View source for BSEP-86-0996, Responds to Violations Noted in Insp Repts 50-324/85-26 & 50-325/85-26.Denies Violation Re Documenting Qualification of Rockbestos Firewall III Cables.Rockbestos Repts Sufficiently Demonstrate Interim Qualification of Cable

{{Adams
| number = ML20212A347
| issue date = 06/30/1986
| title = Responds to Violations Noted in Insp Repts 50-324/85-26 & 50-325/85-26.Denies Violation Re Documenting Qualification of Rockbestos Firewall III Cables.Rockbestos Repts Sufficiently Demonstrate Interim Qualification of Cable
| author name = Dietz C
| author affiliation = CAROLINA POWER &amp; LIGHT CO.
| addressee name = Grace J
| addressee affiliation = NRC OFFICE OF INSPECTION &amp; ENFORCEMENT (IE REGION II)
| docket = 05000324, 05000325
| license number = 
| contact person = 
| document report number = BSEP-86-0996, BSEP-86-996, NUDOCS 8607280163
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 5
}}

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Carolina Power & Light Company a d':L 2  nII : 5 e Brunswick Steam Electric Plant P. O. Box 10429 Southport, NC 28461-0429 June 30, 1986 FILE: B09-13510E SERIAL: BSEP/86-0996 Dr. J. Nelson Grace, Administrator U.S. Nuclear Regulatory Commission Suite 2900 101 Marietta Street hV Atlanta, GA 30323 BRUNSWICK STEAM ELECTRIC PLANT UNITS 1 AND 2 DOCKET NOS. 50-325 AND 50-324 LICENSE NOS. DPR-71 AND DPR-62 RESPONSE TO IhTRACTIONS OF NRC REQUIREMENTS

==Dear Dr. Grace:==

The Brunswick Steam Electric Plant (BSEP) has received I&E Inspection Report 50-325/85-26 and 50-324/85-26 and finds that it does not contain information of a proprietary nature.
This report identified two items that appeared to be in noncompliance with NRC requirements. Carolina Power & Light Company (CP&L) responded to the second violation on May 20, 1986 (Serial Number BSEP/86-0721). Enclosed is CP&L's response to the first violation.
Very truly yours,
(  k',_g C. R. Dietz, General Manager Brunswick Steam Electric Plant RMP/ cab Enclosure cc: NRC Document Control Desk 8607280163 860630 PDR     ADOCK 05000324 G                    PDR~
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;             VIOLATION
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Paragraph (j) of 10CFR50.49 requires that a record of qualification must be maintained to permit verification that each item of equipment is qualified for                        ,
its application and meets its specified performance requirements when
!             subjected to the conditions predicted to be present when it must perform its
:             safety function.
1 l             Contrary to the above, the licensee's file, QDP-12 for Rockbestos Firewall III, insulated cable with Hypalon jacketing, did not provide
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j             sufficient analysis to support qualification for the cable's specific applications at BSEP. The file did not provide sufficient analysis in the following areas:
}l            a.      Analysis to document that cable qualification test's profiles enveloped j                     required plant environments.
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: b.      Analysis to document that cable functional performance tests conducted                            ,
during qualification testing were applicable to BSEP cable performance                            i
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requirements.
: c.      Analysis to document that tested cable was the same as or similar to the i                     cable installed in BSEP.
This is a Severity Level IV violation (Supplement I).
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===RESPONSE===
I.      Admission or Denial of the Alleged Violation s
}                      Carolina Power & Light (CP&L) Company denies that the Rockbestos I                     Firewall III cable qualification documentation (QDP-12) had insufficient i                     analysis at the time of the NRC inspection to support qualification for l                      the cable's specific applications at BSEP. The QDP, as reviewed during
 !                     the inspection, cited Rockbestos qualification reports and supplemental
{                      testing / analysis which were evaluated (per the QDP) to be applicable for BSEP-installed cable and to envelop the BSEP qualification parameters.
