ML20236K117: Difference between revisions
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| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC | | document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC | ||
| page count = 18 | | page count = 18 | ||
| project = | |||
| stage = Supplement | |||
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Latest revision as of 14:38, 25 January 2022
| ML20236K117 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 11/03/1987 |
| From: | Murphy W VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | Johnston W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20236K121 | List: |
| References | |
| FVY-87-105, NUDOCS 8711090105 | |
| Download: ML20236K117 (18) | |
Text
{{#Wiki_filter:~ gy VERM6NibANKEE. . l; MNUCLAhtNWER CORPOR TIDNJ V ' t h- . RD S, Box 169, Ferry Road Brattleboro, VT 05301 FVY 87-105
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'~4 ENGINEERING OFFICE . l p) b.[
- 1671 WORCESTER ROAD
.- I s- r FRAMINGHAM, MASSACHUSETTS 01701 (f -
.l)hb TELEPHONE 617 872 8500. j 31: November 3, 1987
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~U.S. Nucletr Requlatory. Commission 'f f
,N1 Region J -
j L631 Parf.4[f .$enue'{~ ' _ _ _ 14 Q] , King,offressia,PA 19406 ,
![ttn:1 i - illiam V. JohOst ,ActindDirector '
) .ivision!cf React Safety-Refet 4nces s s License'No. DPR-28.(Oocket No. 50-271) 3 h' ' N )') *Ietter, USNRC to VYNPC, NVY 87-158, " Equipment c' 7
/_ . Qualification Inspection of Vermont Yankee Nuclear i
// (" p . .!' / ' ' Pour Station (Inspection No. 50-27/87-19), j jJ daied 9/29/87 I
<c/t y t 1 i fNebSir:
Subject:
NRC inspection 87-19, Environmental Qualification
,13 Inspection of, Vermont. Yankee Nuclear Power Station
;y During the week of October 19, 1987 through October 23, 1987, a team of NRC
.and contractor personnel performed ISE Inspection 87-19, Environmental Qualification Program, at the )/erront Yankee Nuclear Power Station. At the exit meeting, the lead auditor-identiffed several areas where supplemental infor-3 mrjion'should be provide /to assist irl the final evaluation of the inspected areas and to supplement'.information which would ultimately appear in the subject inspection report.
'3 9 .
Accordingly, we are pros jtind Aheattachedinformationwhichcanbeasso-ciatedwiththefollowingspeafficpinspectionareas: ) l t Attachment A GE EB-5 Terminal Blocks Justification of Original Qualification Wire Critnps in Justification of Original Qualification
'l{v' Attar,hment'8 .
,> .LimitorqueMOV'y)
L.l? Q[.f - Attachment C Dings Brakes ' Justification of Original Qualification W Rome Cable Justification of Original Qualification 9
4'i E Attachments At*pchment E. Lewis Cable Justification of Equipment Qualifiability
, . A ttachqnt F Tape Splices in Justification of Original Qualification
-' O1 Limitorque MOV's)
- g; o 'n.Att%inent G 3M Tape Splices ! Justification of Original Qualification
.", 'AttachmeerjH Cerro., Cable Justification of Original Qualification y ,y .Attaphment I Additional Information'
.' on MOV Walkdoans' c2c ;
t,w Co. , 4"Q _ 'y ] Question numbers referenced irg the attachments correspond to question num- , g<c- bers pjdc. rated d'uring NRC Inspectie 87-19. gg {
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VERMONT YANKEE NUCLEAR POWER CORPORATION i JU.S. Nuclear Regulatory Commission .l
! Noveinber 3,1987 ,
Q3 Page 2 l e It was Vermont Yankee's understanding that-the inspection team viewed the !
-programmatic' controls and bases for Vermont Yankee's EQ Program as very effec- ;
tive, . based ilpon statements at the management exit' meeting held at the conclu- -{ sion of the site inspectionivisit. Further, the staff identified no equipment or safety problem. associated wi.th the Vermont-Yankee'EQ Program. However, during the inspection,.a number of discussions of Vermont Yankee's application of simi-
.g larity qualification analyses'were held. It remains Vermont Yankee's' position.
