Text

Forwards Addl Info Re Bunker Ramo Instrumentation Penetration Modules,Per 890131 Request.Util Believes That Modules Environmentally Qualified in Accordance w/10CFR50.49 & NUREG-0588,Category II
	ML20245D962
Person / Time
Site:	Byron, Arkansas Nuclear, Braidwood, San Onofre, Midland, LaSalle, 05000000
Issue date:	04/28/1989
From:	Hunsader S; COMMONWEALTH EDISON CO.
To:	Murley T; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation
Shared Package
ML20245D268	List: ML20245D266; ML20245D397; ML20245D962;
References
	RTR-NUREG-0588, RTR-NUREG-588 NUDOCS 8905010249
	Download: ML20245D962 (21)
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/ Address Reply to: Post Office Box 77 '

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Chicago, Illinois tiO690 - 0767 April 28, 1989 i

1 Dr. Thomas E. Murley, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commiss2on Washington, DC 20555 i

1 Actn Document Control Desk

Subject:

LaSalle Unit 2 Bunker Ramo Instrumentation Penetration Modules NRC Docket Nos. 50-374 References (a) January 31, 1989 G. Holahen letter to H.E.

Bliss

Dear Dr. Murley:

In reference (a) the NRC staf f stated that without additional information regarding IR values recorded during peak LOCA temperatures and the test conditions when the lowest value was recorded, there is insufficient test data and supporting analysis to demonstrate functional operability of the Bunker Ramo penetrations during design basis event conditions.

Reference (a) requested that Commonwealth Edison (Edison) address this concern and furnish our plans and schedule to either qualify, test or replace the subject penetrations with ones which have been previously demonstrated to be qualified.

In response to this request, Edison met with the NRC staf f on April 25,~1989 at the NRC White F1'.nt offices to present the bases for Edison's position that the Bunker Ramo modulos for the LaSalle Unit 2 are environmentally qualified for the plant specific application.

In that meeting, Edison presented additional information thSt Edison believes i

addressed the NRC concerns.

Attachment "A" presents the details of that which was presented and discussed.

In summary Edison believes that the Bunker Ramo Modules are environmentally gi.ellfled in accordance with 10 CFR 50.49 and NUREG 0588, Category II.

As a result, the modules will be retained in the plant until the completion of their qualified life.

Please address any questions concerning this matter to this office.

S.C. Hensader

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8905010249 890428 PDR ADOCK 05000374 P

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R. Gardner-RIII Resident Inspector-LaSalle

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q LASALLE COUNTY STATION - UNIT 2 ENVIRONMENTAL QUALIFICATION OF BUNKER RAMD AMPHENOL PENETRATIONS RESPONSE TO NRC STAFF CONCERNS PREPARED BY COMPONENT QUALIFICATION DIVISION l

COD-042965 l

April 25, 1989 l

e ENVIRONMENTAL QUALIFICATION BUNKER RAM 0 PENETRATIONS

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e LASALLE BUNKER RAMO PENETRATIONS ARE QUALIFIED TO NUREG 0588, CAT II REQUIREMENTS e

ONLY THERMOCOUPLE AND RESISTANCE TEMPERATURE DETECTORS (RTDs) ARE CONNECTED TO THE BUNKER RAMO PENETRATION MODULES.

e LASALLE PENETRATIONS QUALIFIED BY AN UNIQUE TEST (TEST REPORT 123-2183, REVISION 04) e LASALLE ACCEPTABLE IR REQUIREMENTS ARE IN Kn NOT Mn,

e NRC LETTER, DATED JANUARY 31, 1989.

REQUESTED IR DATA DURING PEAK LOCA TEMPERATURE, CECO PERFORMED A TEST FOR BRAIDWOOD APPLICATION AT WYLE LABS e

(WYLE REPORT 170404-1, DATED FEBRUARY 24, 1989).

THE BRAIDWOOD TEST MODULES HAVE IDENTICAL MATERIALS AND e

CONSTRUCTION TO THOSE INSTALLED AT LASALLE, THE BRAIDWOOD TEST PEAK DBA TEMPERATURE ENVELOPS LASALLE o

POSTULATED PEAK LOCA TEMPERATURE.

THE BRAIDWOOD TEST LOWEST IR FOR BUNKER DAM 0 PENETRATIONS e

HAS NEGLIGIBLE EFFECT FOR LASALLE APPLICATIONS.

