNPP) Mr. G. 0. Bright (ASLB)

Mr. J. P. O'Reilly (NRC-RII) Dr. J. H. Carpenter (ASLB)

Mr. Travis Payne (KUDZU) Mr. J. L. Kelley (ASLB)

Mr. Daniel F. Read (CHANGE/ELP)

Chapel Hill Public Library Wake County Public Library 8408300243 8408~4 PDR ADOCK 05000400 PDR 411 Fayettevilte Street o P. O. Box 1551 o Raleigh. N. C. 27602

r fy ATTACHMENT LIMITOR UE MOTOR OPERATOR

1. Verify that the [Limitorque] motor operator orientation of the tested equipment is the same as those motor operators being qualified in this

[Limitorque] package. Provide justification or analysis for those operators not having the same orientation as the tested equipment.

~Res onse:

Motor operators are installed per piping drawings at Shearon drawings are prepared by the design engineering group with input Harris'hese from each vendor to assure that orientation of the operator is the same as during testing, or that any changes are justified. The field uses these drawings as installation criteria. Isometrics are verified in the field and the results transmitted to the site design engineering group.

In addition, motor operator orientation of active valves in harsh environments will be verified in our equipment qualification walkdown which has already begun. To date, no deviations have been found.

2. The material analysis performed in Section E [Limitorque Report], under aging, only addresses the insulation materials. A more in-depth analysis of the non-metallic materials found on the Limitorque operator should be presented (the 0-rings should be included).

~Res onse:

A more expanded materials analysis will be included in Section E of the reviewed document. However, there is no safety concern because:

a) Limitorque has stated that the insulation material has the lowest activation energy of the non-metallic materials used; i.e., it is the limiting material.

b) Limitorque has certified that Equipment Qualification Report Nos. 600456 and B0058 are applicable to our valves. Report B0058 includes an analysis of the non-metallic materials, including 0-rings. (Material information of a more detailed nature is considered proprietary by Limitorque.)

c) Report B0058 has been certified to be adequate by CPSL, as documented in the equipment qualification package and has been accepted at other plants by the NRC.

3. What is the maximum normal temperature that these operators will experience, and provide justification for not using the maximum normal temperature in the aging methodology.

(493PSA/ccc)

I

~Res onse:

The maximum postulated normal temperature inside containment for these operators is 120'F as shown in Tab E page 2F of 3F of the qualification package. This temperature was used in the aging analysis.

4. How is 0-ring qualification assured?

~Res onse:

Carolina Power & Light Company has maintained written and verbal communications with Limitorque to assure that the valve operators have qualified 0-rings. Limitorque has provided certification letters which provide traceability of the Shearon Harris operators by Limitorque Shop Order Numbers.

5. Is walkdown of Limitorque valves to be 100 percent?

~Res onse:

All Limitorque operators on active valves in a harsh environment will be field verified.

6. Will there be walkdowns of other safety-related electrical equipment?

~Res onse:

Walkdowns will be performed on other safety-related electrical equipment in a harsh environment. The equipment will be selected on a sample basis using good engineering practice to select the sample type and size.

7. Are Limitorque operators at Shearon Harris required to be sealed?

~Res onse:

Limitorque operators on safety-related, active valves are sealed at the conduit entry point.

(493PSA/ccc)

li BIW INSTRUMENT CABLE Is the cable (BIW) required to operate submerged?

~Res onse:

BIW cable at Shearon Harris is not required to operate submerged. An evaluation is currently being conducted to determine if there are any cables, other than BIW, which will be required to operate submerged.

Cables required to operate in a submerged condition will be qualified for the condition. The results will be included in the documentation packages for those cables.

2. Insulation Resistance (IR) values during the LOCA test were performed, however, no analysis or summary was presented on how the observed decrease in IR values may affect loop accuracies.

~Res onse:

The IR values observed during environmental qualification testing are currently being used to perform a leakage current study for the Class lE instruments utilizing these cables. The results of the study will be evaluated to determine effects on instrument loop accuracies and setpoints. The results of the study and the evaluation will be documented.

3. What is the minimum acceptable IR value before the cable is considered to have failed?

~Res onse; Various acceptance criteria were used during the review of the EQ test reports. For the instrument cables the acceptance criteria include:

continuity during the LOCA simulation, ability to carry current and hold a voltage during the tests, and the ability to pass the voltage withstand test. In addition, the IR values measured during the tests are reviewed for overall behavior during the tests, in particular that they recover towards the original values. The above tests serve to indicate that the cables are qualified.

4 ~ In Section F of the EQ package, it states that interfaces were not part of the qualification. Where are the cable terminations addressed in the EQ submittal?

~Res onse:

Triaxial cable installation interface consists of the connectors, which are qualified by separate documentation packages associated with the individual type of equipment where the connector is required. These packages will be available for site audit.

(493PSA/ccc)

5. The description of the test set-up, including the manner in which the cable penetrated the test vessel, has not been placed in the test report. How is the installation kept consistent with the tested configuration?

