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Requests Supplemental Response Describing Util Corrective Actions & Date of Full Compliance,Per Insp Rept 50-302/89-18
	ML20058Q200
Person / Time
Site:	Crystal River
Issue date:	07/31/1990
From:	Merschoff E; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Beard P; FLORIDA POWER CORP.
References
	NUDOCS 9008210152
	Download: ML20058Q200 (5)
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July 31, 1990.

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Florida Power Corporation

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Mr. Percy M. Beard, Jr.

Senior,Vice President, Nuclear

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Operations

ATTN: Manager, Nuclear'0perations

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Licensing

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P. O.-Box 219-NA-21

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Crystal River,-.FL 32629

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- Gentlemen:

SUBJECT: 'NRC INSPECTION REPORT NO. 50-302/89-18

Thank you-_for your response of September 20, 1989, to our Notice of-Violation

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Lissued on August = 21,1989, concerning activities conducted at ,your Crystal;

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-River facility.

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We have completed our evaluation of your response to Violation B and 'have

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concluded, for the reasons presented in the enclosure' to this letter, that- the

violation occurred as stated- in the Notice of Violation. ' Therefore , - in t

accordance <with, the requirements of- 10 CFR 2.201, and within 30 days? of the.

date of- this letter, please submit a supplemental response describing; your

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corrective actions and date of full compliance.

.Should you have any questions concerning this letter, we would be. happy te meet

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with you and discuss the matter.

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Sincerely;

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Origir , signed by

Caudle A. Julian

Ellis W. Merschoff, Acting Director-

Division of-Reactor Safety-

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Enclosure:

Staff Evaluation of Licensee

Resp,onse

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Gary L. Boldt

Vicel President, Nuclear Production

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P. O. Box 219-SA-2C

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General Counsel

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State ~ Planning and Development

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ENCLOSURE

STAFF E MLUATION OF LICENSEE RESPONSE

DATED SEPTEMBER 20, 1989

Our assessment of_ your reasons for denial of the violation is as follows:

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a.

The requirements anc overall intent for performing Type B testing are

stated in \\0 CFR 50, Appendix J. Paragraphs II.G, d. '.1, II.G.2, II.G.3, .

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and II.G.4.

These paragraphs define the following overall requirements'

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for testing:

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Type 6 tests are intended to detect local leaks and to measure

leakage across each pressure-containing or leakage-limiting boundary

for any primary containment penetration subject to leakage.

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Electrical. penetrations penetrating containment and employing sealing'

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mechanisms as presure-containing or leakage limiting boundaries are

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subject to Type L testing.

The classification of seals called sealant

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compounds, includes any compound used to form a leakage-limiting boundary.

It may be hard setting or resilient since, if. resilient,-it simply falls

.into the category called resilient seals.

The classification of seals called flexible metal seal assemblies includes

those seals which employ a metal 'to metal assembly which, under force,

forms mating surfaces which act as a pressure-containing, leakage-limiting

boundary.

Whether such an assembly is flexible, non-flexible,- or

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malleable is . immaterial.

If flexibility. is construed to be an essential

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characteristic of the category. of seals called flexible metal seal

assemblies, non-flexible . metal seal assemblies 'must still be Type B

tested.

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b.

In their response, the licensee attempts to relate sealant compounds to

adhesive agents such as wax, paraffin, or putty.

Within the context of

.the -regulations,--it .is clear that 'the term sealant compounds does not

' refer to such agents since these materials could not withstand containment

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pressures under accident conditions.

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c.

In their response, the licensee states that polysulfone is not a resilient .

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material and provides a statement from-the vendor to this effect. -In our.

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discussions with the vendor's chief engineer on October 16, 1989, we

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determined this is not a hard and fast position.

In fact, we have

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' observed several . examples where the polysulfone plugs are identified as

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resilient seals in Conax vendor manuals and in literature describing

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. design features of the Conax assembly. While the material has properties

that are difficult to classify, the vendor also agreed that the material

is a compound used as a seal (sealant compound).

In the context of the

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regulations, polysulfone is considered a sealant compound and by Cenax

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literature may also be considered a resilient seal.

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'In,their! response, the licensee' denied that the cap'and ferrule assembly.

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We-agree'with this statement.

As indicated in the report,

flexible was considered only in the' sense that the material was deformable-

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and was _ not intended to. imply a flexible joint. -The cap and ferrule'

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assembly used by Conax would logically fall into.the classification of a

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flexible metal seal assembly where flexibility- is not considered- a key

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element.

We. reemphasize that while paragraphs II.G.1, II.G.2 and II.G.3 identify-

several commonly used, broad classifications of seals which must be Type B-

tested, they do' not exclude other types of seals which are pressure-

containing, leakage-limiting boundaries from Type B testing.

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e.

In their response, the licensee states that the Technical Specifications

(TS)- excluded electrical penetrations from those requiring _ Type B testing.

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TS'4.6.1.2:.d requires testing in accordance with 10 CFR 50 Appendix J and

the omission of electrical penetrations from the-TS does not constitute a

request for' exemption .

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-In their response, the licensee states. that the _ Final Safety Analysis

Report (FSAR), Section 5.6.4.2, describes how they comply with 10 CFR 50

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Appendix J requirements for . Type B testing.

With the exception of the

last sentence, the FSAR addresses only resilient seals and gaskets.

The;

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one sentence about electrical penetrations is deceptive in that it can1be

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. read; to imply that. potential leakage paths through the penetrations are

sealed with steel to steel-welds.

The cap and ferrule assembly is not

described.

Since the last sentence is vague and because of the licensee's

commitment to perform-testing in accordance with Appendix J. it cannot be

construed as an exemption from testing electrical penetrations.-

In summary, we concluded that Type B testing of Conax electrical penetrations

-is required and'that the violation is correct as written.

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ML20058Q200

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