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Page 1 of 16 g

LaSalle County Project No. 8319-02 Environmental Qualification of Bunker-Ramo-Amphenol Penetrations Response to NRC Staff Concerns 1.0 PURPOSE The purpose of this document is threefold:

1.

Identify all Class 1E instrumentation penetrations manufactured by Gunker Ramo Amphenol that are installed at LaSalle County Station.

ii.

Provide a summary of our initial response to NRC concerns on the environmental qualification of Bunker Ramo penetrations.

iii.

Provide adc'4tional test data and justification to NRC's response to our submittal.

2.0 REFERENCES

2.1 LaSalle EQ Binder EQ-LS062 2.2 NRC staf f memorandum dated 04-15-88 identifying ccncerns on the qualification of Bunker Ramo Penetrations.

2.3 NRC letter dated 05-13-88 to CECO identifying concerns regarding the qualification of Bunker Ramo Penetrations installed at LaSalle Unit 2.

2.4 Minimum IR values recorded during LaSalle test of Bunker Ramo j

Penetrations.

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Page 2 of 16' LaSalle County - 2 Project No. 8319-02 i

2.5 IR measurements and time / temperature graph recorded during LaSalle Test.

2.6 NRC Information Notice No. 88-29 "Difficiencies in Primary Containment Low-Voltage Electrical Penetration Assemblies."

2.7 Sunnary LaSalle's Response to NRC concerns given to the staff in a meeting on August 4, 1988 by Nuclear Utility Group.

2.8 Summary of Telecon between the NRC staff and LaSalle engineering staff on the qualification of Bunker Ramo Penetrations installed at LaSalle Unit 2 held on December 1, 1988.

2.9 NRC letter dated January 31, 1989 to CECO regarding the qualification of Bunker Ramo Penetrations installed at LaSalle Unit 2.

2.10 Acceptance of Wyle Test on Bunker Ramo Penetrations for Braidwood by NRC staff.

2.11 Comparison of Bunker Ramo Modules between Braidwood and LaSalle.

2.12 LOCA profiles and measured IR data.

2.13 Bunker Ramo penetration module IR values vs error in suppression pool water temperature.

3.0 ELECTRICAL PENETRATION ASSEMBLIES (EPA) INSTALLED AT LASALLE STATION 3.1 All Electrical Penetration Assemblies (EPA) installed in Unit 1 are manufactured by Conax and are qual 'ied to 10CFR50.49 requirements.

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Page 3 of 16 6

s LaSalle County - 2 Project No. 8319-02 3.2 There are a total of 22 EPAs installed in Unit 2.

Six EPAs are using Conax modules and are qualified to 10CFR50.49 requirements.

Sixteen EPAs are using Bunker Ramo modules. Ot.ly two of these sixteen Bunker Ramo modules are used for Class 1E applications. A listing of all the Unit 2 penetrations, their applications, safety classification and functions are given next.

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LaSalle County - 2 Froject No. 8319-02 Bunker Ramo Instrument Penetrations Installed at LaSalle LaSalle County Station uses Conax electrical modules exclusively in Unit 1 and for Unit 2 both Conax and Bunker Ramo electrical modules are used.

The Unit 2 Bunker Ramo electrical penetrations are identified below:

Penetration Type of Applications Qualification Tag No.

Manufacturer Service Served Requirements

2LV94E Bunker Ramo Instrumentation Drywell Temp.

Pressure and

2 8.V95 E Bunker Ramo Instrumentation Monitoring &

electrical in-Suppression tegrity Pool Temp.

Monitoring 2LV96E Bunker Ramo Control Safety Relief Pressure and 2LV97E Bunker Ramo Control Valves and electrical in-2LV98E Bunker Ramo Control Valve Motor tegrity 2LV99E Bunker Ramo Control Operators 2B33-S301 Bunker Ramo Medium Voltage Pwr Reactor Recirc. Pressure in-2B33-S302 Bunker Ramo Medium Voltage Pwr pumps 2833-tegrity only C001A & B 2C11-S301 Bunker Ramo Instrumentation Control Rod Pressure in-2C11-S302 Bunker Ramo instrumentation Position tegrity only 2C11-5303 Bunker Ramo Instrumentation Indication 2C11-S304 Bunker Ramo Instrumentation 2C51-S301 Bunker Ramo Instrumentation Neutron Pressure in-2C51-S302 Bunker Ramo Instrumentation Monitoring tegrity only 2C51-S303 Bunker Ramo Instrumentation 2C51-5304 Bunker Ramo Instrumentation 2LV92E Conax Instrumentation Pressure &

2LV93E Conax Instrumentation electrical integrity Low Voltage Power Pressure Integrity

( Conaxmodules ]

2AP96E low Voltage Power 2AP97E j

and Pressure & Elec.