.that qualification.by similarity-is a fully acceptable method of qualifying !
existing' plant equipment under the provisions of the EQ regulatii,ns. Further,
- it"is Vermont Yankee's position that we followed similarity methods consistent with those followed at other nuclear facilities which the staff has accepted during inspection'of EQ-Programs. Based on these facts, we conclude that with
;one exception (Lewis Cable) the EQ files as presented during the audit for the 3
.above equipment contained sufficient information to justify full qualification !
of the affected equipment. Attachment E provides additional information requested by the NRC documenting the equipment qualifiability of the Lewis Cable. We are therefore requesting a meeting to discuss the similarity issue and its appl.ication at Vermont Yankee with your staff an-d members of the technical , staff at NRR. This meeting would allow the opportunity for.us to present the
-bases for similarity qualification criteria which have been applied consistently and thoroughly in our EQ program. We propose the week of November 16, 1987 for such a meeting subject to successful mutual arrangements by all parties.
We' trust that the attached information will significantly supplement the audit record in several key areas and lead to the final resolution of unresolved items. We also firmly believe that the meeting requested will be of significant mutual benefit to NRC and Vermont Yankee in resolving the remaining inspection issues. We would appreciate prompt consideration of our request for a meeting. , Should you have any questions or require further information, please contact this office. Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION W Warren P. f urphy v Vice President and Manager of Operations
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i Off , yq Page 1 of 2 ATTACHMENT A Question No. 9: General Electric EB-S Terminal Blocks-Limitorque test 800119 does not establish qualification because megger readings taken,(apply 2.2 volts) does not demonstrate insulation resistance at the-required voltage. Response No,' 9':
;In an effort to demonstrate the qualified status of these terminal blocks, we x'
pursued a " similarity analysis" to GE CR151B terminal blocks qualified in y another' documentation file. Qualification by this analysis was demonstrated to
\' 'the satisfaction of your auditors. However, since we-had to make an addition to the ffle, we were cited. !
We have reviewed this' file and.the NRC question again. There is no statement'in l
-the report that the megger ope atW at a voltage of 2.2 volts. The auditor ver-bally informed us that he had " heard somewhere" that.this was the case. In addition, we have reviewed catalog information concerning Biddle Meggers and .
have discussed their technical attributes with the manufacturer (see attached notes of telephone conversation). These terminal blocks are required to operate during the first seven days of a HEL8. However, the steam and high temperature conditions only exist for approximately one hour. One hour data is not available from the test report; however, date at 10 seconds, 30 minutes and 2.5 hours is available. During that perjod, the minimum recorded resistance was recorded at 200 kilohm. That reading was taken'in the presence of caustic spray application. From a review of the technical information on the megger, we conclude that the minimum v.oltege range usable to create these readings wo'ald have been 100 volts. Since these i terminal blocks are utilized in instrument applications where the maximum ' voltage, except poiwer supply input voltage, is 52 volts DC; we conclude that the terminal blocks are qualified for their application. In addition, we conclude that the documentation that presently exists adequately suppurts that qualification. We were unable to acquire the information presented during the audit period. However, this information dees not modify or amplify any portion of the documen-tation package. It merely serves to address an auditor's question brought up
-during the audit. Under these conditions, we feel that reconsideration of our response is warranted and that no violation should be assessed.
Ifithere were some technical bases to dispute, the information contained in Test Report 80119, the information would have been presented to the industry in the form of an I&E Information Notice or by vendor notification. It has been and l will continue to be our practice to address concerns expressed in such Notices in a rigorous and timely manner, a__-_-__ _ _ _ _ _ l
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - = - - - - - - - - ----
.Page 2 of'2!
h I,;4.. > ATTACHMENT'A. < R; . g.' ,w[ *, M 4 1
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- FILE NO.
