ML20212C905
| ML20212C905 | |
| Person / Time | |
|---|---|
| Issue date: | 12/23/1986 |
| From: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Garde B GOVERNMENT ACCOUNTABILITY PROJECT |
| References | |
| REF-QA-99900277 IEIN-84-44, NUDOCS 8612310227 | |
| Download: ML20212C905 (5) | |
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DEC 2 31986 Ms. Billie Pirner Garde Director, Mid-West Office Government Accountability Project Midwest Office 3424 Marcos Lane Appleton, Wisconsin E4911
Dear Ms. Garde:
Your letter dated November 24, 1986 requested answers to nine questions regard-ing electrical equipment qualification of Rockbestos cable. A restatement of your questions and the answers are provided below.
Question 1 - What is a " mild" environment? This is not a precise engineering term.
Answer 1 - The Code of Federal Regulations,10 CFR 50.49, defines " mild" environment as an environment that would at no time be significantly more severe than the environment that would occur during normal plant operation, including anticipated operational occurrences.
Question 2 - What were the objections of the Enforcement Division to recommen-dations from the Design Engineering Division and others for specific followup for all licensees employing Rockbestos cable?
Answer 2 - The Enforcement Staff did not " object" to proposed NRC recomenda-tions to licensees for followup on Rockbestos cable. The Enforcement Staff did comment on a draft infonnation notice regarding this matter. Those comments were provided to you as part of a Freedom of Information Act submittal (F0IA 84-441) and are available in the PDR under accession number 8501240119. Such comments are an integral part of development of information notices.
Question 3 - What was the reasoning behind issuing an Information Notice rather than a Bulletin?
A veer 3 - A decision was made by the staff to issue an information notice rather than a bulletin because (1) no failures of Rockbestos cable had been reported from any nuclear power plant, (2) the manufacturer had committed to conducting a retest program, involving all cables in question, including new test equipment and revised test procedures, and (3) testing of Rockbestos cable had been performed by other organizations such as Franklin Research Corporation and Sandia Laboratories and the cable was found to be qualifiable.
Question 4 - The file does not include a final information notice. Was there any change in werding from the draft transmitted to Noonan and Baer by James G.
Partlow on February 7, 19847 8612310227 861223 PDR ORO NEXD
Billie Pirner Garde Answer 4 - Yes, changes were made and the final version, IE Information Notice No. 84-44, " Environmental Qualification Testing of Rockbestos Cables," was issued on June 8, 1984. Information Notices are routinely distributed to the Public Document Room. A copy of IE Information Notice No. 84-44 is enclosed for your information.
Question 5 - Have subsequent inspections shown Rockbestos to be meeting the qualification test methods desired by the NRC? l Answer 5 - As part of its corrective action in response to the NRC-identified deficiencies in its qualification program, Rockbestos has been requalifying its Class 1E cable in accordance with the applicable industry standards and quality assurance requirements. NRC has been monitoring the performance of the requal-ification tests at Rockbestos by reviewing test plans, observing selected phases of the actual tests, examining test samples, and reviewing the test results. NRC inspectors have concluded that proper test procedures, practices, and quality assurance were employed by Rockbestos throughout the requalifica-tion program and that no conditions were noted that would invalidate this testing or affect the credibility of the test results or conclusions. Results to date have supported qualification of Rockbestos cable for the specified environmental conditions.
Question 6 - Have the design errors in the SNUPPS reactors respecting Rockbestos cable been corrected at Wolf Creek and Callaway as recommended by Bechtel? This ccrrection required installation of a junction box and several feet of high temperature cable from the solenoid operated valve to tha junction box.
Answer 6 - The Valcor valve and extension wire deficiency was corrected at Wolf Creek and Callaway nuclear power plants. NRC Inspection Report 50-283/84-049 dated April 4,1985, page 3, discusses the NRC inspection and closecut of that deficiency for the Callaway plant. NRC Inspection Report 50-482/84-49 dated January 18, 1985, page 31, discusses the NRC inspection and closecut of that deficiency for the Wolf Creek plant.
Question 7 - Are there established reporting procedures to the hRC for correct-ing design errors?
Answer 7 - The Code of Federal Regulations,10 CFR Part 21, requires licensees, vendors, suppliers, and/or designers to notify the NRC immediately of any deficiency (including defects or design errors) of a component when that component is used in an application (such as safety system) where failure would compromise the health and safety of the public by creating a substantial safety hazard if that component failed to provide the service function intended. In addition,10 CFR 50.72 and 50.73 require licensees to notify the NRC of condi-tions that could prevent fulfillment of certain safety functions including discovery of design, analysis, fabrication construction or procedural inadequacies.
a Billie Pirner Garde Question 8 - Are there systematic procedures in place to ferret out all design and construction errors affecting safety before a plant goes on line?
Answer 8 - The NRC requires preoperational, hot functional, and startup testing of components and systems before a nuclear power plant goes operational. These test procedures and test results are reviewed by NRC staff for adequacy, accuracy, and functional performance before initial plant startup. In fact, the licersee and plant constructor perform walkdowns and as-built verification to plant specifications before a plant can start an initial approach to criti-cality. Also, a turnover of any component or system from the plant constructor to licensee requires an inspection by the licensee to verify the adequacy of those components or systems to meet the service intended, including the design requirements specified. All of these efforts are reviewed through a rigorous inspection program by the NRC staff during the life of the plant.
Question 9 - RE: NRC's letter to Representative Dan Glickman dated June 5, 1984: " Simultaneous" failure of control valves on each of two essential service water trains may not be credible, but would failure of the second valve be replaced to regain the desired backup condition?