Integrity 2AP98E 4 Amphenol 7 Low Voltage Power Pressure & Elec.

Integrity I

2AP99E header Low Voltage Power Pressure Integrity L plate 2 j

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Page 7 of 16 LaSalle County - 2 Project No. 8319-02 Functional Description i

Parameter Type of Instrument Circuit 1.

Drywell Ambient Temperature Thermocouple (TC) 2.

Suppression Pool Water Temperature Resistance Temperature Detector (RTD) 1.

Drywell Ambient Temperature Instrument Nos. (TC):

2TE-CM058 2TE-CM059 2TE-CM060 2TE-CM061 Safety Function These thermocouple are Regulatory Guide 1.97, Type D Category 2 variables. They provide input to two temperature recorders 2TR-CM037 (Div. 1) and 2TR-CM038 (Div. 2). Their sole function is to provide indication of the drywell ambient temperature to the control room operating personnel. They are not required to initiate any of the six safety functions, namely:

Emergency Reactor Shutdown

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Containment Isolation Reactor Core Cooling Containment Heat Removal Reactor Heat Removal Preventing Significant Release of Radioactive Material J

to the Environment i

Page 8 of 16

.o LaSalle County - 2 Project No. 8319-02 0

The recorders are set to provide a high alarm at 140 F.

The recorder 0

range is 0-250 F, As stated above the subject temperature sensors do not provide any inputs to the reactor protection system (RPS) or the emergency core cooling systems (ECCS) to scram the reactor to mitigate the accident which results in high temperature.

2.

Suppression Pool Water Temperature Instrument No. (RTDs):

i 2TE-CM057A.C.D.E.F,G,J,K,M,N,P,R,U,V Safety Function These RTDs are Regulatory Guide 1.97 Type A Category I variables, used to monitor the LOCA suppression pool water temperature. They provide input to two tnperature recorders 2TR-CM037 (Div.1) and 2TR-CM038 0

0 (Div. 2), high alarm and high high alarm inputs at 100 F and 110 F respectively. The proper functioning of these RTDs and related cir-cuits is required for the operator to manually initiate suppression pool cooling via the RHR system.

Most transients that result in addition of heat to the suppression pool are of very short duration and have a small effect on the suppression 1

pool temperature. However, there are depressurization transients which may result in the addition of considerable heat.

In all cases suppres-0 sion pool temperature is maintained below design temperature of 200 F by the RHR system (refer to the Design Assessment Report, Chapter 6).

The suppression pool cooling is initiated when the pool temperature reaches 100 F.

This occurs in less than 10 minutes after an accident.

0 The suppression pool temperature monitors perform the safety function of providing indication to the control room operating personnel.

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3 Page 9 of 16 LaSalle County - 2 Project No. 8319-02 4.0

' QUALIFICATION OF BUNKER-RAMO PENETRATION ASSEMBLIES LaSalle's licensing basis is NUREG 0588 Category II. All Class 1E l

equipment in harsh areas is required to be qualified to NUREG 0588 Category 11 and IEEE 323-1971 requirements.

However, it is. established that the LaSalle Bunker Ramo penetration assemblies meet the perfor-gance requirements consistent with IEEE 323-1974 in addition to ti.e i censing commitments'.

The Unit 2 Bunker Ramo electrical instrumentation penetrations are:

Penetration Type of Applications Qualification Tag No.

Service Served Requirements 2LV94E Instrumentation Drywell Temp.

Maintain containment 2LV95E 1rstrumentation Monitoring &

pressure integrity and Suppression integrity of Pool Temp.

Class 1E Monitoring circuits l

The subject penetration assemblies were procured prior to February 1983. LaSalle EQ binder EQ-L5062 (Ref. 2.1) documents the qualifica-tion of these penetrations per NUREG 0588 Category II requirements l

based on Amphenol test report 123-2183, Rev. 4.

This test was performed uniquely for laSalle's qualification requirements and l ^

represents the installed configuration.

