ML20245L470
| ML20245L470 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 04/27/1989 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-88-07, GL-88-7, ULNRC-1992, NUDOCS 8905080050 | |
| Download: ML20245L470 (6) | |
Text
. _ _ _
1901 Gratmt Street Pust offa:e Box 149 St iows. M;sswm 63166 p
3Id 654 2550
(
Union o~ia ~~"
LECTIUC C',,*" "'*'*
April 27, 1989 U.
S.
Nuclear Regulatory Commission Attnr Document Control Desk Mail Station F1-137 Washington, D.C.
20555 ULNRC-199 2 Gentlemen:
DOCKET NUMBER 50-483 CALLAWAY PLANT ENVIRONMENTAL QUALIFICATION OF BUNKER RAMO CONTAINMENT PENETRATIONS
References:
- 1. NRC letter dated 5-13-88 from D. M.
Crutchfield to D.
F.
Schnell
- 2. ULNRC-1783 dated 6-3-88
- 3. Letter from the Nuclear Utility Group on Equipment Qualification to J.
W. Craig dated 10-3-88
- 4. NRC letter dated 1-31-89 from G. M. Holahan to D.
F.
Schnell
- 5. NRC letter dated 3-15-89 from D.
R. Muller to H.
E., Bliss-CECO
- 6. NRC letter dated 12-22-87 from J.
J.
Harrison to D.
F.
Schnell A concern regarding environmental qualification of
{
Bunker Ramo Containment Electrical Penetrations was initially identified during an EQ inspection at Braidwood Unit 2 in March 1988.
Copieri of the Callaway EQ files were sent to NRC-Region III in April 1988.
Shortly thereafter, NRC issued Reference 1 which discussed the provisions of Generic Letter 88-07.
In response, Reference 2 noted that a qualification evaluation, which supported operability, had been made available to the Callaway Resident Inspector and the Licensing Project Manager.
Reference 3 transmitted formal copies of several presentations made to the Staff during an August 4, 1988 meeting with the Nuclear Utility Group on Equipment Qualification (NUGEQ), of which Union Electric l
1s a member.
These presentations included discussions of previous Staff acceptance of the qualification of Bunker l
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1301 Gmoot Suvet Post Othce Box 149 St Icms, Mmoun 6316E 314 554 2650 y
i Union oc ' " sci ~ "
Euscnue
~~
April 27, 1989 U.
S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station F1-137 Washington, D.C.
20555 ULNRC-199 2 i
Gentlemen:
DOCKET NUMBER 50-483 i
CALLAWAY PLANT ENVIRONMENTAL QUALIFICATION OF BUNKER RAMO CONTAINMENT PENETRATIONS
References:
- 1. NRC letter dated 5-13-88 from l
D. M. Crutchfield to D.
F.
Schnell j
- 2. ULNRC-1783 dated 6-3-88 3.
Letter from the Nuclear Utility Group on Equipment Qualification to J.
W.
Craig dated 10-3-88 4.
NRC letter dated 1-31-89 from G. M.
Holahan to D.
F.
Schnell
- 5. NRC letter dated 3-15-89 from i
D.
R.
Muller to H.
E.
Bliss-CECO 6.
NRC letter dated 12-22-87 from l
J.
J.
Harrison to D.
F.
Schnell l
A concern regarding environmental qualification of Bunker Ramo Containment Electrical Penetrations was initially identified during an EQ inspection at Braidwood i
Unit 2 in March 1988.
Copies of the Callaway EQ files l
were sent to NRC-Region III in April 1988.
Shortly thereafter, NRC issued Reference 1 which discussed the provisions of Generic Letter 88-07.
In response, Reference 2 noted that a qualification evaluation, which supported operability, had been made available to the l
Callaway Resident Inspector and the Licensing Project Manager.
Reference 3 transmitted formal copies of several presentations made to the Staff during an August l
4, 1988 meeting with the Nuclear Utility Group on Equipment Qualification (NUGEQ), of which Union Electric l
1s a member.
These presentations included discussions of previous Staff acceptance of the qualification of Bunker 00YY 8905080050 890427 PDR ADOCK 05000483 P
s Ramo penetrations, explanations regarding low IR readings during the 123-2222 test (i.e. Table V values), and an affidavit from a test engineer responsible for the 123-2202 (i.e. Midland test) attesting to over 40 IR readings per test circuit of greater than 1 megaohm during peak LOCA conditions.
In Reference 4, NRC rejected the affidavit as a basis for qualification and requested that Union Electric provide additional qualification information and plans to either qualify, test, or replace the subject penetrations.
The following discussions are in response to questions raised in Reference 4.
Additional information was requested regarding the similarity of the tested configurations and actual installed instrument circuits.
Test module 69#14 (WCSF) in the 123-2222 test report and our installed 85#16 instrument modules have identical physical dimensions, module materials, and termination methods via Raychem WCSF-N heat shrink tubing.
Only the size, number, and manufacturer of conductors passing through the modules are different.
