ML20207T201
| ML20207T201 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 03/17/1987 |
| From: | Hinson C Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8703230303 | |
| Download: ML20207T201 (10) | |
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-[ o NUCLEAR REGULATORY COMMISSION e 5 wAsNeesoTON, D. C. 20006 March 17, 1987 Docket No. 50-1 5 a .
LICENSEE: Consumers Power Company FACILITY: Big Rock Point Plant
SUBJECT:
BACKGROUND AND MEETING 5lMIARY OF MARCH 3 AND 4, 1987 MEETING WITH CONSUMERS POWER COMPANY TO DISCUSS THE ENVIRONMENTAL QUALIFICATION OF SAFETY-RELATED ELECTRICAL EQUIPMENT CA8LES On Tuesday, March 3, and Wednesday, March 4, 1987, the staff met with Consumers Power Company personnel (the licensee) from the Big Rock Point Plant (BRP), and Region !!! personnel to discuss the environmental qualification of Butyl rubber andpolyethylene(PE)insulatedcablesinstalledatBRP. A list of attendees at these meetings is included as Attachment 1.
EEEEE On March 14, 1984, a meeting was held with the licensee to discuss their proposed method of resciution of environmental qualification (EQ) deficiencies identified in the staff Safety Evaluation Report (SER) dated April 26,1983 and the Franklin Research Center Technical Evaluation Report dated February 18, 1983. Some of the approaches described by the licensee for addressing and resolving the identified deficiencies included replacing equipment, perfoming additional analyses, obtaining additional qualification documentation, and detemining that some equipment is outside the scope of 10 CFR 50.49, and, therefore, not required to be environmentally evalified. As a result of the March 14, 1984 meeting, the NRR staff conducted an audit of the licensee's EQ files on June 5 through 7, 1984. On the basis of this audit and additional meetings with the licensee, the staff issued an SER on November 15, 1985 stating that the licensee's EQ Program "is in compliance with the requirements of 10 CFR 50.49, that the proposed resolution for each of the environmental cualification deficiencies identified for Big Rock Point is acceptable, an< that continued operation of Big Rock Point will not present undue risk to the public health and safety." This SER also stated that the EQ files will be re audited by the staff during follow-up inspections to be performed by Region !!! to verify that they contain the appropriate analyset and other necessary documentation to support the licensee's conclusions that the equipment is qualified.
During the week of September 15 throufih 19,1986, Region !!! conducted an inspection of the Itcensee's program for establishing and maintaining the qualification of electrical equipment within the scope of 10 CFR 50.49.
Although the resulting inspection report of November 4,1986 (No. 50-155/
860!3(0RS)) detemined that the licensee had implemented a program to meet the requirements of 10 CFR 50.49, this report identified several Potential Enforcement / Unresolved Items.
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One of these items concerned qualification of Butyl rubber and PE insulated cables at BRP. The NRC audit team observed that the licensee had not perfomed testing of.similar or identical kinds of PE or Butyl rubber insulated cables, but had attempted ~to qualify them through reference to an analysis of generic industry tests of PE and Butyl rubber insulated cables. The licensee stated that tests of identical cables could not be perfomed due to a lack of sufficient plant records needed to locate and obtain identical samples from their plant. After reviewing the Ifcensee's generic qualification of these cables, Region !!! determined that the PE and Butyl rubber insulated cables installed at BRP were unqualified due to the failure of the licensee to esteh11sh adequate similarity between the tested cables in the generic reports and the plant cables.
Meetine Susunary - March 3.1987 On February 26, 1987, after NRR staff had reviewed the cable EQ findings of the November 4,1986 inspection report with Region !!!, the staff infomed the licensee that they would like to meet with the licensee to discuss EQ of the cables identified in the inspection re port. A pre-meeting was scheduled for the afternoon of March 3, 1987 with BRD licensino personnel, Region !!!, and NRR and IE staff. This was to discuss the techn' cal merits of the licensee's similarity arguments showing that the Butyl rubber and PE insulated cables in question were qualified. The licensee stated that their PE insulated cables were obtained from General Electric (GE), General Cable, and Anaconda, while their Butyl rubber insulated cables came from GE and Anaconda. The following safety systems needed to mitigate a loss of coolant accident (LOCA) at BRP contain these types of cablest Reactor Protection System, Containment Isolation System. Primary Enclosure Spray Actuation System, Primary Core Spray System, Post Incident Cooling System, and the lack-up Enclosure Spray System.