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TELEPHONE CONVERSATION
SUMMARY
l Project eN e LL rc k 'Date'.'10fSJ!37 <j
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or i I Page 1 of 2 ATTACHMENT B i i Question No. 19: l Nylon Insulated Wire Joints In three Limitorque operators in the Reactor Building (outside containment), nylon wire joints were used on motor leads. On one MOV-10-150, these joints were used to splice two wires together making a current path. No documentation
. exists in EQ File 3.1'for these joints.
t a) Need to demonstrate environmental qualification for use of these nylon wire joints outside containment, b) Need to determine if any of these joints are used in containment. If so, need to address EQ for in-containment conditions. Response No. 19:
'Limitorque QDR 3.1 contains certification from the vendor that the motors are
' qualified by Limitorque Test Reports B0003, 600376A, and 600198. Nylon wire joints for dual voltage motors were supplied by Limitorque and are considered part of the motor itecelf. Test Reports 80003, 600376A, and 600198 tested dual voltage motors that contained insulated wire joints. We considered these dual voltage motors to be qualified by the test reports contained in the QDR.
Through membership in industry groups, Vermont Yankee is aware of the current ongoing discussions between the NRC and Limitorque regarding the nylon wire joints. To date, we have not received correspondence from either the NRC or the vendor to indicate the qualificaiton of these connectors was not established by the existing test reports. To cite Vermont Yankee for a documentation violation based on an ongoing investigation of an unnoticed issue in our estimation is not appropriate. Therefore, in accordance with the provisions of the Vermont Yankee Equipment Qualification Program, Vermont Yankee maintains that full qualification has been established for these components. However, during the audit, the qualification of these splices was questioned by the auditor. The discussion presented in the attached telecon mitigates con-cerns raised during the audit by justifying an alternative acceptability of these components. It is important to note, however, that Vermont Yankee considers the Limitorque Notor Operators being discussed as fully qualified for their application by the existing documentation.
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Attachment B Page 2 of 2-
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i t 1 a 3: 1 L As discussed irt the response -to Question ~ 14(2), there are forty-one .(41) EQ n '
.MOV's in the: Reactor Building and~ steam tunnel'at Vermont Yankee. Of.these,.
isix.(6);are single-voltage' motors and do not contain~ nylon-insulated wire
. joints. Thirty-three.(33). valves with dual-voltage motors are required;to func-etionlonly post-LOCA.and are not required.to operatef in a steam environment
. -Qualification of'these MOV'stto. operate in'the worst case-post-LOCA; radiation; environment'of'2 x;10 7LR Lis'demonstrat'ed by' materials analysis .in EPRI Reportt
~
NP-2129 which indicates thatlthe1 dielectric strength of nylon'is not.signifi-Jeantly. reduced at radiation doses significantly above the required value. Two valves with' dual-Voltage motors are pres'ently' listed . in Vermont Yankee's' EQ ' - J
- matrixtas requiredLtoioperateLduring a HELB, The EQ matrix was developed byl
. selecting; equipment and systems which placed the plant in the most stable state for the postulated: accidents. The scenario for each adcidentlis based on'the Vermont / Yankee FSAR and; Emergency Operating Procedures'. It is desirable that-a11} equipment-be~ operable,from the' Control Room buta-if access is available,
' local operation'is permitted.
o-MOV 10-34A-and MOV-10-3'98 operate to est'ablish the-torus cooling mode of RHR.
- Torus cooling mode.of RHR is. required to remove decay heat from.the torus following a HELB; however, our analyses indicate that under the. worst case HELB scenario initiation of torus cooling can be delayed for 70 minutes. At this U time,athe Reactor. Building temperature has returned.to normal. The two valves-
.are fully? accessible and torus cooling-can be manually initiated by locally 9 . opening the' valves.. -
Because our program was developed to allow all equipment required for HELB to be operable 1 remotely, we intend to resolve any concerns by obtaining additional
. qualification documentation to support the operation of MOV-10-34A and i MOV-10-39B during a HELB or to. replace the nylon splices with new splices.
