05000261/FIN-2017007-06
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Finding | |
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| Title | Penetration F01 Submergence |
| Description | Introduction: The inspectors identified a URI concerning the submergence qualification of Robinson EPA F-01. The qualification may not have qualified the EPA in accordance with NUREG-0588, Category 1 requirements. Description: In 1988, the licensee determined that penetration F-01 would become submerged and subsequently contracted testing to demonstrate qualification. The inspectors reviewed Wyle qualification test report 41175-1, and EGS qualification test report, EGS-TR-903200-04-R000. These two reports were credited for submergence in EQDP-1700 for the CONAX penetrations. The inspectors were concerned that the CONAX penetration F-01 was not tested in its most limiting configuration. To place the penetration pigtails in a configuration that could support qualification, the licensee performed a modification, MOD 977, Repairs to Protect Penetration F-01, to re-terminate the pigtails by adding Raychem heat shrink to provide submergence protection. Modification, MOD 977, specifically figure 1, drawing number C20482, and feed through detail drawing number B190670 revision 1, appears to allow 36 conductors to be bundled together in a single pass through. The EGS and Wiley test reports did not test the 36 conductor configuration or demonstrate that the signals passing through these bundles would remain operable for the duration of submergence as required by NUREG-0588, Category 1 requirements. The inspectors were also concerned that while the termination procedures in MOD 977 required a two inch Raychem overlap, it also allowed a one-half inch overlap during Raychem installation. A one-half inch overlap may not ensure submergence qualification in accordance with EGS qualification report EGS-TR-903200-04-R000. In addition, the EGS qualification used an 8.3 pH caustic solution during submergence testing, which is less than what was required for Robinsons harsh environment design basis (10.5 pH). Title 10 CFR 50.49(d)(3) and (e)(6), RG 1.89 revision 1, C.d.3.a, and NUREG 0588 Section 2.2(5) Qualification by Test, required that equipment that could be submerged must be qualified by testing in a submerged condition to demonstrate operability for the duration required. The inspectors are concerned that F-01 is not qualified for submergence and the pigtails may not meet the requirements for submergence qualification. The licensee entered this concern into their corrective action program as NCR 2167136. This URI is opened to determine if a performance deficiency or violation exists. To resolve this URI, the inspectors need the licensee to address the apparent lack of qualification required by NUREG-0588, Category 1 EQ requirements. (URI 05000261/2017007-06, Penetration F01 Submergence) |
| Site: | Robinson  |
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| Report | IR 05000261/2017007 Section 1R21 |
| Date counted | Dec 31, 2017 (2017Q4) |
| Type: | URI: |
| cornerstone | No Cornerstone |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.21N |
| Inspectors (proximate) | G Ottenberg T Fanelli M Greenleaf S Walker |
| INPO aspect | |
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Finding - Robinson - IR 05000261/2017007 | |||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Robinson) @ 2017Q4
Self-Identified List (Robinson)
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