Text

RO 77-12:on 770809,certain Requirements of Util Specs 82-3832 & Bechtel Specs SEP-304 Not Met Prior to Containment Penetrations Installation.Caused by Lack of Specific Documentary Evidence Supporting Qualification
	ML13308B451
Person / Time
Site:	San Onofre
Issue date:	09/08/1977
From:	Ottoson H; SOUTHERN CALIFORNIA EDISON CO.
To:	; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
	RO-77-12, NUDOCS 8103050946
	Download: ML13308B451 (13)
	v • d • e

LER 77-12 LICENSEE EVENT REPORT CONTROL BLOCK:

[PLEASE PRINT ALL REQUIRED INFORMATION]

1 6

LICENSEE LICENSE EVENT NAME LICENSE NUMBER TYPE TYPE I 1l Ic 1A Is loislil 10 10 1-lololololol-lo10 1411 111 1111 L iI 7

89 14 15 25 26 30 31 32 REPORT REPORT CATEGORY TYPE SOURCE DOCKET NUMBER EVENT DATE REPORT DATE CONTcoTI mI iI LI LU I 01o51 1-012 101 61 01 81 01 917 7 0177 7

8 57 58 59 60 61 68 69 74 75 BO EVENT DESCRIPTION Durina review of documentation received from the manufacturer of new containment I

7 8 9 80 Ipenetrations, Southern California Edison determined that certain requirements of Edison 7

B 9 80

[EB ISpecification No. 82-3832 and Bechtel Specification No. SEP-304 had not been met priori 7

8 9 80 E~

[to the installation of the penetrations.. Corrective action includes:

(1) performance 7

8 9 80 Qg [of radiation resistance tests, (2) either ongoing qualification or replacement, **

l 7

8 9 PRIME 80 SYSTEM CAUSE COMPONENT COMPONENT CODE CODE COMPONENT CODE SUPPLIER MANUFACTURER VIOLATION M[x I X[I L IP E IN IEI TI RI L

IA 1318 101 1 N I 7

8 9 10 11 12 17 43 44 47 48 CAUSE DESCRIPTION MOB ILack of specific documentary evidence supporting qualification as rPquired by Edison 7

8 9 80 E ISpecification No. 82-3832 and Bechtel Specification No. SEP-304.

I 7

8 9 s

7 89 80 FACILITY METHOD OF 80 STATUS

% POWER OTHER STATUS DISCOVERY DISCOVERY DESCRIPTION LE

[1 00 N/A I

D I

iscovered during documentation 7

8 9

10 12 13 44 45 46 review 60 FORM OF ACTIVITY COrITENT RELEASED OF RELEASE AMOUNT OF ACTIVITY LOCATION OF RELEASE I

Lz I.JI N/A N/A 7

8 9

10 11 44 45 80 PERSONNEL EXPOSURES NUMBER.

TYPE DESCRIPTION

[TE 1 1ol o0 [z I I N/A 7

8 9 11 12 13 80 PERSONNEL INJURIES NUMBER DESCRIPTION B IoL 0of I N/A 7

8 9 11 12 80 OFFSITE CONSEQUENCES 15E N/A 7 89

.80 LOSS OR DAMAGE TO FACILITY TYPE DESCRIPTION 16 IZ I

N/A 7

8 9 10 80 PUBLICITY M I N/A 7

8 9 80 ADDITIONAL FACTORS lEvent Description (cont'd) **

(3) implementation of new quality assurance procedure 1

7 6 9.

80 M1l [(77-12).

7 89

.80 NAME:

H. L. Ottonn PHONE: (213) 572-1989 GPO 881-667

ENCLOSURE 1 Report Concerning Deficiency In Electrical Penetration Assembly Qualification Documentation San Onofre Nuclear Generating Station, Unit 1 September 8, 1977 INTRODUCTION In an August 9, 1977 telephone conversation to the Nuclear Regulatory Commission (NRC), Region V office; Southern California Edison (Edison) identified deficiencies relative to qualification documentation provided for electrical pene tration assemblies supplied by the Bunker Ramo Corporation (Amphenol).

