ML17261A558

Responds to Violations Noted in 870610 Insp Rept 50-244/87-03.Corrective Actions:Addl Positive Sealing Provided at detector/connector-cable Interface for Victoreen high-range Radiation Monitor

ML17261A558
Person / Time
Site:	Ginna
Issue date:	07/09/1987
From:	Kober R ROCHESTER GAS & ELECTRIC CORP.
To:	Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
IEIN-86-053, IEIN-86-53, NUDOCS 8707250136
Download: ML17261A558 (12)

Text

REGULATORY INFORMATION DISTRIBUTIQN SYSTEM (RIDSi ACCESSION NBR: 8707250136 DOC. DATE: 87/07/09 NOTARIZED: NO DOCKE1 ACIL: 50 244 Robert Emmet Ginna Nuc lear Plantz Unit it Rochester G 05000244 AUTH. NAME AUTHOR AFFILIATION OBERI R. W. Rochester Gas 4 Electric Corp.

REC IP. NAME RECIPIENT AFFILIATION RUSSELI W. T. Region 11 Office of Director

SUBJECT:

Responds to NRC 870610 ltr re violations noted in Insp Rept 50-244/87-03. Corrective actions:addi positive sealing provided at detector/connector-cable interface for Victoreen high range radiation monitor.

DISTRIBUTION CODE: 'IEOID TITLE: General COPIES RECEIVED: LTR (50 Dkt)-Insp Rept/Notice of g ENCL Response Violation Q SIZE:

NOTES: License Exp. date in accordance with 10CFR2i 2. 109(9/19/72i. 05000244 RECIPIENT COPIES REC IP IENT CQP I~S ID CODE/NAME LTTR ENCL ID, CODE/NAME LTTR ENCL PD1-3 PD 1 STAHLEi C 2 lNTERNAL: AEOD 1 1 DEDRO NRR MOR ISSEAUi D 1 1 NRR/DOEA DIP. 1 1 NRR/DREP/EPB 1 ~ 1 NRR/DREP/RPB 2 NRR/DRIS DIR 1 1 NRR/PM*S/ ILRB 1 QE LIEBERMANIJ 1 OGC/HDS2 IL 1 1 RFS DEPY GI 1 ILE 01 TERNAL: LPDR 1 1 NRC PDR 1 1 NSIC i TOTAL NUMBER OF COPIES REQUIRED: LTTR 20 ENCL 20

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TD ! IC 55455 ROCHESTER GAS AND ELECTRIC CORPORATION e 89 EAST AVENUE, ROCHESTER, N.V. 14649.0001 ROGER VA KOBER TTI.K5'taDle5.

VICE PI5CSIDCITT CI.CCTRIC ORDD5ICTIDI5 ARCA CODE TIO 546.2700 July 9> 1987 Mr. William T. Russell Regional Administrator U.S. Nuclear Regulatoiy. Commission Region 1 631 Park Avenue Kxng of Prussia> PA 19406

Subject:

Inspection Report No. 50-244/87-03 Notice of Violations R.E. Ginna Nuclear Power Plant Docket No. 50-244

Dear Mr. Russell:

This letter is in response to Inspection Report 50-244/87-03<

dated June 10< 1987< transmitting two notices of vxolation

'relative to 10CFR50.49. The RG6E position on these notices of violation> including (1) the corrective steps which have been taken and'the results achieved< (2) corrective steps which will be taken to avoid further violations< and (3) the date when full compliance will be achievedi is included in the Attachment.

Although RG6E does not consider that any installed equipment was in violation of 10CFR50.49> as noted in the Attachment< RGGE has enhanced the documentation provided in the affected 10CFR50.49 files. The additional sealing< equipment testing> and analysis all performed by RGGE provides further confirmation that requirements of 10CFR50.495 including documentation> have been met. No further corrective actions are considered warranted.

V r truly yours>

Roger W. Kober Attachment 8707250i3b 870709 PDR ADOCK 05000244 8 PDR

ATTACHMENT RGSE Response to Notices of Violation Concerning lOCPR50.49 Inspection 50=244/87-03 NOTICE OP VIOLATION A:

"As a result of the equipment qualification (EQ) inspection of February 9-13'987> and in accordance with NRC Enforcement Policy (10CFR-2, Appendix C)i the following violations were identified:

A. 10CFR50.49(f) requires that gualification of each component be based on testing or experience with identical equipment or with similar equipment with a supporting analysis to show that the equipment to be qualified is acceptable.

10CFR50.49(k) requires> in part< that electrical equipment need not be requalified if it was previously required by the Commission to be qualified in accordance with the "Guideline for Evaluating Environmental Qualification of Class 1E Electrical Equipment in Operating Reactors" (DOR Guidelines).

Section 5.2.2r of the DOR Guidelines reqpectively requires> in part< that the type test is only valid for equipment identical xn design and material cohstructxon to the test specimen< and any deviations should be evaluated.

Contrary to the above> during the EQ inspection on February 9-13 1987 the licensee had not established similarity or. the test specimen and the installed component for the following:

l. The installed Crouse-Hinds Electrical Penetration (Ref.

050-244/87-03-02 paragraph 12. 2 > )

2. The General Cable Corporation's PVC cable used in a harsh environment. (Ref. 12.4< 050-244/87-03-03)"

RGSE RESPONSE:

As explicitly described in RGSE's March 6> 1987 letter response to the Inspection 50-244/87-03 exit meeting> the qualification information available in the RGSE 10CFR50.49 files at the time of the inspection provided reasonable assurance that the Crouse-Hinds electrical penetrations< and the General Cable Corporation PVC with cables> were fully environmentally qualified in accordance the DOR Guidelines and 10CFR50.49> in order to perform their required functions.