In' conclusion, Vermont Yankee maintains that the documentation in question ade-quately supports the equipment qualification. I s u
Attachment C Page 1 of 2 ATTACHMENT C Question No. 14:
- 1. Dings Brake's:
(a) Similarity analysis or materials analysis for radiation. (b) Similarity analysis for thermally tested Class H insuletion. Response No. 14: In establishing qualification of Limitorque valve operators, Vermont Yankee reviewed qualification test data and its applicability to the components installed at the plant. Any areas in which the installed configurations did not correspond with the tests were addressed. This included the actuators , supplied with Dings brakes. The Qualification Documentation Review (QDR) package for Limitorque operators shows Vermont Yankee's. concern regarding brake qualification dating back to ; 1980. The concern was that the brake coils could not be shown to withstand radiation. In 1984, Vermont Yankee replaced the existing brakes containing radiation resistant coils, and accompanied by a Certificate of Compliance from Limitorque which states, "... The motor supplied with special radiation resistant brake coils with materials equivalent to K80110 would be equivalent or superior to the brake motor included in Limitorque Qualification Report 600198." Based upon the information supplied, Vermont Yankee believed suf ficient documentation existed to support environmental qualification of the valve operators with motors containing brakes with special radiation resistant coils. In order to satisfy concerns raised during the recent inspection; however, Vermont Yankee has obtained additional information on the composition of the brake coils. A materials analysis further er.hancing our qualification conclusion is contained below. Part 1(a) The material used in the special radiation resistant coils with Class H insulation supplied with the Dings brakes at Vermont Yankee is listed below. The radiation threshold values of this materini are also listed. These 7 threshold values exceed the 8.0 x 10 R dose at Vermont Yankee for the application of the brakes. Therefore, these materials are considered qualified for radiation. 5927R/20.239
Attachment C Page 2 of 2 Component- Material Threshold Dose Magnet Wire Insulation Pyre ML 200 MR (Joy X-604) Crossover Barrier , Pyre ML-Coated Glass 330 MR (NP-2129) Fabric Lead Wire NOMAX, Glass-Braided 330 MR_(NP-2129) Belden 30718 Core, Liner Pyre ML-Coated Glass 330 MR (NP-2129) Fabric-Outer Wrap .007 Thick Glass Tape 100 MR-(NP-1558) Final Coat 'Dow Corning 997 Varnish 500 MR (REIC-21) l
'Part 1(b)
Dings brake coil, Model No. H-60240, was type-tested for environmental conditions including steam, but excluding radiation. The material list of the type-tested coil., Model H-60240'(60 series), is the same as that supplied for Vermont Yankee Model No. 6-71015-6S (70 series) [see attachment). In addition, per telecon (attached), Dings has stated.that the materials supplied in the type tested coil
'(60' series) is the same as supplied in the Vermont Yankee coils (70 series).
The Vermont Yankee brake coil materials, therefore, would exh! bit the same characteristics upon exposure to environmental tests. As additional proof, this radiation-resistant insulation has been used on motors subjected to and passing similar environmental tests (see Limitorque Certificate of Compliance, QDR Pages F18 and F19, attached). Vermont Yankee concludes, therefore, that the Dings brakes used at our plant are qualified, however, additional supporting documentation nas been obtained and will be added to the qualification files. 1
-. . 1
,. y___-_--____ ___ _, _ _ - ._ es.p ... Attachment'C- Appendix A sesed en the plant calkeevn. tre codels of Dings'leeke vote identified. Page ' I of 1 These were N 61003-50 and 1-72025 7. I cA.V06-41009-50 series Blags krake was used el the test speeleen to. The broke-
. f ' establish (Uelifitatiet tapetted in the WCAF 7410L.euseessfully possee a s
_( ' test 414 not include re.!1stien. Letter tre. r. nievin to r. sentevisee aated 7-so-or. estantiebee traceability by solel ad serial no. to installed Its units.' The letter also identifies Class X initl6 tion for both sodell 90H100H0 and
^
E-12025-7e , , Dings drawings l(60240 and E70033 identify the meterial makeup of the. ceil of the instelled units. _
-itetter'. free D. Malberg to P. Sentevlece detd 9-24-87s verifiestho' l b meterial used in the'eesstreetion of the cells are per the specification l
(revings listed Seve. -
.. d N meterial snelysis fee the Class R insulation of the type tested teil edel E-60240 (Dings breis model V06-61003-50) is provided belove l.' . Matt 9 fat THPESHOLD DMI, COMPoH M PYtt MLf 200 Masarads
- 1. Masnet Wire Insulation (Joy 1-404) i Crossover Barrier. FYtt ML 330 Meserels
- 2.