Answer 9 - A failure of an individual valve in this application would be evident by loss of normal system operation such as flow, temperature, differen-l tial pressure, and the like. Technical Specifications require correction of a failure within the essential service water system at the Wolf Creek plant to meet the limiting condition of operation (LCO). In this case, the LC0 at Wolf l Creek requires the failure to be corrected or have the plant in hot standby condition within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and cold shutdown condition within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />, if the failure has not been corrected.
I believe this is responsive to your questions to help you to complete your review and investigation.
R Origgge[1gpeti bg Victor Stellef ,
VictorStel'15Jr.
Executive Director for Operations
Enclosure:
IE Information Notice 84-44 Distribution:
VStello, EDO JMTaylor, IE RWStarostecki, IE ELJordan, IE SASchwartz, IE RLBaer, IE AWDromerick, IE VDThomas, IE JGPartlow, IE BKGrimes, IE JAAxelrad, IE TRehm, ED0 HRDenton, IE JPMurray, ELD TEMurley, RI JNGrace, RII JGKeppler, RIII RDMartin, RIV JBMartin, RV MLReardon, IE ED0 #002353 CDelsio 86-650 PDR - 'DCS " '
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Billie Pirner Garde addition,10 CFR 50.72 and 50.73 require licensees to notify the NRC of condi-tions that could prevent fulfillment of certain safety functions including
. discovery of design, analysis, fabrication construction or procedural inadequacies.
Question 8 - Are there systematic procedures in place to ferret out all design and construction errors affecting safety before a plant goes on line?
Answer 8 - The NRC requires preoperational, hot functional, and startup testing of components and systems before a nuclear power plant goes operational. These test procedures ^and test results are reviewed by NRC staff for adequacy, accuracy, and functional performance before initial plant startup. In fact, the licensee and plant constructor perform walkdowns and as-built verification to plant specifications before a plant can start an initial approach to criti-cality. Also, a turnover of any component or system from the plant constructor to licensee requires an insp:ction by the licensee to verify the adequacy of those components or systems to meet the servlce intended, including the design requirements specified. All of these efforts are reviewed through a rigorous inspection program by the NRC staff during t le life of the plant.
Question 9 - RE: NRC's letter to Represent tive Dan Glickman dated June 5, 1984: " Simultaneous" failure of control y ves on each of two essential service water trains may not be' credible, ut would failure of the second valve be replaced to regain the desired' backup ondition?
Answer 9 - A failure of an individu va ve in this application would be evident by loss of normal system opera n such as flow, temperature, differen-tial pressure, and the like. Technical ecifications require correction of a failure within the essential service w t system at the Wolf Creek plant to meet the limiting condition of operati n ( ). In this case, the LC0 at Wolf Creek requires the failure to be corr cted have the plant in hot standby condition within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and cold sh tdown co ition within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />, if the failure has not been rrected.
I believe this is responsive to yo r questions to lp you to complete your review and investigation.
/
/ N Sincerely, Victor Stello, Jr.
Executive Director for Operations Distribution:
VStello, EDO JMTaylor, IE RWStarostecki, IE ELJordan, IE SASchwartz, IE RLBaer, IE AWDromerick, IE VDThomas, IE JGPartlow, IE BKGrimes, IE JAAxelrad, IE TRehm, ED0 HRDenton, IE JPMurray, ELD TEMurley, RI JNGrace, RII JGKeppler, RIII RDMartin, RIV JBMartin, RV MLReardon, IE ED0 #002353 CDelsio 86-650 PDR DCS DEPER R/F EGCB R/F VDThomas R/F
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Billie Pirner Garde Question 8 - Are there systematic procedures in place to ferret out all design and construction errors affecting safety before a plant goes on line?
Answer 8 - The NRC requires preoperational, hot functional, and startup testing of components and systems before a nuclear power plant goes operational. These test procedures and test results are reviewed by NRC staff for adequacy, accuracy, and functional perfonnance before initial plant startup. In fact, the licensee and plant constructor perform walkdowns and as-built verification to plant specifications before a plant can start an initial approach to criti-cality. Also, a tu nover of any component or system from the plant constructor to licensee requires an inspection by the licensee to verify the adequacy of those components or s stems to meet the service intended, including the design requirements specified. All of these efforts are reviewed and continuously monitored through a rigo ous inspection program by the NRC staff during the life of the plant. f Question 9 - RE: NRC's lette tpRepresentapt Dan Glickman dated June 5, 1984: " Simultaneous" failure f control y lves on each of two essential service water trains may not be credible but would failure of the second valve be. replaced to regain the desire bac p condition?
Answer 9 - A failure of an indi 1 valve in this application would be evident by loss of normal em op ation such as flow, temperature, differen-tial pressure, and e. Techni i Specifications require correction of a failure within the essential service ter system at the Wolf Creek plant to meet the limiting condition of operati (LC0). In this case, tha LC0 at Wolf Creek requires the failure to be correc d or have the plant in hot standby condition within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and cold shutdo condition within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />, if the failure has not been correc d.
I believe this will meet your needs to comp te your review and investigation.
Sincerely, Victor Stello, Jr.
Executive Director for Operations Distribution:
VStello, ED0 JMTaylor, IE RWStarostecki, IE ELJordan, IE SASchwartz, IE RLBaer, IE AWDromerick, IE VDThomas, IE JGPartlow, IE BKGrimes, IE JAAxelrad, IE TRehm, ED0 HRDenton, IE JPMurray, ELD TEMurley, RI JNGrace, RII JGKeppler, RIII RDMartin, RIV JBMartin, RV MLReardon, IE EDO #002353 CDelsio 86-650 PDR DCS DEPER R/F EGCB R/F VDThomas R/F DD:IE D:IE EDO RWStarostecki JMTaylor VStello '
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