~Res onse:

The attachment to BIW letter dated July 18, 1983 shows the test set-up in the autoclave. BIW utilized a three foot tray section inside the test chamber. The tray is below the chemical spray nozzle. The vendor indicated that the cables were laid on the tray.

The cables were brought out through the test chamber opening which was sealed with an epoxy compound. Cable trays are used to route cables inside the plant. As such, the test set-up does represent the field installation. The above referenced letter is included in the final EQ package for this cable, which is currently under revision.

6. Were IR measurements taken on all instrument cables during their environmental qualification tests?

~Res onse:

The Shearon Harris EQ program includes insulation resistance measurements of all instrument cables during qualification testing.

7. Is instrument cable used with safety-related equipment at Shearon Harris qualified without its jacket?

~Res onse:

The qualification of Class 1E instrument cables, except for coaxial and triaxial cables, is performed using jacketed and unjacketed cable samples. For the coaxial and triaxial cables, the tests are performed with the jacketed cables intact. This is how the cables are installed at the connectors. A qualified heat shrink material is then put over the connectors of the cables during installation.

(493PSA/ccc)

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RESISTANCE TEMPERATURE DETECTOR (RTD)

1. Please reconcile the following statements made in the RTD Qualification Package:

o Qualified life of 20-23 years is claimed by using an activation energy of 0.98 eV for epoxy.

~Res onse:

Reference:

1. WCAP 8587, Appendices B and U

2. WCAP 8687 ESE 5 and 6 Carolina Power & Light Company evaluated the accelerated aging part of the RTD test program (Reference 2) utilizing the Arrhenius methodology and 0.98 eV as the controlling activation energy (E )

(Epoxy: Ea = 0.98 eV as specified by Reference 2). Results of this evaluation indicate that a 23 year qualified life at SHNPP is appropriate.

o "The qualified life is limited to ten (10) years by the expected radiation during the ten (10) year life and the DBE."

~Res onse:

The Westinghouse generic qualification program included an exposure of 70 megarads which corresponds to that expected over a ten-year normal installed life of the wide range RTDs. Shearon Harris plant specific, worst case, normal radiation exposure is 3.5 megarads for the same RTDs. Therefore, 10 years is a conservative qualified life.

0 In calculating the post accident operability time demonstrated, an activation energy of 0.5 eV was used.

~Res onse:

Reference:

1. WCAP-8587, Appendices B and D

2. WCAP-8687 ESE 5 and 6 An activation energy of 0.5 eV was utilized initially by CP&L and Westinghouse as the controlling activation energy (Ea) for the post accident evaluation since Westinghouse developed the conservative generic post accident test profile using 0.5 eV as the reference Ea (Reference 1). As previously indicated, 0.98 eV is the controlling activation energy and is being used by CP&L in revising the RTD qualification package.

(493PSA/ccc)

2. What is the maximum expected normal temperature for these RTDs?

~Res onse:

The maximum expected normal temperature for the narrow range/wide range RTDs is based on a 50'C service temperature for ambient conditions plus an additional 50'C temperature rise resulting from heat transfer from the reactor coolant system. Thus the total expected maximum normal temperature for the well mounted and bypass manifold RTDs is 100'C or 212'F. This is presently documented in CP&L's qualification report.

3. Justify the 50'C temperature rise assured in the aging calculations.

~Res onse:

Westinghouse has performed a heat transfer calculation using 620'F as a reactor coolant system fluid temperature, a maximum of 140'F as the ambient temperature around the area of the epoxy potting material and a minimum air velocity of 5.0 ft/sec in this area. This results in a conservative temperature rise of 50'C.

4. The basis for activation energy used in calculations could not be located in the file. Provide the reference and basis for the activation energy used.

~Res onse:

The 0.98 eV activation energy used for the epoxy has two sources:

a) WCAP-8587 "Methodology for Qualifying Westinghouse WRD Supplied NSSS Safety Related Electrical Equipment" page D-12 documents the results of a study conducted by Westinghouse and shows that the minimum activation energy for a cast epoxy is 0.98 eV.

b) EPRI Report NP-1558 (September 1980) "A Review of Equipment Aging Theory and Technology" page 84 documents an activation energy of 0.98 eV for epoxy based on 50% retention of flexural strength.

(493PSA/ccc)

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LUBRICATION In the case where specific brands of lubricants are not recommended by the equipment manufacturer, how does CP&L assure that lubricants used are environmentally qualified?

~Res oese:

Carolina Power & Light Company has contracted a leading lubrication vendor to perform a lubrication study for Shearon Harris. The study has been received and it documents the lubricants that can be used in the cases where the vendor CP&L is currently has not specifically recommended a particular brand.

reviewing the lubricant vendor's documentation which was produced to support the report. An equipment qualification package will be generated using the same procedure used for other equipment. In the study, radiation stability, or conversely the amount of radiation damage, is measured using conventional physical and chemical analysis and by comparing the results with the unirradiated material. In addition, standard performance tests are performed on previously irradiated material or as a dynamic procedure during irradiation.

These test results are compared to the original equipment manufacturer's test reports to assure that the lubrication performance criteria have been enveloped.

This information will be available in an equipment qualification package when complete.

(493PSA/ccc)

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