Of the several approaches available to the licensee for qualification of their PE and Butyl rubber insulated cables (replacement of present cable with qualified cable, successful qualification testing of each of the five types of cable at BRP, or proof of similarity between cables described in qualification testsreportsandthoseactuallyinstaIIedatBRP),thelicenseechosetouse the similarity approach. The licensee stated that since the September 1986 It audit,theyhavelocatedthePurchaseOrders(P0s)forthefivetypesofcable in question. These P0s provide detailed information on the installed cables, including material composition, insulation thickness, and jacket thickness.
In order to show that these installed cables were qualified according to the 00R Guidelines, the licensee obtained test reports for similar cables which had been qualifted.
As a basis for qualification of the PE insulated cables manufactured by GE, General Cable, and Anaconda which are installed at BRP, the licensee cited a test done by Wyle Laboratories on a PE cable from Plastics Wire and Cabis Company. This test had been performed by Wyle for the Tennessee Valley Authority (TVA)forcableinstalledatBrownsFerry. Although the physical description of the PE cables in the TVA report matched the description of the PE cables installed at BRP, the staff stated that since the PE caples in the
I test report were manufactured by a different manufacturer, similarity of the tested cables to those installed at BRP had not been demonstrated. The staff stated the. formulation (which includes material, manufacturing process, and fabrication)'of the cables must also be shown to be similar, and that BRP's electrical equiprent qualification (EEQ) files do not contain sufficient information to establish such a similarity link.
The licensee cited an IEEE Transactions paper of April 1186 as a basis for qualification of the Butyl rubber insulated cables manuftetured by GE and General Cable which are installed at BRP. This paper contained limited test data on one styrene-butadiene synthetic rubber based insulation, per IPCEA 5-19-81 Section 3.15 and 3.16. The staff said that because the formulation for the cable listed in the IEEE report differs from those of the cables in the plant, and because the test conditions in the IEEE report are unknown, this report cannot be used to establish adequate similarity in accordance with the D0R Guidelines to the Butyl rubber insul6ted cables in the plant.
The licensee said that since the IE E0 audit in September 1986, they have been able to show that the PE and Butyl rubber insulated cables at BRP were constructed according to IPCEA standards. The staff said that this is not a sufficient basis for establishing cable qualification.
The staff consensus was that the licensee has not provided sufficient data to established a clear link between qualified cables and the PE and Butyl rubber insulated cables installed in the plant. The staff said that it would be very difficult for the licensee to qualify their cables using a similarity argument because the licensee would have to obtain acceptable qualification test reports for cables which had identical electrical, mechanical, and chemical properties as the PE and Butyl rubber insulated cables installed at BRP. The fact that the cable marufacturers are no longer manufacturing similar cables makes the probability of obtaining an acceptable test report very unlikely.
The other two alternatives to qualifying the PE and Butyl rubber insulated cables at BRP are to replace these cables with qualified cables or to take samples of each of the five vendor / cable varieties and subject these cables to environmental qualification tests duplicating the worst case conditions for an accident at BRP. The licensee stated that they considered these two alternatives not to be cost effective, and they would still want to be able to prove the acceptability of the cables using a similarity test.
Peetina Summary - March 4. 1987 This meeting was attended by the same people who were at the March 3. 1987 meeting with the addition of NRC and BRP management personnel (Attachment 1).
The licensee briefly described the history of EQ issues at BRP (Attachment 2).
They said that since the !E EQ audit conducted in September 19M . they have located the procurement documents for the PE and Butyl rubber insulated cables which were identified in the inspection report as being unqualified. They said that they believed the information provided by these documents established adequate similarity between the qualified cables and the cables installed at BRP.
