ML17261A558

Responds to Violations Noted in 870610 Insp Rept 50-244/87-03.Corrective Actions:Addl Positive Sealing Provided at detector/connector-cable Interface for Victoreen high-range Radiation Monitor

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

Notice of Violations

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:

A.10CFR50.49(f)

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.

10CFR50.49(k)

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

penetrations<

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

penetrations>

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

penetrations

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.