The penetrations were supplied in connection with work accomplished during the 1976/1977 refueling outage. Eleven containment penetrations were purchased.

Two of these pene trations were used for electrical power to the residual heat removal pump motors and were purchased by Edison.

The other nine penetrations were purchased by Bechtel. One of these was used for containment integrated leak rate test instru mentation and the remaining eight are stored as spares.

Documentation was submitted by Amphenol to both Edison and Bechtel, certifying compliance with Edison and Bechtel procurement documents prior to installation and use of the penetration assemblies.

A subsequent detailed review by Edison and investigation of all documentation submitted revealed the deficiencies discussed herein.

DESCRIPTION OF DEFICIENCY The procurement documents under which the electrical pene tration assemblies were purchased require compliance with Edison Specification No. 82-3832 and Bechtel Specification No. SEP-304, both of which require compliance with require ments presently contained in IEEE Standard No. 317-1976, IEEE Standard for Electrical Penetration Assemblies in Containment Structures for Nuclear Power Generating Stations.

-2 The deficiencies detailed below result from lack of specific documentary evidence supporting qualification as required by IEEE-317-1976 and from failure to comply with specific specifi cation requirements. The deficiencies reported are as follows:

1. Radiation Resistance IEEE-317-1976 (Section 6.3.2) requires testing on all penetration materials not known to be nondegradable by radiation to verify that these materials will maintain physical and electrical properties required to function as designed in the specified service conditions.

Review of qualification documentation submitted by Amphenol indicates that this testing was not performed on the phenolic material utilized as cable supports.in the penetration assembly.

2. Thermal Cycling and Aging/Design Basis Event Tests The minimum specified design life for the penetrations supplied is 35 years. Determination of the qualified life of the electrical penetration assemblies supplied to Edison was based on the analysis of results of prototype tests. These tests were performed to a different aging and LOCA profile than that specified; however, an analysis performed by an Amphenol consultant correlating available prototype test data to specification requirements, concludes that the penetration assemblies have a "qualified life" of at least 5.74 years.

This conclusion does not necessarily reflect prototype test failures, but merely represents the fact that suffi cient data was available to show analytically, a qualified life of at least 5.74 years.

3. Repeat Rated Continuous Tests IEEE 317-1976 (Section 6.4.12) requires rated continuous current testing subsequent to seismic testing of pene trations.

This test was not performed as specified.

ANALYSIS OF SAFETY IMPLICATIONS

1. Radiation Resistance:

Review of the design of the penetration assemblies indicates that failure of the cable supports due to material degradation will not affect the integrity of.the pressure boundary. Furthermore, failure at the supports would not be expected to result in the loss of the ability to provide the required power, since stresses in the cable following a support failure would not be sufficient to damage the cables. These conclusions are based on a review of the physical configuration of the penetrations and design parameters of the cables and terminations used.

-3

2. Thermal Cycling and Aging/Design Basis Event Tests The documentary evidence presented by Amphenol supports a qualified life of at least 5.74 years which is less than the required 35 year design life.

Although this conclusion means that some form of ongoing testing or periodic penetration assembly replacement must be instituted, it presents no immediate impact on safety within the initial qualified life of at least 5,74 years.

3. Repeat Rated Continuous Current Test The purpose of this test is to verify that the penetration assembly will not experience any loss of function or ability to function as specified resulting from seismic events.

To satisfy the intent of this requirement, Amphenol per formed rated continuous current tests prior to the seismic test.

The penetrations were then subjected to a continuous continuity test at rated voltage during and after the seismic test.

No discontinuities were recorded.

Although the specification test was not performed, the continuity test results, along with an Amphenol analysis of stress data from short circuit testing, are considered adequate to demon strate acceptable performance of the penetration during and after a seismic event.

CORRECTIVE ACTION TAKEN With identification of the specific deficiencies addressed in this report, immediate action was taken to obtain the required additional documentation.