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I As discussed in the March 3,1987 meeting, the staff said that the licensee still had not identified a clear link between qualified cable and the cable installed at:BRP.. The staff would be satisfied if the licensee could obtain qualification tests for cable by the same manufacturer with the same formulation. When asked if the staff has ever accepted a similarity test for cable from other than the same manufacturer, the staff said that this had been done in two instances, for Browns Ferry and Fort St. Vrain. The test for Browns Ferry involved qualification in a semi-harsh environment where the temperature did not exceed 180*F (vs 240* for BRP). Fort St. Vrain's test involved very benign conditions with no integrated radiation exposure. In both cases, the test environments were milder than the post LOCA environment for BRP.
With respect to the alternative of taking cable samples from the plant and subjecting them to qualification testing, the licensee said this was not a viable alternative due to the number of samples that would have to be removed. The staff said that an acceptable qualification test could consist of subjecting one representative sample from each vendor / cable type to a harsh environment which bounds the harshest environment seen by any of the cable types.
At this point the staff and licensee caucused separately to discuss the licentee's options. Upon reconvening, the staff told the licensee that it had three options to choose from that would resolve the staff's cable EQ concerns.
- 1) Perform qualification tests on each of the five vendor /cabic types in question to assure acceptability,
- 2) Replace all of the cable in question, or
- 3) Collect additional test or qualification data to show cable similarity.
The licensee said that they will need three to four weeks to compare the costs involved with each of the three alternatives before they can reach a decision on which of the three options to choose. The staff said that the licensee would have thirty days from the date of startup to choose one of the three optionsandtosubmitadetailedprogramplan(includingtimeschedules)to the NRC describing how the licensee plans to accomplish this option and how it will resolve the staff's cable EQ concerns. The staff will review this submittal in detail and again meet with the licensee to discuss the acceptability of the chosen alternative.
In the interim, and prior to plant restart (scheduled for March 7,1987), the licensee must submit a Justification for Continue Operation (JCO) for the specific EEQ components which rely on the cable types in question. This JC0 should assume that all of the cables in question fail when exposed to the harsh environment following a LOCA and it should identify what backup systems are available to safely shut the plant down. NRR and Region III staff connitted to evaluate the licensee's JC0 immediately upon receipt. The licensee agreed to prepare and submit this JC0 to both NRR and Region III staff by March 6, 1987, one day prior to the planned restart of BRP from the current refueling outage.
The meeting was adjourned at 3:30 pm.
Original signed by Charles S. Hinson, Project Manager BWR Project Directorate #1 Division of BWR Licensing Attachments:
As stated cc w/ attachments:
See next page 9
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9 Mr. Kenneth W. Berry Consumers Power Company Big Rock Point Plant I
CC: .
Mr. Thomas A. McNish, Secretary Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Judd L. Bacon Esquire Consumers Power Company .
212 West Michigan Avenue Jackson, Michigan 49201 Big Rock Point Plant ATTN: Mr. David P. Hoffman Plant Superintendent 10269 U.S. 31 North Charlevoix, Michigan 49720 Mr. Bud Heeres County Commissioner 303 Sheridan '
Charlevoix, Michigan 49720 Office of the Governor Room 1 - Capitol Building Lansing, Michigan 48913 Regional Administrator Nuclear Regulatory Commission, Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Nuclear Facilities and Environmental Monitoring Section Office Division of Radiological Health P. O. Box 30035 Lansing, Michigan 48909 l U.S. Nuclear Regulatory Commission Resident Inspector Office
- Big Rock Point Plant
. 10253 U.S. 31 North Charlevoix, Michigan 49720 4
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4 Attachment 1 Attendees Meeting with Consumers Power Company
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on Equipment Qualification of Cables March 4. 1987, 1:30 pm Name Title & Affiliation Charles Hinson* BRP Project Manager - NRR/ DBL /BWD1 Angelo Marinos* NRR/ DBL /EICSB J. Donohew NRR/ DBL /BWD1 Anil S. Gautam* EQ Lead /RIII/DRS Stephen Guthrie NRC/Sr. Res. Insp., Big Rock Point Paul Shemanski NRR/PWR-B/PEICSB Nick Chrissotimos Acting Director /DRS/RIII Bob Alexander
- BRP - Tech. Enc.
Dave Hoffman BRP - Plant Supt.