In the case of the Crouse-Hinds penetrations> all of the materials of construction were shown to be equal to or better than the materials which were tested> as documented in EEQ Package 58. In the case of the PVC cablei it was shown that minor deaf ferences z,n

PVC formulations< as could exist and still meet IPCEA S61-402 standards> were well within the performance requirements for the "control-type" applications at Ginna Station. Therefore< as stated in the Narch 6i 1987 letter> RGGE considers that no violation of 10CFR50.49 existed at the time .of the inspection.to However RGGE has made improvements to the f iles in order clarify the qualification documentation as follows:

a) As noted in paragraph 12.2 of the Inspection 'Report> RGGE submitted a more detailed material-by-material analytical comparison of the tested penetrations and Ginna's Crouse-Hinds penetrations in a letter d'ated Narch 6< 1987. This comparison has been added to the EEQ Package 08 files. This additional information< which addresses all of the NRC concerns expressed during the inspection> provides the corrective action taken by RGGE. It should be noted that NRC comments in Section 12.2 of the Inspection Report> relative to consideration of humidity and nitrogen gas effects on the internal penetration materials were not brought up during the inspection. Nonetheless< these issues can be resolved as. noted below:

(1) The qualification test documentation in the files demonstrated material qualification using highly conductive boiler steam. This testing envelopes the noted humidity concerns (2) Nitrogen is an inert gas> which in this aoplication excludes oxygen and> therefore, suppresses degradation from normal aging (oxidation) effects. Testing in an air atmosphere (78% nitrogen) is, conservative.

No additional corrective action is necessary> since the EEQ Package 08 files now include all of the explanatory materials comparison analysis deemed necessary by the NRC.

b) As noted in paragraph 12.4 of the Inspection Reports a confirmatory test of the specific PVC cables used in 10CFR50.49 applications in containment at Ginna Station was completed as of February 12~ 1987. This test> which confirmed the suitability of the installed cable< has been incorporated into the EEQ Package 544 files. No additional corrective action is considered necessary.

NOTICE OF VIOKATION B:

"10CFR50.49(f) requires that qualification of each component be based on testing or experience with identical equipment or with similar equipment with a supporting analysis to show that the equipment to be qualified is acceptable.

Contrary to the above> during the EQ inspection on February 9-.13>

1987< the licensee had not provided supporting documentation to establish qualification of the following:

0

1. The installed Victoreen High Range Radiation Monitor's cable/

connector/detector environmental seal configuration using Raychem Hea t Shrink Tubing over metal surfaces in the harsh.

environment. (Ref. paragraph 12.7f 050-244/87-03-05) 2 Deviation from Raychem requirements for Heat Shrink tube splice minimum seal length and minimum bend radius. (Ref. paragraph 12.6g 050-244/87-03-06)

3. Effects of insulation resistance changes and instrument accuracy for circuits using Coleman cable. (Ref. paragraph 12.5p 050-244/87-03-04)"

RG&E POSITIONS:

l. Victoreen High Range Radiation Monitor As noted in Enclosure 1 to RG&E's March 6, 1987 letter concerning Inspection 50-244/87-03< RG&E did address all of the leakage path failure mechanisms determined in the Victoreen Qualxfication Test Report 950.301. The final Victoreen assembly which passed the LOCA test did not provide a seal at the interface being questioned, at .the base of the detector/connector-cable interface (See Victoreen Test Report 950.301, Page VI-45< Photograph YI-24, which was reproduced as Attachment 10 to Enclosure 1 of RG&E's March 6> 1987 response letter to Inspection 87-03). Therefore>

RG&E has concluded that the configuration installed at the time of the inspection was fully environmentally qualified. It should be noted that a Raychem heat shrink tube was shown to form an environmentally qualifxed seal when installed over a metal surface> as documented in Reference 3.b.l> Figure IV-1> of EEQ Package 636.

RG&E did> however< provide additional sealing< prior to March 6>

1987 consisting of RTV 7403< at the detector/connector-cable interface> to provide additional positive sealing. This seal arrangement is virtually identical to the conf iguration demonstrated to be qualifie'd in EEQ Package N36> Reference 3.b.3.

The documentation relative to the acceptability of the presently-installed configuration has been added,to the EEQ Package N36 files. RG&E does not consider that any additional corrective 'action is warranted.

2. Raychem Minimum Seal Length and Bend Radius As stated in Enclosure 5 of RG&E's 3/6/87 letter concerning Inspection 50-244/87-03< RG&E does not belie've that the RG&E installations were violations of 10CFR50.49. The specif ied Raychem bend radius and overlap specificatxons were considered recommendations< not requirements. Based on RG&E experience with similar configurations< RG&E was confident that the installed configurations were acceptable. Based on IEIN 86-53> RG&E was made aware of industry-wide concern with these recommendationsi

0 and promptly initiated a plan for actual LOCA qualification testing. As expected< the test results were acceptable. These qualification reports have been incoroorated into EEQ Package 512 files. It is not considered that any additional corrective action is warranted.

3. Coleman Cable Insulation Resistance As noted in Enclosure 3 to RG&E's March 6> 1987 letter relative to Inspection 50-244/87-03< RGSE considered that the combination of testing and materials analysis in Package 513 provided reasonable assurance that the, cable would be able to perform its required function. This conclusion was also reached by the NRC and FRC in FRC TER C5257-454. Nonetheless~ RGGE performed additional confirmatory testing< including measurements of leakage current<

which demonstrated performance suit'able for instrumentation circuits during DBE conditions. This test report has been included in RGSE's EEQ Package N13. No additional corrective action is considered necessary.