II. Discussion
;                      Prior to the NRC inspection, CP&L had prepared QDP-12 to evaluate and i                      document the qualification established for Rockbestos Firewall III cables, j                      This qualification documentation was based upon the original Rockbestos                           ;
j                      qualification testing for irradiation and chemically cross-linked                                  ;
i                      polyethylene cable insulation systems (per Rockbestos Reports QR-1806 and 1                      QR-1807, respectively) as supplemented by supporting analysis / test results                      j j                      provided by Rockbestos Report QR-4802. CP&L believed these reports were j                       acceptable to sufficiently demonstrate the cable's interim qualification
;                      based upon the following:
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* Rockbestos had provided their original certification for cables supplied to BSEP in QR-1806/1807 and (in response to IN 84-44) 1                   backed up their certification per QR-4802. Rockbestos comparisons to other testing, as consolidated in QR-4802, provided a validation of their original test results and conclusions (through programs independent of the Rockbestos organization).
* QR-1806/1807 were sequential test programs that enveloped BSEP normal and postulated accident parameters. Satisfaction of the required BSEP conditions was documented within the QDP per the Qualification Summary and EQ Evaluation Form.
Furthermore, QR-4802 (as noted in the QDP) presented a worst-case profile defined by Bechtel Power Corporation (340 F/62 psig peak, 180-day accident duration, chemical spray, 64 x 10' rads gamma, and 1.18 x 10' rads beta), which enveloped BSEP requirements except for the (40-year normal plus accident) radiation requirement of 110 x 10' rads gamma. Additionally, the QDP specified that radiation tolerances for this cable were demonstrated by Sandia l                    Laboratories testing performed at greater that 150 x 10' rads gamma to justify the cable's acceptability to the BSEP radiation requirements.
* Based upon CP&L's review of IN 84-44 and the Rockbestos response per QR-4802, CP&L had concluded that the IN did not provide a sufficient i                   basis that QR-1806/1807 were technically deficient with respect to
,                    BSEP qualification requirements; rather, that the IN raised concerns over Rockbestos test administration and documentation practices, which placed an overall doubt in the Rockbestos qualification programs. For this reason the "possible courses of corrective action" (stated in IN 84-44) had been dispositioned per the           .
1                   Resolution of IE Notices Section of the QDP to dispel this doubt.
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* IN 84-44 stated that the NRC staff had concluded that no immediate j                    safety problem existed with the use of Rockbestos cables, despite              i j                    the above-noted doubt raised by the NRC in the validity of                     l Rockbestos test programs.                                                      '
* CP&L contact with Rockbestos was maintained to monitor the
 ;                   Rockbestos requalification test programs and to request the final qualification reports for review and inclusion within BSEP QDP qualification evaluations. It was felt that these requalification 1                    test reports would be utilized to provide further credence to the
 ;                    original test results of QR-1806/1807.
To demonstrate CP&L tracking of Rockbestos requalification efforts,
 !                    an August 15, 1985, CP&L telephone conversation memorandum with Mr. G. Littlehales of Rockbestos was included in a revision to the
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QDP-12 qualification evaluation. This telecon stated that Rockbestos has successfully completed the requalification testing of chemically cross-linked Firewall III and that their irradiation cross-linked Firewall III had completed 76 of the 100-day LOCA simulation without problems. (The qualification evaluation noted that the 76-day LOCA simulation exceeded the BSEP 30-day accident requirement.)
* Based upon Rockbestos's claim in QR-4802 that similarities existed between both chemically cross-linked and irradiation cross-linked cables, CP&L was not aware at the time of the inspection of any variations in the formulation of chemically crossed-linked cables that would affect the cable's environmental qualification.
The Notice of Violation identified certain areas of QDP-12 in which sufficient analysis was not provided in the opinion of the NRC inspectors.    ,
In response to each of these areas, the following is offered:
: a. As stated above, the QDP qualification evaluation did include an analysis that the BSEP conditions were enveloped by QR-1806/1807 and by supplemental data per QR-4802.
