ML13322A980
| ML13322A980 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 05/05/1989 |
| From: | Nandy F SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML13311B090 | List: |
| References | |
| IEIN-88-029, IEIN-88-29, NUDOCS 8905090111 | |
| Download: ML13322A980 (4) | |
Text
Southem California Edison Company P. 0. BOX 800 2244 WALNUT GROVE AVENUE ROSEMEAD, CALIFORNIA 91770 F. R. NANDY TELEPHONE MANAGER OF NUCLEAR LICENSING May 5, 1989 (818) 302-1896 U. S. Nuclear Regulatory Commission Attention:
Document Control Desk Washington, D.C. 20555 Gentlemen:
Subject:
Docket No. 50-206 Environmental Qualification of Bunker Ramo Electrical Penetration Assemblies San Onofre Nuclear Generating Station Unit 1 By letter dated January 31, 1989, it was indicated by the NRC staff that the Bunker Ramo (Amphenol) electrical penetrations installed at San Onofre Unit 1 were not considered environmentally qualified. The letter stated that the documentation reviewed by the NRC staff did not provide sufficient test data and supporting analysis to demonstrate operability of the penetrations during a design basis event. It also indicated that testing would be required to demonstrate the qualification of the penetrations.
The letter requested that we provide you with our plans and schedule for qualifying, testing or replacing the penetrations.
When the NRC first raised the issue concerning Bunker Ramo penetrations in April, 1988, SCE reviewed the applicable Environmental Qualification Document Package (EQDP) for the Bunker Ramo penetrations at San Onofre Unit 1. SCE verified that the subject penetrations continued to be fully qualified to DOR Guideline criteria applicable to SONGS 1 and forwarded an informal copy of the EQDP to the NRC. Although SCE considered the NRC's concerns inapplicable to the SONGS 1 applications, efforts were initiated to develop additional confirmatory evidence of the equipment's qualification. A consultant with expertise in this area was brought in and additional, previously unidentified test data were found. A revised EQDP incorporating this additional material and addressing such issues as were raised in Information Notice 88-29 was issued in June, 1988.
This additional effort again confirmed that the equipment is fully qualified to the DOR Guideline criteria.
8C905090111 89505 PDR ADOCK 05006026
Document Control Desk
-2 Based on the information in the NRC's January 31, 1989 letter and the staff's conclusion, we are concerned that the NRC staff did not consider the applicability of the DOR Guidelines to the San Onofre Unit 1 penetrations, nor the insignificant effect of the insulation resistance (IR) issue for the power and control application of these penetrations at San Onofre Unit 1 as documented in the revised EQDP. Therefore, provided as an enclosure is the EQDP for the Bunker Ramo (Amphenol) electrical penetrations installed at San Onofre Unit 1.
The Bunker Ramo (Amphenol) penetrations at San Onofre Unit 1 are utilized in power and control circuits for safety-related equipment. They are not used in any instrumentation application as is discussed in IE Information Notice 88-29. The environmental qualification of the penetrations as documented in the EQDP is based on the DOR Guidelines and specifically addresses the significance of IR values on the power and control circuits. It is SCE's position that the Bunker Ramo (Amphenol) penetrations at SONGS 1 continue to be environmentally qualified and capable of performing their safety function in a post-accident environment. Environmental qualification testing of the penetrations installed at SONGS 1 is not necessary.
It is requested that the NRC staff review the enclosed EQDP for the Bunker Ramo (Amphenol) penetrations used at San Onofre Unit 1. If additional information or a meeting with the staff is necessary following your review, please contact me.
Very truly yours, Enclosure cc: J. B. Martin, Regional Administrator, NRC Region V F. R. Huey, NRC Senior Resident Inspector, San Onofre Units 1, 2 and 3
oUNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 May 25, 1989 To Recipients On Attached List.
Subject:
Southern California Edison Company letter dated May 5, 1989 "Environmental Qualification of Bunker Ramo Electrical Penetration Assemblies San Onofre Nuclear Generating Station Unit 1" By letter dated May 5, 1989, Southern California Edison Company submitted for NRC review, an Environmental Qualification Document Package for the Bunker Ramo penetrations at San Onofre Unit 1. This document was processed under accession number 8905090111 and made PDR available. Prior to microfilming purposes, it was discovered this document contained confidential information. The project manager (Charles Trammell) for San Onofre Unit 1 was notified of this matter. Charles contacted Southern California Edison Co.
and advised they had submitted confidential information with no request that it be withheld from public disclosure.
On May 24, 1989, the Document Control Desk (DCD) received a call from Rick Ornelas (Southern California Edison Co.) requesting the May 5, 1989 submittal be withheld from public disclosure due to containment of confidential information. Rich advised that a letter and affidavit would be submitted to the DCD in support of this request.
This document will be reprocessed under 10 CFR 2.790 through the DCD.
Recipients who have received this document should upgrade their copy to Proprietary status with the exception of, LPDR, NSIC and NRC PDR. These copies should be returned to:
Don Lanham Pl-37 One White Flint North U.S Nuclear Regulatory Commission Washington, D.C. 20555 Sincerely Yours, James C. McKnight IMVDCB Document Control Desk encl: RIDS distribution sheet
Recipients for RIDS distribution, Accession Number 890509111.
CHARLES TRAMELL ACRS NRR/DEST/MEB NUDOCS-ABSTRACr REG FILE ILPDR NSIC NRC PDR