Conductor size and number of conductors are not relevant to the qualification of the penetration module itself.
This is borne out by the successful, albeit contested by the Staff, Midland test results on 69#16 modules and by subsequent testing performed at Wyle Labs for Commonwealth Edison on an 85#16 instrumentation module and a spare 69#14 control module received from Callaway Plant.
The latter testing has been accepted by the Staff per Reference 5.
Module pigtail cables used at Callaway from various manufacturers are qualified by separate test reports.
The use of different module pigtails is not relevant to qualification of the module itself.
Additional discussion of the effects of low insulation resistance (IR) readings on control circuits was requested.
As discussed during the August 4, 1988 meeting with the NUGEQ, a test shutdown during the 123-2222 test occurred 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br /> into the test.
Up until that time no IR problems had occurred.
After test restart, chamber flooding resulted in drastic IR drops for the 69#14 circuits terminated both by splices and by terminal blocks.
Evidence of floodirg was supported by engineers present during the testing by post-test chamber inspections (see Reference J), and by the magnitude that previously acceptable IR values dropped well after peak test conditions.
Thus, low IR values for the 69#14 circuits with terminal blocks during the 123-2222 test are attributed to a test anomaly that submerged the terminal blocks.
These Kulka terminal blocks were separately tested via Conax test report IPS-675 and demonstrated acceptable leakage currents (less than 0.3 mA).
NRC approved their use in control
~
circuits at Callaway in Reference 6.
Since our l
penetrations are located well above the maximum post-LOCA flood level and have junction box drains, flooding will not occur at Callaway and the low IR readings for these 69#14 circuits with terminal blocks are not applicable to Callaway Plant.
The combined effects of IR readings associated with the 123-2222 test 69#14 (WCSF) circuit, indicative of the module itself, the IPS-675 terminal block test, and the connecting control cable tests (i.e.,
for Rockbestos, Brand-Rex, or Anaconda) would show no degradation on the control circuits routed through Bunker Ramo penetrations at Callaway Plant.
As to our qualification plans, we believe the above discussions sufficiently establish qualification.
Furthermore, we support all positions made by or on behalf of the NUGEQ, including those from former senior Staff personnel, attesting to the qualification of Bunker Ramo penetrations.
Although we did not feel a need to subject these modules to additional testing, we made available two of our spares to Commonwealth Edison for testing at Wyle Labs.
Given that the test profile enveloped our requirements and that IR values greater than that required for the most limiting instrument loop at Callaway were observed, we feel that the NRC approval given for Braidwood in Reference 5 is equally applicable to Callaway.
Furthermore, questions regarding similarity and control circuits are rendered moot when consideration is given to this test report.
Should you have any further questions, please contact us.
With this response, Union Electric considers this issue closed.
Very truly yours,
/
4 D.
F.
Schnell GGY/ dis
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-3 1
STATE-OF MISSOURI.).
)
,. CITY OF ST.. LOUIS )
Donald F.'Schnell, of' lawful age, being first duly _ sworn
- upon oath says that he is Senior ~Vice President-Nuclear and an officer of. Union Electric Company;-that he has read the' foregoing.
document and knows the content thereof; that he has executed the same for and on behalf of said company with full power and' authority to do'-
so; and that the. facts therein stated are true and correct to the best of his knowledge, information'and belief.
By 36nald'F.' Schnel1~
Senior Vice President-Nuclear SUBSCRIBED and sworn to before me this '///2;16 day of 198 on
~
RY C. GUIN'N
- .s
. NOTARY PUBUC-STATE OF MISSOURI
. ST. LOUIS CITY MY COMMISSION EXPIRES JUNE 16,1990
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' Gerald'Charnoff, Esq.
cc:
Shaw, Pittman, Potts & Trowbridge 2300 N.
- Street, N.W.
Washington, D.C.
.20037 Dr. J. O. Cermak CFA,'Inc.
4 Professional Drive (Suite 110)
Gaithersburg, MD 20879 R. C. Knop Chief, Reactor Project Branch 1 U.S.. Nuclear Regulatory Commission
'1 Region III 799 Roosevelt Road i
Glen Ellyn, Illinois 60137
)
.j Bruce Little i
Callaway Resident Office l'
U.S. Nuclear Regulatory Commission RR#1 Steedman, Missouri 65077 Tom Alexion (2)
)
Office of Nuclear Reactor Regulation 1
U.S.
Nuclear Regulatory Commission 1
1 White Flint, North, Mail Stop 13E21
)
11555 Rockville Pike Rockville, MD 20852 Manager, Electric Department Missouri Public Service Commission P.O. Box 360 Jefferson City, MO 65102 U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
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Nuclear Date E210.01 DFS/ Chrono D.
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Schnell J.'E.
Birk J. V. Laux M. A.
Stiller G.
L. Randolph R.
J.
Irwin H. Wuertenbaecher W.
R. Campbell A. C. Passwater R.
P. Wendling D.
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Shafer D.
J. Walker O. Maynard (WCNOC)
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