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Page 10 of 16 7, c LaSalle County - 2 Project No. 8319-02 5.0 NRC' CONCERNS DURING THE REGION 111 AUDIT OF BRAIDWOOD 2 BUNKER RAM 0 PENETRATION ASSEMBLIES AND LASALLE COUNTY'S RESPONSE During a Regional EQ inspection at Braidwood 2, conducted in February and March 1988, the NRC staff concluded that Environmental Qual. fica-tion (EQ) had act been adequately demonstrated for the Bunker Ramo Instrumentation Penetrations for the following reasons:

1. Unacceptable insulation resistance values were recorded and identi-fied as " anomalies". Of 81 measurements taken, only 14 were at the 6

design minimJm value of 10 ohms or higher (17%)*. The referenced tests were Braidwood 2 Test Report 123-2220, Rev.

4, dated 10-10-79 and Test Report 123-2159, Rev. 1, datec 06-18-79 (Table V).

Although the suspected " anomalies" were corrected by replacing tenninal blocks with qualified splices, no follow-up testing was conducted to demonstrate qualification.

2. Insulation resistance (IR) readings taken in other tests were not taken at a frequency consistent with IEEE Standard 323-1974.

(Staff concluded one IR measurement taken 8 or 15 to 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months into the test does not demonstrate qualification as discussed in IEEE Standard).

MIDLAND EQ test report (123-2201, Rev. A).

As a result of this audit, the NRC staff believes that the above issues have generic implications. Hence, they have identified these and asked the staff to evaluate the applicability of these concerns (Ref. 2.2).

The following write-up provides the basis for qualification of Bunker Ramo Instrumentation Penetrations installed at LaSalle.

i

IR requirement for Braidwood application only.

a,

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LaSalle County - 2 Project No. 8319-02 0

result in recorded temperatures being 0.23 F less than-the actual i

temperature. The inaccuracy (0.23 F) resulting from the measured IR 0

values will not be visibly detectable to the operator.

Conclusions

]

Based on the above points, we conclude that the Bunker Ramo modules are qualified for use in QSalle and the concerns raised by the NRC staff during the Braidwood EQ inspection are not applicable.

These concerns and our response for LaSalle are summarized below:

6.0 RESPONSE TO NRC LETTER DATED MAY 13., 1988 (REF. 2.3)

The only safety-related Class IE Bunker Ramo electrical instrumentation penetrations are:

Penetration Type of Applications Qualification Tag No.

Service Served Requirements 2LV94E Instrumentation Drywell Ambient Maintain containment l

l 2LV95E Instrumentation Temp. Monitoring pressure integrity i

and Suppression and integrity of Pool Water Temp.

Class lE circuits Monitoring Drywell Ambient Temperature Monitors As discussed in Section 3.0, these monitors have a high alarm at 140 F.

The normal ambient temperature inside the drywell is below 0

135 F.

During a postulated DBA, the temperature reaches 340 F in less than 300 seconds. The IR of the module does not decrease appreciably during the initial transient of a LOCA environment, because of insuffi-cient duration for high temperature /high humidity effects. Hence the thermocouple sensing the drywell temperature will trigger the alarm at 140 F immediately during a LOCA. These thermocouple after triggering 0

I.S O 1

L Page 13 of 16 l...-

LaSalle County - 2 q

l Project No. 8319-02 the alarm have no other safety or Reg Guide 1.97 function. The subject 0

thermocouple also feed two recorders whose range is 0-250 F.

During 0

the postulated accident the ambient will reach 250 F within a short 0

0 duration and rise up to 340 f. 'hence the recorders will peg at 250 F and af ter which the input from these thermocouple to the respective l

recorders is greater than the range of the recorders. Based upon the j

function of the Drywell Ambient thermocouple, degradation in IR of the l

l subject Bunker-Ramo instrument penetration modules will have no impact on the safety function of these thermocouple, Suppression Pool Water Temperature Monitors 0

As discussed in Section 3.0, these monitors have a hig,, alarm at 100 F 0

and a high-high alarm at 110 F.

The suppression pool water temperature RTDs are connected to the 102 #20AWG nodules.

The minimum IR recorded during LOCA (Bunker-Ramo Report 123-2183, Rev. 04, Tab F1 of EQ-LS062) is given in Ref. 2.4.

The minimum IR of 2006 ohms mentioned,in the Report 123-2183, Rev. 04 (Page 8 of Tab F1, EQ-LS062) is for the control (60 # 14 AWG) module and hence is not applicable for the subject RTDs.

A system loop inaccuracy calculation was performed (CID-MISC-05, Rev.