Silicone toMed Mics . lHF-2121) Or SillCppe bendet glass M!cA Sheet 2006 Megareds
- 3. fie Board . . .
(DOR Guidelines -Table C-1) j 330 Meg 4ta!5
" 4. Lead Virt - FC. ? tX w Sun- %' % (177-2129) y e:1t.n- wJd gs PYBE ML or 330 Meterade
" 3. Liner (Nf-2129)
Silicone bonded Mice or Silicone bonded glass Classfa;t 100Megareis
- 6. Cerner Liniy Tape (SP-1559)
N/A N/A
- 7. Coil Identificatsen
* (Nareplete)
Glass Tape 100 Megarads
- 8. Outer wrap (HP-1556) 500 Megarade
'** 9 . Vacnish cow 997 Vernish (e111eene resin) (REIC-21)
N/A
- 10. Lead Vire Ties Metal.
The thteshold dose of all materials exceed the 1P3 dose of 4.22 Megereds. I I l i i
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~ FILE,NO.
\
t r I TELEPHONE CONVERSATION
SUMMARY
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(~~[ - Attachment C LiMITORQUE CdNNO" RATION .
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' 5114 Wc av 0%d P O Bon 11318 Lynchburg. Virg.nia 24506 l
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#,: f Teleonone--804 528 4400 . Telex--82 9448 F l CERTIFICATE OT COMPLIANCE QDR- 3.1 ,
REV.4 i July 20, 1984 , Customer Vermont Yankee Nuclear Power Co. 1 Customer Purchase Order'No. 22115 Limitorque Order No. 3K3400-D & E q i I 1 b*e hereby certify, according to our records, the motors supplied on the above mentioned order are that which were ordered and are provided in accordance with , I.imitorque's Quality Assurance program which meets the applicable requirements cf ERC Regulatery Guide 10CFR50, Appendix B, and ASSI E5.2. The brake motor supplied .] with special radiation resistant brake coils with materials equivalent to K80110 / would be equivalent or superior to the brake motor included in Limitorque Qualification Report 600198. The capability of the motor and brake coil to withstand radiation only can be supported by Qualification Report 600376A. For 3600 R.P.M. motors, the naneplate vill indicate a speed in the ran;;e of 3365 to 'I
~
3480 R.P.M.. Mot.or serial no's Item D - 1YF331295-A-2-TK Item E - 1YFB31295-A-1-TK
. State of Virginia City of Lynchburg
...... 3 Subscribed and sworn to before .me on this 20th day of July, 1984 '} .v . L.
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' ,' John D. Allen NoturyPublick MS ufMT\.3-My commission expires March!!. 1966 P t ./
- 0000C Auto:" ate:
- cl e Actuetcrs a..c Jacas for Industr,
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. Attachment C
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LIMITORQUE cdWFURATION ~~.[ w w-
< 5114 woodait Roa: a i O Ben 11318 Lynenourg. Viromia 24506 ,
- f. '
Teleonone-804 528 4400
- Telex-82 9448
.* -QDR- 3.1
. CERTIFICATE OF COMPLIANCE ,
- July 14, 1984 i
' Customer Vermont Yankee Nuclear Power Co.
a Customer Purchase Order No., 22115
^
Limitorque Order No. 3K3400-A thru C *
' We hereby certify, according to our records, the cotors supplied en the above mentiened order are:
- 1) that which were ordered s
-2) provided in accordance with Limitorque's Quality Assurance program which meets I the applicable require:ents of NRC Regulatory Guide 10CTR$0 Appendix B, and-l
'AKSI N45.2.
4 , The brake motor supplied with special radiation resistant brake coils with =aterials l squivalent to K80110 e uld be equivalent or superior to the brake motor included in Limitorque Quali. fica. tion Report 600198. The capability of the motor and brake coil to )
"*"""'""'""""'"'""""""'^~'
, C9 For 3600'.R.P.M. motors, the nameplate will indicate a speed in the range of 3365 to !
3480 R.P.M..
- i Motor serial no's Item A lYTB31295-A-3 'IK ?