The present status of Edison's and Amphenol's efforts is as follows:

1. Alnphenol is now in the process of performing radiation resistance tests on cable support material samples.

2. Discussion between Edison and Amphenol has resulted in identification of the following course s of action available to provide documentation supporting the required 35 year qualified life.

Edison will pursue one of the following options after additional evaluation.

A. Ongoing Qualification:

IEEE 323-1974 allows ongoing qualification in the event that equipment has a qualified life less than the required design life of the nuclear generating station.

As it applies to the subject penetrations, additional type tests including thermal cycling and aging, seismic, continuous current, and design basis event tests may be required.

These tests would be in accordance with Section 6.4 of the IEEE 317-1976 and following the Design Basis Event environmental conditions specified.

-4 B. Module Replacement:

The other alternative being considered is re-placement of existing design modules with modules presently undergoing generic qualification testing to IEEE 317-1976 by Amphenol. These generic tests would envelope Edison's specified requirements including DBE and design life.

3. To give positive assurance that all future equipment accepted and installed is fully documented, development of a new Edison quality assurance procedure was begun immediately. When the procedure is implemented, appro priate training will be conducted in its use. The procedure will provide implementation of requirements in 10CFR50, Appendix B, Criterion VII, as it relates to verification of documentary qualification evidence required by procurement documents.

SCHEDULE The schedule established for the corrective action now in progress is detailed as follows:

1. Radiation tests on cable support materials are now in progress. Amphenol will complete these tests by September 16, 1977.

2. Edison and Amphenol are presently determining which approach to providing qualified life documentation will be implemented. A decision to replace penetration modules with fully qualified modules or to perform additional type tests on a prototype of the installed penetrations will be made prior to October 21, 1977.

Implementation will be completed as rapidly as possible consistent with test scheduling and material delivery.

All work must be completed and all documentation will be furnished for either alternative selected prior to January 1982.

3. The new quality assurance procedure being written as part of the corrective action will be implemented by December 5, 1977.

CONCLUSION This report has identified deficiencies in qualification documentation of electrical penetration assemblies for San Onofre Nuclear Generating Station, Unit 1. These deficien cies, do not adversely affect the safety of operations; however, the documentation received by Edison does not totally confirm acceptable penetration performance subse quent to operation beyond 5.74 years under the specified environment.

-5 Effective corrective action is now being taken to provide the documentation necessary to qualify the penetrations as required by the procurement documents and to ensure against further deficiencies of the type described in this report.

ENCLOSURE 1 Report Concerning Deficiency In Electrical Penetration Assembly Qualification Documentation San Onofre Nuclear Generating Station, Unit 1 September 8, 1977 INTRODUCTION In an August 9, 1977 telephone conversation to the Nuclear Regulatory Commission (NRC), Region V office; 'Southern California Edison (Edison) identified deficiencies relative to qualification documentation provided for electrical pene tration assemblies supplied by the Bunker Ramo Corporation (Amphenol).

The penetrations were supplied in connection with work accomplished during the 1976/1977 refueling outage.

Eleven containment penetrations were purchased. Two of these pene trations were used for electrical power to the residual heat removal pump motors and were purchased by Edison.

The other nine.penetrations were purchased by Bechtel. One of these was used for containment integrated leak rate test instru mentation and the remaining eight are stored as spares.

Documentation was submitted by Amphenol to both Edison and Bechtel, certifying compliance with Edison and Bechtel procurement documents prior to installation and use of the penetration assemblies.

A subsequent detailed review by Edison and investigation of all documentation submitted revealed the deficiencies discussed herein.

DESCRIPTION OF DEFICIENCY The procurement documents under which the electrical pene tration assemblies were purchased require compliance with Edison Specification No. 82-3832 and Bechtel Specification No. SEP-304, both of which require compliance with require ments presently contained in IEEE Standard No. 317-1976, IEEE Standard for Electrical Penetration Assemblies in Containment Structures for Nuclear Power Generating Stations.