: b. The QDP qualification evaluation identified the cables generically tested in QR-1806/1807 and compared these test specimens to the electrical parameters for BSEP cables. Additionally, the qualifica-tion evaluation stated that (although the cables were energized) functional tests were not performed during the accident simulations of QR-1806/1807, as insulation resistance (IR) tests were not required by IEEE-383 during the accident if IR measurements were performed following the environmental cycle.
: c. As noted above, Rockbestos certification to QR-1806/1807 for cables supplied to BSEP confirms that the tested cables were similar to those installed in BSEP. Furthermore, during the initial preparation of the QDP qualification evaluation, the generic use of Rockbestos Firewall III data was believed to be justified per QR-4802, page 5-1-2, which states that the difference in the irradiation cross-linked and the chemically cross-linked materials is minor (to accommo-date the different cure systems) and that previous testing of both materials has shown similar results.
J         Each of the above responses is consistent with CP&L's determination that QR-1806 and QR-1807, as supplemented by QR-4802, were valid to demonstrate the cable's qualification. In addition, given CP&L's awareness of the ongoing Rockbestos requalification efforts and given the NRC admission that no immediate safety significance existed for installed Rockbestos cables, CP&L believed that sufficient effort was performed to disposition the IN and to reaffirm the cable's qualification per the QDP which existed at the time of the NRC inspection. However, the NRC inspectors advised that more detailed analyses in the above areas for each of the applicable supplemental tests (from QR-4802) to the corresponding BSEP parameters was required to be documented within the QDP to more fully satisfy the corrective actions recommended by IN 84-44. CP&L was not appraised that this issue was being classified as a potential violation / enforcement action until the exit meeting; rather, discussions with the NRC inspectors I
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who reviewed the QDP inferred that a revision to the QDP qualification evaluation would be left as an open item as a result of the inspection to allow CP&L to augment the QDP qualification evaluation with the required detailed analyses.
Subsequent to the NRC inspection, Rockbestos requalification results (per Rockbestos Reports QR-5804 and QR-5805 for chemically and irradiation cross-linked cables, respectively) have been reviewed and incorporated into QDP qualification evaluations. These reports provide additional assurance that our original determination of the cable's qualification was correct.
It is CP&L's current understanding that the Rockbestos requalification efforts cover each cable type currently in production by Rockbestos. To assure that cables supplied to BSEP are applicable to QR-5804/5805, Rockbestos has been contacted to perform a documentation review of their manufacturing shop order records and to certify to the applicable Rockbestos qualification report (s) for each BSEP cable type procured from Rockbestos. Preliminary results provided by Rockbestos of this research indicate that BSEP cables, with one exception, are either the irradiation cross-linked (KXL-760G) formulation (the only irradiation cross-linked formulation ever manufactured) or the latest chemically cross-linked (KXL-760D) formulation. The one exception currently identified is a partial supply of single conductor #12 AWG Firewall III cable on CP&L Purchase Order B-0848, which Rockbestos stated to be chemically cross-linked KXL-780 formulation. A material's similarity analysis of the thermal and radiation tolerances between the KXL-780 and KXL-760D formula-tions is currently being developed by Rockbestos to complete their qualifi-l               cation assessments. Similarity analysis for this one P0 item remains as the only outstanding documentation required for the QDP. This analysis will be integrated into the QDP qualification evaluation within one month after its receipt. However, since QR-1807 included a test specimen of KXL-780, interim qualification remains demonstrated per QR-1807 as supple-mented by QR-4802 and QR-5804.
III. Conclusion Based upon the above discussion, CP&L believes that QDP-12 contained sufficient analysis at the time of the NRC inspection to demonstrate the qualification of Rockbestos Firewall III chemically and irradiation cross-linked cables. The documentation problem (described in IN 84-44)                              l was adequately evaluated within QDP-12 (prior to completion of the Rockbestos requalification programs) and was further verified once the Rockbestos test results were integrated into BSEP QDP qualification evaluations. CP&L believes that QDP-12 (as reviewed during the inspection) complied with the requirements of 50.49 and that the alleged violation should be dismissed.
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