Item B - 1YTB31295-A-5-TK Ite= C - 1YFB31295-A-4-TK State of Virginia City of Lynchburg Subscribed and sworn to before ne on this ' 14th day of July, 198!.. ,, )* t , u _v j
. Notary Public hM.n My encaissior.' expires Match 7, khb 19 f.S 1
ol Supervisor onnne A.Aomatec Valve Actuators and Ja: c for Industry
Page 1 of 4 ATTACHMENT D The following. engineering analysis is being performed to document the justification of the original qualification of Rome Cable as documented in
'QDR 6.14. The NRC's concern about Rome Cable is documented as Question 2 below:
NRC Concerns
- 1. The file lacked specific reference to supporting-data to allow a l determination of the adequacy of qualification data .specifically type testing was not done on aging, temperature radiation - etc. How can the functional requirements be accomplished if'the environmental plant l conditions have not been met - (temperature radiation) LOCA Testing ?
- 2. How was similarity between the tested cable and the installed cables established in regards to aging, PEAK temperature, radiation ? )
Subsequent answers have addressed the NRCs concerns but it is our contention
'that the file properly documented qualification on October 19, 1987. The .
original' file was not found acceptable based on the audit team's position that ] qualification'by similarity arguments between Rome Cable and other manufacturers' cable were not sufficient to establish qualification. It is Vermont Yankee's contention that the basis of the Rome Cable qualification is a combination of testing of the actual cable purchased by Vermont Yankee, Franklin testing conducted on Rome XLPE Cable, and similarity analysis with other XLPE insulated cable manufactured by other companies. The similarity analysis is use.d simply to extend tests on actual Rome Cable to .; envelope peak temperatures experienced at Vermont Yankee. The demonstration of adequacy in environmental qualification is not completely absolute but rather relates to the " reasonable" concepts established in title 10 of the Code of Federal Regulations and NRC staff guidance in such l appropriate document as the DOR Guidelines (Enclosure 4. IEB 79-01B,
" Environmental Qualification of Class IE Equipment," January 14, 1980). For example 10CFR$0 Appendix B, " Quality. Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants" in the Introduction paragraph establishes l l
requirements," necessary to provide adequate confidence ...." 10CFR50 l Appendix A. " General Design Criteria for Nuclear Power Plants," Criterion 1, - l
" Quality Standards and Records," requires QA to be, " established and implemented in order to provide adequate assurance . . ." Finally the DOR {
j Guidelines, " Guidelines for Evaluating Environmental Qualification of Class 1E l Electrical Equipment in Operating Reactors" Paragraph 1.0 Introduction. ) concerns itself with, " Class 1E equipment whose documentation does not provide j reasonable assurance of environmental qualification." < l On the basis of the regulations and NRC staff guidance the requirements ) establish " reasonable assurance" or provide " adequate assurance" or " adequate l confidence" that environmental qualification is established. The Vermont Yankee EQ flies provide " reasonable or adequate assurance" such that " adequate confidence" of environmental qualification exists. 1
page 2 of 4
. ATTACHMENT D (Continued) i l
l 1 Insisting on similarity only by exact formulation, absolute testing'or .i "similar" absolute certainty words exceeds the intent of all nuclear safety j related quality assurance. This is especially true for DOR Guideline plants. l The NRC's reluctance to accept only similarity as a basis of qualification is not the issue with Rome Cable. In a paper written by Mr. M. Jacobus, Sandia National Laboratory titled,
" Experience Gained From Equipment Qualification Inspections," qualification by generic similarity is discussed. Generic material qualification is defined as !
qualifying.one manufacturer's product using accident test data from other .) manufacturers products and/or other generic data. Mr. Jacobus also states I that in general, for incontainment applications, generic material
. qualification is still not accepted. However, for certain outside containment applications, generic material qualification has been accepted based on !
individual application based on the following factors:
- 1. The severity of the environments relative to commonly known material ')
capability and to normal (nonaccident) envirotunents.
- 2. The amount of margin between generic test environments and the required environments for the item to be qualified.
- 3. What similarity data exists (e.g., aging, radiation resistance, ,
information on materials, and processing from manufacturers involved, I etc).
- 4. What type test data does exist for the item to be qualified. I It is Vermont' Yankee's contention that if generic qualification with no type test data has been found acceptable for outside containment applications, that our use of generic qualification to only extend the steam test peak for incontainment use is justifled.