0/ 3OC c?/

-2 The deficiencies detailed below result from lack of specific documentary evidence supporting qualification as required by IEEE-317-1976 and from failure to comply with specific specifi cation requirements.

The deficiencies reported are as follows:

1. Radiation Resistance IEEE-317-1976 (Section 6.3.2) requires testing on all penetration materials not known to be nondegradable by radiation to verify that these. materials will maintain physical and electrical properties required to function as designed in the specified service conditions. Review of qualification documentation submitted by Amphenol indicates that this testing was not performed on the phenolic material utilized as cable supports.in the penetration assembly.

2. Thermal Cycling and Aging/Design Basis Event Tests The minimum specified design life for the penetrations supplied is 35 years. Determination of the qualified life of the electrical penetration assemblies supplied to Edison was based on the analysis of results of prototype tests.

These tests were performed to a different aging and LOCA profile than that specified; however, an analysis performed by an Amphenol consultant correlating available prototype test data to specification requirements, concludes that the penetration assemblies have a "qualified life" of at least 5.74 years.

This conclusion does not necessarily reflect prototype test failures, but merely represents the fact that suffi cient data was available to show analytically, a qualified life of at least 5.74 years.

3. Repeat Rated Continuous Tests IEEE 317-1976 (Section 6.4.12) requires rated continuous current testing subsequent to seismic testing of pene trations.

This test was not performed as specified.

ANALYSIS OF SAFETY IMPLICATIONS

1. Radiation Resistance:

Review of the design of the penetration assemblies indicates that failure of the cable supports due to material degradation will not affect the integrity of the pressure boundary. Furthermore, failure at the supports would not be expected to result in the loss of the ability to provide the required power, since stresses in the cable following a support failure would not be sufficient to damage the cables. These conclusions are based on a review of the physical configuration of the penetrations and design parameters of the cables and terminations used.

-3

2. Thermal Cycling and Aging/Design Basis Event Tests The documentary evidence presented by Amphenol supports a qualified life of at least 5.74 years which is less than the required 35 year design life.

Although this conclusion means that some form of ongoing testing or periodic penetration assembly replacement must be instituted, it presents no immediate impact on safety within the initial qualified life of at least 5.74 years.

3. Repeat Rated Continuous Current Test The purpose of this test is to verify that the penetration assembly will not experience any loss of function or ability to function as specified resulting from seismic events.

To satisfy the intent of this requirement,' Amphenol per formed rated continuous current tests prior to the seismic test.

The penetrations were then subjected to a continuous continuity test at rated voltage during and after the seismic test.

No discontinuities were recorded. Although the specification test was not performed, the continuity test results, along with an Amphenol analysis of stress data from short circuit testing, are considered adequate to demon-.

strate acceptable performance of the penetration during and after a seismic event.

CORRECTIVE ACTION TAKEN With identification of the specific deficiencies addressed in this report, immediate action was taken to obtain the required additional documentation.

The present status of Edison's and Amphenol's efforts is as follows:

1. Amphenol is now in the process of performing radiation resistance tests on cable support material samples.

2. Discussion between Edison and Amphenol has resulted in identification of the following courses of action available to provide documentation supporting the required 35 year qualified life. Edison will pursue one of the following options after additional evaluation.

A. Ongoing Qualification:

IEEE 323-1974 allows ongoing qualification in the event that equipment has a qualified life less than the required design life of the nuclear generating station.

As it applies to the subject penetrations, additional type tests including thermal cycling and aging, seismic, continuous current, and design basis event tests may be required.

These tests would be in accordance with Section 6.4 of the IEEE 317-1976 and following the Design Basis Event environmental1 conditions specified.

-4 B. Module Replacement:

The other alternative being considered is re-placement of existing design modules with modules presently undergoing generic qualification testing to IEEE 317-1976.by Amphenol. These generic tests would envelope Edison's specified requirements including DBE and design life.