01, dated 04-14-88, Tab G7 of EQ-LS062) by using the minimum IR re-corded during the LOCA for the subject RTO module, i.e., 1.5 Ma. The calculation established that the minimum measured IR will result in 0

0.23 F less than the actual temperature. The impact of Bunker Ramo modulate IR on suppression pool water temperature inaccuracy is given i n Ref. 2.13.

Assum..g the leakage IR of 15Kn between conductor to ground (instead of the total leakage from the 102 conductors in parallal}, the inaccuracy in suppression pool water temperature is less 0

i than 119 (Ref. 2.13), which is much less than the 100 F margin exist-ing in the designed temperature of the suppression pool.

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7 Page 14 of 16; LaSalle County - 2 L

Project No. 8319-02 Ref. 2.5 provides a chronology of IR measurements performed during the LOCA ~i.ests.

As pointed out in NRC Information Notice No. 88-29 (defi-ciercies in primary containment low-voltage electrical penetration assemblies, Ref. 2.6), penetration IR could degrade the signals of 4 to -

20 milliamps instruments (transmitters).

IR does not degrade the signals from RTD as severe as it does to the signals from transmitters.

0 The measured low IR resulted in a 0.23 F lower than the actual tem-perature of the suppression pool.

No IR was measured during the 0

initial high temperature of 340 F during a LOCA. However, as discussed above RTO circuits are not as sensitive as the transmitters circuits with respect to IR.

Since the margin in the design is extremely high 0

0 (100 F) when compared with the inaccuracy (0.23 F), the knowledge about IR during the initial peak temperature is not a concern at LaSalle, j

7.0 NRC STAFF MEETING, AUGUST 4,1988 BY NUCLEAR UTILITY GROUP ON ENVIRONMENTAL QUALIFICATION Reference 2.7 was given to the NRC staff on environmental qualification of Bunker-Ramo Instrument Penetrations. This is a snort summary of l

LaSalle's response to NRC concerns.

l 8.0 TELEPHONE CONVERSATION WITH NRC STAFF ON DECEMBER 01, 1988 Reference 2.8 provides the details on the telephone conversation between Mr. J. Craig, Mr. P. Shemanski and Mr. H. Walker of NRC staff and our engineering staff. This answered NRC questions on specific LaSalle applications.

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Page 15 of.16 LaSalle County -'2 a'

Project No. 8319-02.

9.0 LASALLE COUNTY RESPONSE TO NRC LETTER DATED JANUARY 31, 1989,

" ENVIRONMENTAL QUALIFICATION OF BUNKER-RAMO ELECTRICAL PENETRATION ASSEMBLIES AT LASALLE UNIT 2, REQUEST FOR INFORMATION", (Ref. 2.9)

J The above NRC letter requested additional information regarding the resolution of the issues involving the environmental qualification of Bunker-Ramo containment penetration assemblies installed at LaSalle Unit 2.

The letter specifically asked for additional information regarding IR values recorded during peak LOCA temperatures and the test conditions when the lowest value was recorded.

4 As explained before, the subject penetration assemblies are qualified for the specific function inspite of the lack of additional information regarding the 'R value recorded during peak LOCA temperature in the LaSalle test (test report No. 123-2183, Rev. 04, February 1982). As shown in Ref. 2.5, the information regarding IR af ter 103.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months into the LOCA was recorded in the above LaSalle test.

CECO recently completed a test on Bunker Ramo modules with identical material and construction to the installed LaSalle modules (Ref. 2.11) to demonstrate their capability during a postulated LOCA with respect to IR integrity at Wyle Labs (Wyle report 17040-1, February 24,1989).

The acceptance of the Wyle test by your staff is in given in Ref. 2.10.

The peak LOCA test temperature in the Wyle test envelops the LaSalle postulated peak LOCA temperature (Ref. 2.12).

The test results demon-strates that the Bunker Ramo penetration modules have insulation resis-tance higher than 31 megohms for RlD and thermocouple circuits at the peak LOCA temperatures. As expected, this limiting IR of 20 megohms did not occur at the initial transient high temperature but occurred at 203 F when the modules have been exposed to 353 hours0.00409 days 0.0981 hours 5.83664e-4 weeks 1.343165e-4 months of test.

f s

f The above Wyle test supports our previous statement that the IR does not degrade during the inittal high temperature of LOCA environment.