The following analysis which takes the four factors dese:ibed by Mr. Jacobus into account, docwnents our contention of the original acceptability of the Rome Cable file. The cable manufacturer's Cable Qualification Test Progran included environmental testing of various samples of titeir cables by Franklin Institute Research Laboratories (FIRL) (see QDR Tab Gl). The cable installed at Vermont Yankee has been described by the manufacturer as being essentially the same as cable tested by FIRL (QDR Tab F, Page F2). Additionally, ikt order to demonstrate compliance with the EBASCO Cable specification for Vermont Yankee, the :able manuf acturer performed environmental tests on actual samples of cable purchased by Vermont Yankee. -a--__
'Ls Page 3 of 4 , p: .
o
, ATTACifMENT D i .(Continued)
.' ' 7 The requirements for.both the'FIRL-tests and the type of tests performed by,
' Rome on Vermont' Yankee's cable were developed prior to IEEE 323 or any other industry-wide' guidelines for environmental-qualification guidelines.
The: current postulated environmental parameters for Vermont. Yankee are more harsh than those stipulated in the cable specification. testing or the FIRL-
- r- 'Tcst Program.
When appropriate, FIRL test data is used to support qualification of the ? cables installed at' Vermont Yankee; however, the aging and peak temperature ( ' requirements for Vermont. Yankee are not enveloped by the FIEL test or the
, . specification testing. Those sections.of the review are extended through j similarity with other cable manufacturers' testing. ';
The use of similarity to extend qualification is acceptable because: r- i h' J Ac The' cables are similar in construction;.the Rome Cable and the similar ' GE Cable both use 0.030 inches of carbon black. filled chemically
# . cross-linked polyethylene insulation'which meets the requirements of IPCEA Standard S-66-524. (See QDR Pages DT14,'DT15, F2, and F4.)
.I B. Significant margin exists between the requirements for Vermont Yankee and m .the' demonstrated capabilities of the similar cable. The GE XLPE insulated cable was qualified in accordance with the applicable
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n . .,
- IEEE standards. That qualification demonstrated (QDR Pages DT15 and DT16) that the GE' Cable has:
- 1. A normal-life expectancy of greater than 40 years at'an ambient of 900C-(QDR Page DT15). The requirement for Vermont Yankee primary containment (worst case for all locations at Vermont Yankee) is
,i 40. years at 8500 (QDR Page DTL).
- 2. A peak accident' temperature capability of 3460F while electrically energized. Note: Although that peak temperature is not that much' i
> greater than the 3250F peak at Vermont Yankee (Page DT7), the fact I
;; that the GE Cable was electrically energized during the test implies that.the actual peak temperature experienced by the XLPE insulation was higher than 3460F due to resistance heating temperature rise i of the conductor. As noted on Pages DT1 and DT2, the Rome Cable at 1 Vermont Yankee does not experience any temperature rise due to the type of loads serviced. The Vermont Yankee cable only sees the l
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ambient peak temperature. Furthermore, the Rome Cable at Vermont 1 _ Yankee is only used in control or power circuits (no instruments) of i at least 120 V. The operability of those circuits would not be affected by even relatively.large changes in the cable insulation resistance during the peak accident temperatures. x----_ _. _
j Page 4 of 4 ATTACHMENT D l .(Continued)
- 3. - A radiation withstand capability of'2.2 X 108 rads. The f requirements at Vermont Yankee (using Beta reduction data of l Section DR of the QDR) is 1.42 x 10 8 . Note that the FIRL test of' 1 J
Rome XLPE insulated cable demonstrated a capability of 5 x 108 l _ rads (Pages G1-20.). CONCLUSION In accordance with DOR guidelines, the Rome XLPE Cable installed at Vermont Yankee has been demonstrated qualified as documented in QDR 6.14. . ! Qualification is based on a combination of type test of the actual cable purchased by Vermont Yankee, FIRL tests.of similar Rome XLPE insulated cable, ) and.through similarity with other XLPE insulated cable manufactusted by other companles. { l i j 1 l l l _ - - _ _ _ - _ - - - -}}