NL-07-055, Response to Generic Letter 2007-01

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Response to Generic Letter 2007-01
ML071350410
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 05/07/2007
From: Dacimo F
Entergy Corp
To:
Document Control Desk, NRC/NRR/ADRO
References
GL-07-001, NL-07-055
Download: ML071350410 (4)


Text

Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, N.Y. 10511-0249 IEnta Tel (914) 734-6700 Fred Dacimo Site Vice President Administration May 7, 2007 Indian Point Unit Nos. 2, and 3 Docket Nos. 50-247, and 50-286 NL-07-055 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, Maryland 20852

SUBJECT:

Submittal of Indian Point Response to Generic Letter 2007-01

REFERENCES:

1. NRC Generic Letter 2007-01, dated February 7, 2007, "Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients."
2. NEI letter from J. H. Riley to Administrative Points of Contact dated March 26, 2007 "Guidance for Response to GL 2007-01."
3. NRC Letter from Michael J. Case, to J. H. Riley dated April 13, 2007, "Response to Nuclear Energy Institute (NEI) Letter Dated March 26, 2007 - Re: Interpretation of Generic Letter (GL) 2007-01, Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients."

Dear Sir or Madam:

Per reference 1, the NRC issued Generic Letter (GL) 2007-01 to request facilities to submit the following information to the NRC within 90 days of the date of the Generic Letter:

(1) Provide a history of inaccessible or underground power cable failures for all cables that are within the scope of 10 CFR 50.65 (the Maintenance Rule) and for all voltage levels. Indicate the type, manufacturer, date of failure, type of service, voltage class, years of service, and the root causes for the failure.

(2) Describe inspection, testing and monitoring programs to detect the degradation of inaccessible or underground power cables that support EDGs, offsite power, ESW, service water, component cooling water and other systems that are within the scope of 10 CFR 50.65 (the Maintenance Rule).

The response to Item 1 is provided in the attachment to this letter. In researching plant records for the requested information, Entergy Nuclear Operations, Inc. (Entergy) used the NEI and NRC guidance provided in References 2 and 3, respectively, to clarify the population of cables of interest for Indian Point. Data bases researched included Plant Condition Reporting

-/Ii2S

Docket Nos. 50-247, and 50-286 NL-07-055 Page 2 of 2 System (PCRS), Electrical Cable Routing Information System (ECRIS), and personnel interviews.

To date, Indian Point 3 has experienced two (2) cable failures within the scope of the GL and Indian Point 2 has experienced none.

In response to Item 2, Indian Point inspection, testing and monitoring practices presently include visual inspection of cable terminations, periodic meggering / motor current analysis of cables and connected equipment associated with preventative maintenance activities, and periodic inspection of manholes for dewatering. Plant condition reporting is used to determine cause and extent of conditions where deemed necessary and would be the mechanism for determining the need for and extent of any increased cable monitoring.

No new commitments are identified in this submittal.

If you have any questions, or require additional information, please contact Mr. T. R. Jones, Manager, Licensing at (914) 734-6670.

The requested information is being provided pursuant the requirements of 10 CFR 50.54(f). I declare under the penalty of perjury that the foregoing information is true and correct. Executed on May 2007.

nhcere Fred R. Dacimo Site Vice President Indian Point Energy Center - Cable Data Provided In Response to Generic Letter 2007-01 cc: Mr. Samuel J Collins, Regional Administrator, NRC Region I Mr. John Boska, Senior Project Manager, NRC, NRR, DORL Resident Inspector's Office Mr. Paul Eddy, NYS Dept. of Public Service Mr. Peter R. Smith, President, NYSERDA

Attachment 1 To NL-07-055 Cable Data Provided In Response to Generic Letter 2007-01 ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT 2 AND 3 NUCLEAR POWER PLANTS DOCKET NOS. 50-247 AND 50-286 DPR-26 AND 64

NL-07-055 Attachment 1 Docket Nos. 50-247, and 50-286 Page 1 of 1 History of Inaccessible or Underground Power Cable Failures within the Scope of 10CFR 50.65 for Indian Point Cable Type Voltage Manufacturer Date of Failure Type of Root Cause Comments Class I I Service (Yrs.) Service Service Lead Jacket 600 VAC 350 MCM, lead 1994/1975- One phase of Mechanically induced damage Cable within scope of Maintenance

/480 sheathed and 1994 (19 years) feed to resulted in arcing as a result of Rule and experienced catastrophic VAC copper 33SWP moisture and accumulation of failure during operation. Replaced conductor (37 (normally corrosion product in the damaged by Mod 94-3-311 with Okonite copper wires, energized) area. Damage possibly due to cable cable with copper bearing, lead Inner PVC installation or installation of a new sheath, and qualified for water Insulation .10 in adjacent duct bank. Moisture due to submergence.

thick, lead rain with subsequent drying. No cable sheath .09 in degradation due to moisture ingress.

thick, Outer Analysis of cable failure performed by PVC jacket .07 Lucius Pitkin (Ref Report No in thick) M94548).

Lead Jacket 600 VAC Same 2005 /1975 - One phase of Probable cause was insulation Cable within scope of Maintenance

/ 480 2005 (30 years) feed to thinning during original installation Rule and degraded condition found VAC 33SWP with subsequent degradation or during motor current analysis (normally damage during the duct bank collapse (MCA) testing prior to failure.

energized) repaired in 1994. Degradation Replaced (different conductor than contributing cause was submergence the one replaced during 1994 ) by of cable for extended period of time. Mod 1P3-05-20151 with General Moisture due to rain with subsequent Cable Dura Sheath drying. Analysis performed CR-IP3-2005-2634.

