ML20058Q200

Requests Supplemental Response Describing Util Corrective Actions & Date of Full Compliance,Per Insp Rept 50-302/89-18

ML20058Q200
Person / Time
Site:	Crystal River
Issue date:	07/31/1990
From:	Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Beard P FLORIDA POWER CORP.
References
NUDOCS 9008210152
Download: ML20058Q200 (5)

See also: IR 05000302/1989018

Text

,y ., _

July 31, 1990.

'

,

Florida Power Corporation >

[

Mr. Percy M. Beard, Jr. *

'

Senior,Vice President, Nuclear

Operations

ATTN: Manager, Nuclear'0perations j

Licensing (

P. O.-Box 219-NA-21 ~

,

Crystal River,-.FL 32629

- Gentlemen:

l

SUBJECT: 'NRC INSPECTION REPORT NO. 50-302/89-18

Thank you-_for your response of September 20, 1989, to our Notice of-Violation

! Lissued on August = 21,1989, concerning activities conducted at ,your Crystal; e

-River facility. .

We have completed our evaluation of your response to Violation B and 'have ,

concluded, for the reasons presented in the enclosure' to this letter, that- the *

violation occurred as stated- in the Notice of Violation. ' Therefore , - in t

accordance <with, the requirements of- 10 CFR 2.201, and within 30 days? of the.

date of- this letter, please submit a supplemental response describing; your 1

corrective actions and date of full compliance.

.

'

'

.Should you have any questions concerning this letter, we would be. happy te meet

with you and discuss the matter.

! Sincerely; 4

4

Origir , signed by

Caudle A. Julian

Ellis W. Merschoff, Acting Director-

,

Division of-Reactor Safety-

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Enclosure:

Staff Evaluation of Licensee

Resp,onse

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Gary L. Boldt

Vicel President, Nuclear Production i

-. Florida ' Power Corporation.-

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P. O. Box 219-SA-2C

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.St. Petersburg,;FL 33733

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State ~ Planning and Development

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ENCLOSURE

STAFF E MLUATION OF LICENSEE RESPONSE

DATED SEPTEMBER 20, 1989

,

Our assessment of_ your reasons for denial of the violation is as follows:  !

a. The requirements anc overall intent for performing Type B testing are

stated in \0 CFR 50, Appendix J. Paragraphs II.G, d. '.1, II.G.2, II.G.3, . ,

and II.G.4. These paragraphs define the following overall requirements' '

for testing:

~

Type 6 tests are intended to detect local leaks and to measure

leakage across each pressure-containing or leakage-limiting boundary

for any primary containment penetration subject to leakage. '

Electrical. penetrations penetrating containment and employing sealing' '

mechanisms as presure-containing or leakage limiting boundaries are

l

'

subject to Type L testing. The classification of seals called sealant

compounds, includes any compound used to form a leakage-limiting boundary.

It may be hard setting or resilient since, if. resilient,-it simply falls

.into the category called resilient seals.

The classification of seals called flexible metal seal assemblies includes

those seals which employ a metal 'to metal assembly which, under force,

forms mating surfaces which act as a pressure-containing, leakage-limiting

'

boundary. Whether such an assembly is flexible, non-flexible,- or

malleable is . immaterial. If flexibility. is construed to be an essential j'

characteristic of the category. of seals called flexible metal seal

assemblies, non-flexible . metal seal assemblies 'must still be Type B

tested.

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b. In their response, the licensee attempts to relate sealant compounds to

adhesive agents such as wax, paraffin, or putty. Within the context of

.the -regulations,--it .is clear that 'the term sealant compounds does not

' refer to such agents since these materials could not withstand containment

ll pressures under accident conditions. 1

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L c. In their response, the licensee states that polysulfone is not a resilient . .

material and provides a statement from-the vendor to this effect. -In our. '

discussions with the vendor's chief engineer on October 16, 1989, we

l. determined this is not a hard and fast position. In fact, we have

p ' observed several . examples where the polysulfone plugs are identified as

L resilient seals in Conax vendor manuals and in literature describing i

h . design features of the Conax assembly. While the material has properties I

that are difficult to classify, the vendor also agreed that the material i

is a compound used as a seal (sealant compound). In the context of the  ;

L regulations, polysulfone is considered a sealant compound and by Cenax H

L literature may also be considered a resilient seal.

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d.. 'In,their! response, the licensee' denied that the cap'and ferrule assembly. i

i s - fl exibl e.- We-agree'with this statement. As indicated in the report,

flexible was considered only in the' sense that the material was deformable- '

and was _ not intended to. imply a flexible joint. -The cap and ferrule'  !

,

assembly used by Conax would logically fall into.the classification of a

flexible metal seal assembly where flexibility- is not considered- a key ,

element.

We. reemphasize that while paragraphs II.G.1, II.G.2 and II.G.3 identify-

several commonly used, broad classifications of seals which must be Type B-

tested, they do' not exclude other types of seals which are pressure-

containing, leakage-limiting boundaries from Type B testing. ,

e. In their response, the licensee states that the Technical Specifications

(TS)- excluded electrical penetrations from those requiring _ Type B testing. ,

TS'4.6.1.2:.d requires testing in accordance with 10 CFR 50 Appendix J and

the omission of electrical penetrations from the-TS does not constitute a

request for' exemption . {

'f. -In their response, the licensee states. that the _ Final Safety Analysis

~

Report (FSAR), Section 5.6.4.2, describes how they comply with 10 CFR 50

Appendix J requirements for . Type B testing. With the exception of the

last sentence, the FSAR addresses only resilient seals and gaskets. The; .;

one sentence about electrical penetrations is deceptive in that it can1be

~l . read; to imply that. potential leakage paths through the penetrations are

sealed with steel to steel-welds. The cap and ferrule assembly is not

described. Since the last sentence is vague and because of the licensee's

commitment to perform-testing in accordance with Appendix J. it cannot be

construed as an exemption from testing electrical penetrations.-  ;

In summary, we concluded that Type B testing of Conax electrical penetrations

-is required and'that the violation is correct as written. .,

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