The Wyle report confirms that the IR decreases af ter a long duration

)

into the LOCA. As stated earlier, the LaSalle test monitored the IR l

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Page 16 of 16 LaSalle County - 2 Project No. 8319-02 after a long duration (104 hours0.0012 days 0.0289 hours 1.719577e-4 weeks 3.9572e-5 months ) into the LOCA and the measured IR had i

negligible impact on the safety of the plant.

As requested by your abcve letter, the Wyle report provides IR data at peak LOCA tempera-ture.

The Wyle report provides the IR information for the initial high temperature of the LOCA which is not available in the LaSalle report.

As expected, the Wyle report established the limiting phase of the LOCA for insulation resistance to be the long term exposure and not the initial high transient-LOCA temperature. Hence, our previous calcula-tions performed and reported in Tab G7 of EQ-LS062 (Ref. 2.1) is valid and conservative.

10.0 CONCLUSION

j 1he LaSalle test (Test Report No. 123-2183, Rev. 04, February 1982) established qualification for the installed modules at LaSalle for their plant specific application. The Byron /Braidwood test (Wyle report 17040-1, February 24,1989) provides additional supporting information to respond to the NRC concerns. To conclude, the LaSalle test and the Wyle test (the Byron /Braidwood test) demonstrate that the subject i'unker-Ramo penetration module assemblies will perform their intended safety and Reg Guide 1.97 functions at LaSalle - Unit 2 during a DBA. These penetrations are ei..ironmentally qualified to NUREG 0588 l

Cat. 11 requirements.

i

(

l 1

y

9 EXECUTIVE

SUMMARY

l l

NRC identified certain concerns on the qualification of Bunker Ramo Penetrations during an equipment inspection at Braidwood - Unit 2 in February and March 1988. These concerns were:

- Low 1R values during and after LOCA

- Effect of low IR values on instrument accuracy IR values were not taken at a frequency consistent with IEEE Standard 323-1974.

NRC requested through a letter on May 13, 1988, that LaSalle verify their qualification of Bunker Ramo Penetrations.

NRC also issued an IE Notice #88-29 titled, "Difficiencies in Primary Contain-ment Low-Voltage Electrical Penetration Assemblies."

CECO provided the qualification documents to Region III, which showed that the l

concerns identified by the NRC staff has been adequately addressed. The qualification data showed:

- Tested configuration simulates installed configuration at LaSalle.

l (Raychem Splices used in both cases on the inboard side.)

- LaSalle Unique Test with high IR values measured (19 readings) (Lowest 6

l 1.5 x 10 n).

IR calculations for the LaSalle application show negligible effects for intended function.

1

- Qualified to NUREG 0588 Category II - Qualified Life 12.8 years (Q-Seal limiting).

________________J

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,e E

NRC Concerns vs. LaSalle Response r

NRC Concern LaSalle Response l

Low 1R, values during and after LOCA LaSalle test shows high IR.

Effect of low IR values on instrument No trip function. Only indication.

accuracy LaSalle IR Calculation shows negligible effect on equipment accuracy.

Are circuits energized during Circuits energized during DBE/ Post-DBE? If so, DBE/ Post-DBE.

justify IR values-LaSalle IR calculation shows negligible effect on equipment accuracy.

CONCLUSION LaSalle penetrations are qualified to NUREG 0588 Category Il requirements.

In a Telecon, on December 1,1988, between the NRC Staff, CECO and S&L, clari-fications to this submittal was provided. Several questions on specific LaSalle applications were answered.

NRC letter, dated January 31, 1989 to CECO, stated that the documentation provided for LaSalle did not adequately resolve the NRC concerns on the i

qualification of Bunker Ramo Penetrations. The letter said:

"Without additional information regarding IR values recorded during peak LOCA temperatures and the test conditions when the lowest value was recorded, there is insufficient test data and supporting analysis to demonstrate functional Operability of Bunker Ramo penetrations during design basis event conditions."

r 1

l i~. '

This-letter requested that the licensee:

I

.a.

Conduct an' environmental qualification test to 10CFR50.49, or b.

Replace with qualified penetration assemblies.

l' CECO's response to this letter is provided in this document. This document addresses all the concerns identified in the above letter.

It uses new test data from the Braidwood test to respond to specific NRC concerns and supports LaSalle's qualification.

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_ _ _ _ _.

ML20245D962

Contents

Text

Subject:

Dear Dr. Murley:

2.0 REFERENCES

10.0 CONCLUSION

SUMMARY

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ML20245D962

Text

Subject:

Dear Dr. Murley:

2.0 REFERENCES

10.0 CONCLUSION

SUMMARY

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