Text

Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, N.Y. 10511-0249 IEnta Tel (914) 734-6700 Fred Dacimo Site Vice President Administration May 7, 2007 Indian Point Unit Nos. 2, and 3 Docket Nos. 50-247, and 50-286 NL-07-055 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, Maryland 20852

SUBJECT:

Submittal of Indian Point Response to Generic Letter 2007-01

REFERENCES:

1. NRC Generic Letter 2007-01, dated February 7, 2007, "Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients."
2. NEI letter from J. H. Riley to Administrative Points of Contact dated March 26, 2007 "Guidance for Response to GL 2007-01."
3. NRC Letter from Michael J. Case, to J. H. Riley dated April 13, 2007, "Response to Nuclear Energy Institute (NEI) Letter Dated March 26, 2007 - Re: Interpretation of Generic Letter (GL) 2007-01, Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients."

Dear Sir or Madam:

Per reference 1, the NRC issued Generic Letter (GL) 2007-01 to request facilities to submit the following information to the NRC within 90 days of the date of the Generic Letter:

(1) Provide a history of inaccessible or underground power cable failures for all cables that are within the scope of 10 CFR 50.65 (the Maintenance Rule) and for all voltage levels. Indicate the type, manufacturer, date of failure, type of service, voltage class, years of service, and the root causes for the failure.

(2) Describe inspection, testing and monitoring programs to detect the degradation of inaccessible or underground power cables that support EDGs, offsite power, ESW, service water, component cooling water and other systems that are within the scope of 10 CFR 50.65 (the Maintenance Rule).

The response to Item 1 is provided in the attachment to this letter. In researching plant records for the requested information, Entergy Nuclear Operations, Inc. (Entergy) used the NEI and NRC guidance provided in References 2 and 3, respectively, to clarify the population of cables of interest for Indian Point. Data bases researched included Plant Condition Reporting

-/Ii2S

Docket Nos. 50-247, and 50-286 NL-07-055 Page 2 of 2 System (PCRS), Electrical Cable Routing Information System (ECRIS), and personnel interviews.

To date, Indian Point 3 has experienced two (2) cable failures within the scope of the GL and Indian Point 2 has experienced none.

In response to Item 2, Indian Point inspection, testing and monitoring practices presently include visual inspection of cable terminations, periodic meggering / motor current analysis of cables and connected equipment associated with preventative maintenance activities, and periodic inspection of manholes for dewatering. Plant condition reporting is used to determine cause and extent of conditions where deemed necessary and would be the mechanism for determining the need for and extent of any increased cable monitoring.

No new commitments are identified in this submittal.

If you have any questions, or require additional information, please contact Mr. T. R. Jones, Manager, Licensing at (914) 734-6670.

The requested information is being provided pursuant the requirements of 10 CFR 50.54(f). I declare under the penalty of perjury that the foregoing information is true and correct. Executed on May 2007.

nhcere Fred R. Dacimo Site Vice President Indian Point Energy Center - Cable Data Provided In Response to Generic Letter 2007-01 cc: Mr. Samuel J Collins, Regional Administrator, NRC Region I Mr. John Boska, Senior Project Manager, NRC, NRR, DORL Resident Inspector's Office Mr. Paul Eddy, NYS Dept. of Public Service Mr. Peter R. Smith, President, NYSERDA

Attachment 1 To NL-07-055 Cable Data Provided In Response to Generic Letter 2007-01 ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT 2 AND 3 NUCLEAR POWER PLANTS DOCKET NOS. 50-247 AND 50-286 DPR-26 AND 64

NL-07-055 Attachment 1 Docket Nos. 50-247, and 50-286 Page 1 of 1 History of Inaccessible or Underground Power Cable Failures within the Scope of 10CFR 50.65 for Indian Point Cable Type Voltage Manufacturer Date of Failure Type of Root Cause Comments Class I I Service (Yrs.) Service Service Lead Jacket 600 VAC 350 MCM, lead 1994/1975- One phase of Mechanically induced damage Cable within scope of Maintenance

/480 sheathed and 1994 (19 years) feed to resulted in arcing as a result of Rule and experienced catastrophic VAC copper 33SWP moisture and accumulation of failure during operation. Replaced conductor (37 (normally corrosion product in the damaged by Mod 94-3-311 with Okonite copper wires, energized) area. Damage possibly due to cable cable with copper bearing, lead Inner PVC installation or installation of a new sheath, and qualified for water Insulation .10 in adjacent duct bank. Moisture due to submergence.

thick, lead rain with subsequent drying. No cable sheath .09 in degradation due to moisture ingress.

thick, Outer Analysis of cable failure performed by PVC jacket .07 Lucius Pitkin (Ref Report No in thick) M94548).

Lead Jacket 600 VAC Same 2005 /1975 - One phase of Probable cause was insulation Cable within scope of Maintenance

/ 480 2005 (30 years) feed to thinning during original installation Rule and degraded condition found VAC 33SWP with subsequent degradation or during motor current analysis (normally damage during the duct bank collapse (MCA) testing prior to failure.

energized) repaired in 1994. Degradation Replaced (different conductor than contributing cause was submergence the one replaced during 1994 ) by of cable for extended period of time. Mod 1P3-05-20151 with General Moisture due to rain with subsequent Cable Dura Sheath drying. Analysis performed CR-IP3-2005-2634.