ML17261A558
| ML17261A558 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 07/09/1987 |
| From: | KOBER R W ROCHESTER GAS & ELECTRIC CORP. |
| To: | RUSSELL W T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| IEIN-86-053, IEIN-86-53, NUDOCS 8707250136 | |
| Download: ML17261A558 (12) | |
See also: IR 05000244/1987003
Text
REGULATORY
INFORMATION
DISTRIBUTIQN
SYSTEM (RIDSi ACCESSION NBR: 8707250136
DOC.DATE: 87/07/09 NOTARIZED:
NO ACIL: 50 244 Robert Emmet Ginna Nuc lear Plantz Unit it Rochester G AUTH.NAME AUTHOR AFFILIATION
OBERI R.W.Rochester Gas 4 Electric Corp.REC IP.NAME RECIPIENT AFFILIATION
RUSSELI W.T.Region 11 Office of Director DOCKE1 05000244 SUBJECT: Responds to NRC 870610 ltr re violations
noted in Insp Rept 50-244/87-03.
Corrective
actions:addi
positive sealing provided at detector/connector-cable
interface for Victoreen high range radiation monitor.DISTRIBUTION
CODE: 'IEOID COPIES RECEIVED: LTR g ENCL Q SIZE: TITLE: General (50 Dkt)-Insp Rept/Notice
of Violation Response NOTES: License Exp.date in accordance
with 10CFR2i 2.109(9/19/72i.
05000244 RECIPIENT ID CODE/NAME PD1-3 PD COPIES LTTR ENCL 1 REC IP IENT ID, CODE/NAME STAHLEi C CQP I~S LTTR ENCL 2 lNTERNAL: AEOD NRR MOR ISSEAUi D NRR/DREP/EPB
NRR/DRIS DIR QE LIEBERMANI
J IL ILE 01 1 1 1 1 1~1 1 1 1 1 1 DEDRO NRR/DOEA DIP.NRR/DREP/RPB
NRR/PM*S/ILRB OGC/HDS2 RFS DEPY GI 1 2 1 1 1 TERNAL: LPDR NSIC 1 1 i NRC PDR 1 1 TOTAL NUMBER OF COPIES REQUIRED: LTTR 20 ENCL 20
NA55tt'ROCHESTER GAS AND ELECTRIC CORPORATION
e 89 EAST AVENUE, ROCHESTER, N.V.14649.0001
H5a T D!IC 55455 ROGER VA KOBER VICE PI5CSIDCITT
CI.CCTRIC ORDD5ICTIDI5
TTI.K5'taDle5.
ARCA CODE TIO 546.2700 July 9>1987 Mr.William T.Russell Regional Administrator
U.S.Nuclear Regulatoiy.
Commission
Region 1 631 Park Avenue Kxng of Prussia>PA 19406 Subject: Inspection
Report No.50-244/87-03
R.E.Ginna Nuclear Power Plant Docket No.50-244 Dear Mr.Russell: This letter is in response to Inspection
Report 50-244/87-03<
dated June 10<1987<transmitting
two notices of vxolation'relative to 10CFR50.49.
The RG6E position on these notices of violation>
including (1)the corrective
steps which have been taken and'the results achieved<(2)corrective
steps which will be taken to avoid further violations<
and (3)the date when full compliance
will be achievedi is included in the Attachment.
Although RG6E does not consider that any installed equipment was in violation of 10CFR50.49>
as noted in the Attachment<
RGGE has enhanced the documentation
provided in the affected 10CFR50.49
files.The additional
sealing<equipment testing>and analysis performed by RGGE provides further confirmation
that all requirements
of 10CFR50.495
including documentation>
have been met.No further corrective
actions are considered
warranted.
V r truly yours>Roger W.Kober Attachment
8707250i3b
870709 PDR ADOCK 05000244 8 PDR
ATTACHMENT
RGSE Response to Notices of Violation Concerning
lOCPR50.49
Inspection
50=244/87-03
NOTICE OP VIOLATION A: "As a result of the equipment qualification (EQ)inspection
of February 9-13'987>and in accordance
with NRC Enforcement
Policy (10CFR-2, Appendix C)i the following violations
were identified:
requires that gualification
of each component be based on testing or experience
with identical equipment or with similar equipment with a supporting
analysis to show that the equipment to be qualified is acceptable.
requires>in part<that electrical
equipment need not be requalified
if it was previously
required by the Commission
to be qualified in accordance
with the"Guideline
for Evaluating
Environmental
Qualification
of Class 1E Electrical
Equipment in Operating Reactors">(DOR Guidelines).
Section 5.2.2r of the DOR Guidelines
reqpectively
requires>in part<that the type test is only valid for equipment identical xn design and material cohstructxon
to the test specimen<and any deviations
should be evaluated.
Contrary to the above>during the EQ inspection
on February 9-13>1987 the licensee had not established
similarity
or.the test specimen and the installed component for the following:
l.The installed Crouse-Hinds
Electrical
Penetration (Ref.paragraph 12.2>050-244/87-03-02
)2.The General Cable Corporation's
PVC cable used in a harsh environment.(Ref.12.4<050-244/87-03-03)" RGSE RESPONSE: As explicitly
described in RGSE's March 6>1987 letter response to the Inspection
50-244/87-03
exit meeting>the qualification
information
available in the RGSE 10CFR50.49
files at the time of the inspection
provided reasonable
assurance that the Crouse-Hinds
electrical
and the General Cable Corporation
PVC cables>were fully environmentally
qualified in accordance
with the DOR Guidelines
and lOCFR50.49>
in order to perform their required functions.