George Hubbard* NRC/IE/VPB Uldis Potapovs* NRC/IE/VPB '
Max Yost Engineer /INEL
- 1. Gus Lainas NRR/ DBL Bob Bernero NRR/ DBL Bob LaGrange NRR/ DBL /EB Tom Rotella* NRR/ DBL /8WD1 Ron Gardner* Chief /PSS/DRS/RIII Hukam Garg* NRR/ DBL /EICSB Edward M. Evans
- BRP - Engineering Ralph R. Frisch CPC0 Licensing
- Attended March 3, 1987 meeting also.
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- I k nhy s. Cc.L y c, ATTACHMENT 2
} BRP - ELECTRICAL EQUIPMENT QUALITICATION 1975 LOCA Task Force Proposed RDS Modification raised EEQ concerns j
CPCo Voluntarily Shutdown BRP on 1/16/75 6 month outage to qualify electrical components Results provided in Special Report #21 NRC supported actions taken in letter dated 5/30/75 Systematic Evaluation Program (SEP)
NRC requested EEQ information in letters dated 12/23/77 and 9/6/78 (SEP Topic III-12)
Request information provided in letters dated 11/30/78 and 10/31/80 CPCo performed detailed walkdown of EEQ schemes and provided revision to EEQ submittal on 1/30/81 NRC Review and Evaluation CPCo received FRC Evaluation Report and NRCs SER dated 5/28/81 ;
CPCo issued revision 2 to the EEQ submittal on 3/15/82 to address "TER" concerns and provide component JCOs.
CPCo letter dated 4/30/82, discussed resolution of " Aging" issue and use of PRA to evaluate equipment replacement commitments.
j CPCo received 2nd FRC Evaluation Report and NRCs SER on 4/26/83 I
l CPCo letter of 5/31/83 provides response to the 4/26/83 letter and also states that comprehensive review of EEQ program and required actions will be included in the Intearated Assessment Program.
Integrated Assessment Program (EEQ)
Appx X of the BRP PRA discusses EEQ aspects of component failures (3/31/81) l l
NRC letter 3/11/83 summarizes NRC endorsement of Integrated Assessment of all open licensing issues.
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CPCq 1etter of 6/1/83 provides Integrated Assessment of open issues including the following with regard to EEQ.
- Use of Failure Modes and Effects Analysis *
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- disposition of EEQ parameter issues
- disposition of " aging" concerns l-l The submittal also states that, "the above scope replaces all previous i EEQ commitments". ,
NUREG-0828, Integrated Plant Safety Assessment Report (Sept, 1983) provides NRC approval of amended program for EEQ resolution.
CPCo letter of 9/30/83, submits FM&EA for resolution of open EEQ component deficiencies.
NRC Review and Evaluation 4
NRC letter of 3/26/84, summarized 3/14/84 meeting and required actions.
NRC meeting of 6/7/84, raised additional concerns with CPCo approach to EEQ.
Recent EEQ Program Activities CPCo letter of 6/29/84, requests scheduling exemption and commits to a re-review of the BRP EEQ files.
NRC letter of 8/8/84, transmits results of EEQ Audit which concluded inadequate files and recommends use of a consultant.
f CPCo letter of 8/27/84, notified NRC that a consultant (DeBenedetto Associates) has been retained and provides response to questions in letters dated 7/19/84 and 8/8/84.
CPCo letter of 10/31/84 provides description of revised EEQ program, i resolution of TER deficiencies, and submittal of JCOs. This program represented significant change from IPSAR effort.
CPCo letter of 1/7/85 provides additional information requested by NRC.
WPC granted extension until the end of 1985 Refueling Outage on 3/27/85.
NRC SER dated 11/15/85 concluded EEQ program in compliance with 10 CFR 50.49.
MIO387-0092A-BX01
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4 Distribution for Meeino Su mary Dated: March 17,1987 Facility: B: 9 Rock Point Plant ,
i Decket' File ~ (50-155)'"'O
'NRC PDR'"""
Local PDR 1 .
BWD1 Reading
R. Bernero/R. Houston J. Zwolinski J. Donohew-C. Jamerson C. Hinson R. Auluck OGC-BETH(InfoOnly)
E. Jordan B. Grimes ACRS (10)
D. Vassallo' C. Grimes.
G. Lainas/B. D. Liaw G. Hulman. .
E. Marinos W. Hodges BRP File-Copies sent to persons on facility service list
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