BSEP-86-1490, Forwards Supplemental Response to Violation 1 Noted in Insp Repts 50-324/85-26 & 50-325/85-26.Failure to Sufficiently Analyze Rockbestos Firewall III Cable Documentation Denied. Argument Supporting Denial Presented

Forwards Supplemental Response to Violation 1 Noted in Insp Repts 50-324/85-26 & 50-325/85-26.Failure to Sufficiently Analyze Rockbestos Firewall III Cable Documentation Denied. Argument Supporting Denial Presented

ML20215N182
Person / Time
Site:	Brunswick
Issue date:	10/23/1986
From:	Dietz C CAROLINA POWER & LIGHT CO.
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
BSEP-86-1490, NUDOCS 8611040411
Download: ML20215N182 (3)

Text

.. D&T) f.

CA&L Carolina Power & Light Company ,3 Brunswick Steam Electric Planta6 BCT27 All: n5 P. 0. Box 10429 Soutbport,'NC 28461-0429 October 23, 1986 FILE: B09-13510E SERIAL: BSEP/86-1490 Dr. J. Nelson Grace, Administrator U.S. Nuclear Regulatory Commission Suite 2900 101~Marietta Street NW Atlanta, GA 30323 BRUNSWICK STEAM ELECTRIC PLANT UNITS 1 AND 2 DOCKET NOS. 50-325 AND 50-324 LICENSE NOS. DPR-71 AND DPR-62 SUPPLEMENTARY RESPONSE TO INFRACTIONS OF NRC REQUIREMENTS

Dear Dr. Grace:

Enclosed is a supplementary response to Violation No. 1 received in I&E Inspection Report 85-26. .The initial response was submitted on June 30, 1986 (Serial: BSEP/86-0996).

Very truly yours, C , 63. Qfh [1 C. R. Dietz, General Manager Brunswick Steam Electric Plant MJP/mcg

. Enclosure cc: NRC. Document Control Desk

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VIOLATION Paragraph (j) of 10CFR50.49 requires that. a record of qualification must be maintained to permit verification that each item of equipment.i;s qualified for-its application and meets its specified performance requirements when subjected ~

to the conditions predicted to be present when it must perform its safety function.

1 Contrary to the above, the licensee's file, QDP-12, for Rockbestos Firewall III, insulated cable with Hypalon jacketing, did not provide sufficient analysis to

1. support qualification of the cable's specific applications at BSEP. The file did not provide sufficient analysis in the following areas:

1. Analysis to document that cable qualification test's profiles enveloped required plant environments.

2. Analysis to document that cable functional performance tests conducted during qualification testing were applicable to BSEP cable performance

! requirements.

3. Analysis to document that tested cable was the same as, or similar to, the cable installed in BSEP.

This is a Severity Level IV violation (Supplement I).

RESPONSE

I. Admission or' Denial of the Alleged Violation

! CP&L denies that the Rockbestos Firewall III (chemically and irradiation cross linked polyethylene insulated) cable qualification documentation (QDP-12) had insufficient analysis at the time of the NRC inspection to support qualification for the cables' specific applications at BSEP. The qualification documentation contained several independent bases for qualification, including:

A. CP&L's acceptance of Rockbestos Ra,, ort No. QR-4802, which consolidated test programs performed independently of.the Rockbestos l organization.

l B. Documentation of the status of successful Rockbestos. requalification i

testing beyond the BSEP steady-state accident requirements.

i II. Discussion To address concerns raised in Information Notice (IN) 84-44, Rockbestos Report No. QR-4802, dated August 31, 1984, was reviewed and accepted by CP&L for its applicability to BSEP qualification requirements. This

! report cited two test programs performed independently of the Rockbestos organization (by Sandia Laboratories) that qualified both chemically l cross-linked polyethyene (CXLPE) and irradiation cross-linked polyethylene

(RXLPE) insulated Firewall III cables

i i

l1 o l A. SAND 81-2027/1 of 2 (NUREG/CR-2932/1 of 2), dated September 1982, for qualification of CXLPE cables.

B. SAND 83-2406 (NUREG/CR-3588), dated April 1984, for qualification of RXLPE cables.

Reckbestos presented the parameters of ther, test programs and concluded that tba Sandia results demonstrated that both cable insulation systems were qualified. QDP-12, as reviewed during the NRC inspection,' identified

+his Rockbestos conclusion and further stated that the Sandia test parameters adequately enveloped the BSEP normal and accident environmental requirements.

At the time of the NRC inspection, CP&L conYccted Rockbestos to identify the schedule for completion of Rockbestos requalification test programs and their issuance of final test reports for these requalification efforts. Rockbestos stated that requalification testing of CXLPE insulated Firewall III cable had been successfully completed and that '

requalification of RXLPE insulated Firewall III cable had completed 76 of the 100-day LOCA simulation without ~ problems. QDP-12, as reviewed during the NRC Inspection, included a record of this telecon and noted that the 76-day LOCA exposure exceeded the BSEP 30-day accident requirement.

Based upon the availability and formal receipt of the Rockbestos requali-fication test reports (Reports No. QR-5804, dated August 27, 1985, and QR-5805, dated October 8, 1985), CP&L has revised the qualification documentation for both the CXLPE and RXLPE insulated Firewall III cables to document the acceptability of these requalification test reports to the BSEP requirements. Also included in the current revision of QDP-12 is a Rockbestos similarity analysis (Report No. TR-6801, dated July 31, 1986) which substantiates the applicability of QR-5804 to older CXLPE Firewall III formulations. With the incorporation of the Rockbestos requalification test reports and CXLPE similarity analysis into BSEP qualification documentation, it is CP&L's belief that the concerns raised in IN 84-44 have been fully resolved.

III. Conclusions CP&L believes that QDP-12 was sufficient at the time of the NRC inspection to demonstrate the qualification of Rockbestos Firewall III CXLPE and RXLPE insulated cables. QDP-12 documented our acceptance of Rockbestos Leport No. QR-4802 as a basis for qualification of Firewall III cables through test programs performed independently of the Rockbestos organiza-tion (given the IN 84-44 concern that certain original Rockbestos tests were unacceptable to establish the cables' qualification). Additionally, the QDP contained documentation of the telecon with Rockbestos that con-firmed successful completion of requalification testing beyond BSEP steady-state accident requirements. Subsequent to the NRC inspection, the Rockbestos requalification test reports (QR-5804 and QR-5805 for CXLPE and RXLPE, respectively) and the CXLPE similarity analysis,(TR-6801) were incorporated into the current BSEP qualification docuaentation to ensure resolution of the concerns raised by IN 84-44. For these reasons CP&L believes that the alleged violation should be dismissed.