In the case of the Crouse-Hinds
all of the materials of construction
were shown to be equal to or better than the materials which were tested>as documented
in EEQ Package 58.In the case of the PVC cablei it was shown that minor deaf ferences z,n
PVC formulations<
as could exist and still meet IPCEA S61-402 standards>
were well within the performance
requirements
for the"control-type" applications
at Ginna Station.Therefore<
as stated in the Narch 6i 1987 letter>RGGE considers that no violation of 10CFR50.49
existed at the time.of the inspection.
However<RGGE has made improvements
to the f iles in order to clarify the qualification
documentation
as follows: a)As noted in paragraph 12.2 of the Inspection
'Report>RGGE submitted a more detailed material-by-material
analytical
comparison
of the tested penetrations
and Ginna's Crouse-Hinds
in a letter d'ated Narch 6<1987.This comparison
has been added to the EEQ Package 08 files.This additional
information<
which addresses all of the NRC concerns expressed during the inspection>
provides the corrective
action taken by RGGE.It should be noted that NRC comments in Section 12.2 of the Inspection
Report>relative to consideration
of humidity and nitrogen gas effects on the internal penetration
materials were not brought up during the inspection.
Nonetheless<
these issues can be resolved as.noted below:(1)The qualification
test documentation
in the files demonstrated
material qualification
using highly conductive
boiler steam.This testing envelopes the noted humidity concerns (2)Nitrogen is an inert gas>which in this aoplication
excludes oxygen and>therefore, suppresses
degradation
from normal aging (oxidation)
effects.Testing in an air atmosphere
(78%nitrogen)is, conservative.
No additional
corrective
action is necessary>
since the EEQ Package 08 files now include all of the explanatory
materials comparison
analysis deemed necessary by the NRC.b)As noted in paragraph 12.4 of the Inspection
Reports a confirmatory
test of the specific PVC cables used in 10CFR50.49
applications
in containment
at Ginna Station was completed as of February 12~1987.This test>which confirmed the suitability
of the installed cable<has been incorporated
into the EEQ Package 544 files.No additional
corrective
action is considered
necessary.
NOTICE OF VIOKATION B: "10CFR50.49(f)
requires that qualification
of each component be based on testing or experience
with identical equipment or with similar equipment with a supporting
analysis to show that the equipment to be qualified is acceptable.
Contrary to the above>during the EQ inspection
on February 9-.13>1987<the licensee had not provided supporting
documentation
to establish qualification
of the following:
0
1.The installed Victoreen High Range connector/detector
environmental
Raychem Hea t Shrink Tubing over environment.(Ref.paragraph 12.7f Radiation Monitor's cable/seal configuration
using metal surfaces in the harsh.050-244/87-03-05)
2 Deviation from Raychem requirements
for Heat Shrink tube splice minimum seal length and minimum bend radius.(Ref.paragraph 12.6g 050-244/87-03-06)
3.Effects of insulation
resistance
changes and instrument
accuracy for circuits using Coleman cable.(Ref.paragraph 12.5p 050-244/87-03-04)" RG&E POSITIONS:
l.Victoreen High Range Radiation Monitor As noted in Enclosure 1 to RG&E's March 6, 1987 letter concerning
Inspection
50-244/87-03<
RG&E did address all of the leakage path failure mechanisms
determined
in the Victoreen Qualxfication
Test Report 950.301.The final Victoreen assembly which passed the LOCA test did not provide a seal at the interface being questioned, at.the base of the detector/connector-cable
interface (See Victoreen Test Report 950.301, Page VI-45<Photograph
YI-24, which was reproduced
as Attachment
10 to Enclosure 1 of RG&E's March 6>1987 response letter to Inspection
87-03).Therefore>
RG&E has concluded that the configuration
installed at the time of the inspection
was fully environmentally
qualified.
It should be noted that a Raychem heat shrink tube was shown to form an environmentally
qualifxed seal when installed over a metal surface>as documented
in Reference 3.b.l>Figure IV-1>of EEQ Package 636.RG&E did>however<provide additional
sealing<prior to March 6>1987 consisting
of RTV 7403<at the detector/connector-cable
interface>
to provide additional
positive sealing.This seal arrangement
is virtually identical to the conf iguration demonstrated
to be qualifie'd
in EEQ Package N36>Reference 3.b.3.The documentation
relative to the acceptability
of the presently-installed
configuration
has been added,to the EEQ Package N36 files.RG&E does not consider that any additional
corrective
'action is warranted.
2.Raychem Minimum Seal Length and Bend Radius As stated in Enclosure 5 of RG&E's 3/6/87 letter concerning
Inspection
50-244/87-03<
RG&E does not belie've that the RG&E installations
were violations
of 10CFR50.49.
The specif ied Raychem bend radius and overlap specificatxons
were considered
recommendations<
not requirements.
Based on RG&E experience
with similar configurations<
RG&E was confident that the installed configurations
were acceptable.
Based on IEIN 86-53>RG&E was made aware of industry-wide
concern with these recommendationsi
0
and promptly initiated a plan for actual LOCA qualification
testing.As expected<the test results were acceptable.
These qualification
reports have been incoroorated
into EEQ Package 512 files.It is not considered
that any additional
corrective
action is warranted.
3.Coleman Cable Insulation
Resistance
As noted in Enclosure 3 to RG&E's March 6>1987 letter relative to Inspection
50-244/87-03<
RGSE considered
that the combination
of testing and materials analysis in Package 513 provided reasonable
assurance that the, cable would be able to perform its required function.This conclusion
was also reached by the NRC and FRC in FRC TER C5257-454.
Nonetheless~
RGGE performed additional
confirmatory
testing<including measurements
of leakage current<which demonstrated
performance
suit'able for instrumentation
circuits during DBE conditions.
This test report has been included in RGSE's EEQ Package N13.No additional
corrective
action is considered
necessary.