ML13331B123
| ML13331B123 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 01/31/1989 |
| From: | Holahan G Office of Nuclear Reactor Regulation |
| To: | Baskin K SOUTHERN CALIFORNIA EDISON CO. |
| References | |
| GL-88-07, GL-88-7, NUDOCS 8902070228 | |
| Download: ML13331B123 (6) | |
Text
o1 UNITED STATES o0 NUCLEAR REGULATORY COMMISSION 1
cWASHINGTON, D. C. 20555 January 31, 1989 Docket No.:
50-206 Mr. Kenneth P. Baskin Vice President Southern California Edison Company 2244 Walnut Grove Avenue P.O. Box 800 Rosemead, California 91770
Dear Mr. Baskin:
SUBJECT:
ENVIRONMENTAL QUALIFICATION OF BUNKER RAMO ELECTRICAL PENETRATION ASSEMBLIES AT SAN ONOFRE UNIT 1, REQUEST FOR INFORMATION The purpose of this letter is to describe the staff's findings and request additional information regarding the resolution of the issues involving the environmental qualification of Bunker Ramo containment penetration assemblies installed at San Onofre Unit 1.
As you are aware, the concern was initially identified during an equipment qualification inspection at Braidwood Unit 2 in February and March 1988.
Since that time, the staff has discussed this problem on numerous occasions with the affected licensees and solicited qualification information from all available sources. Several months ago, the staff requested that each utility with an operating reactor(s) that has Bunker Ramo or Amphenol containment penetration assemblies installed provide a copy of the qualification documentation that demonstrated the qualification status of the assemblies.
The staff has completed its review of that information and has concluded that the documentation provided by the licensees was not sufficient to demonstrate qualification in accordance with the requirements of 10 CFR 50.49.
Specifically, for San Onofre Unit 1, the following is a summary review of the documentation you provided in support of EQ for the subject penetrations:
During the qualification test there were test failures (direct shorts to other conductors and to the test chamber) but re-testing was not performed. San Onofre Unit 1 did not present sufficient acceptable test data and supporting analysis to demonstrate functional operability of Bunker Ramo electrical penetration assemblies during design basis event conditions. (Test Report No. - 123-1247 Rev. A, June 18, 1974. This test was conducted by Amphenol Sams Division in April 1973.)
9902070228 890131 PDR ADOCK 05000206 P
PNU 1D0
Kenneth P. Baskin
- 2 On August 4, 1988, the staff met with representatives of the Nuclear Utility Group on Equipment Qualification (NUGEQ) to discuss all available qualification information that is applicable to Bunker Ramo/Amphenol penetration assemblies.
The objective was to provide industry representatives an additional opportunity to demonstrate qualification. The meeting also provided the staff with the opportunity to discuss available qualification information in a single meeting with representatives from each utility. NUGEQ presented information in the form of an affidavit from an engineer who participated in conducting environ mental qualification tests on the penetration assemblies in question during 1977 and 1978. An important element in the qualification of the penetration assemblies is the insulation resistance (IR) which was measured during the first 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of the testing. The affidavit recounts that this parameter was measured and recorded at least daily during the test in accordance with the test plan. In addition, the affidavit recounts that more frequent measurements of this parameter were taken and recorded within the early stages of the test to monitor concerns regarding the possible flooding of the test chamber. These latter measurements were apparently not made pursuant to the test plan. The data that was taken to determine if flooding was present could not be located and no test reports presenting these data results are presently available.
However, in his affidavit, the engineer who was present at the tests recalls that the measurements which were taken and recorded were in the acceptable range and thus demonstrated qualification of the penetration assemblies. The information available for review including the various test results of Bunker Ramo assemblies which included low IR readings as well as the affidavit is insufficient to demonstrate qualification as required by 10 CFR 50.49. In addition to the technical inadequacies and questions raised by a review of this information, the NRC staff is not prepared to accept recollections of events which occurred in the distant past as a basis for environmental qualification of these important components. Memory, especially of events so distant in time, is not a satisfactory substitute for data records made at the time of the test and in accordance with a test plan.
Further discussions without additional test data are likely to be of little value. The necessary action to establish qualification is to conduct an environmental qualification test as required by 10 CFR 50.49. An acceptable test could be conducted in accordance with the applicable IEEE standard. The tests should be conducted as early as possible. Replacement with qualified penetration assemblies is an alternate approach to testing. Until the tests are completed and evaluated or replacement is completed, the guidance in GL 88-07 to support interim plant operation would be in effect.
You are requested to furnish, no later than 90 days from the date of this letter, your plans and schedule to either qualify, test or replace the subject penetrations-with ones which have been previously demonstrated to be qualified per the licensing criteria applicable to the facility. -The information is sought to assess your timely compliance with the current licensing bases for your facility.
Kenneth P. Baskin
- 3 The reporting and/or recordkeeping requirements contained in this letter affect fewer than 10 respondents; therefore, OMB clearance is not required under Pub.L.96-511.
Sincerely, Gary M. Holahan, Acting Director Division of Reactor Projects III, IV, V, and Special Projects Office of Nuclear Reactor Regulation cc:
See next page
Mr. Kenneth P. Baskin San Onofre Nuclear Generating Southern California Edison Company Station, Unit No. 1 cc Charles R. Kocher, Assistant Mr. Jack McGurk, Acting Chief General Counsel Radiological Health Branch James Beoletto, Esquire State Department of Health Southern California Edison Company Services Post Office Box 800 714 P Street, Office Bldg. 8 Rosemead, California 91770 Sacramento, California 95814 David R. Pigott Mr. Hans Kaspar, Executive Director Orrick, Herrington & Sutcliffe Marine Review Committee, Inc.
600 Montgomery Street 531 Encinitas Boulevard, Suite 105 San Francisco, California 94111 Encinitas, California 92024 Mr. Robert G. Lacy Manager, Nuclear San Diego Gas & Electric Company P. 0. Box 1831 San Diego, California 92112 Resident Inspector/San Onofre NPS U.S. NRC P. 0. Box 4329 San Clemente, California 92672 Mayor City of San Clemente San Clemente, California 92672 Chairman Board of Supervisors County of San Diego 1600 Pacific Highway Room 335 San Diego, California 92101 Director Energy Facilities Siting Division Energy Resources Conservation &
Development Commission 1516 - 9th Street Sacramento, California 95814 Regional Administrator, Region V U.S. Nuclear Regulatory Commission 1450 Maria Lane, Suite 210 Walnut Creek, California 94596
January 31, 19 Kenneth P. Baskin
- 3 The reporting and/or recordkeeping requirements contained in this letter affect fewer than 10 respondents; therefore, OMB clearance is not required under Pub.L.96-511.
Sincerely,
/s/
Gary M. Holahan, Acting Director Division of Reactor Projects III, IV, V, and Special Projects Office of Nuclear Reactor Regulation cc:
See next page DISTRIBUTION Docket file 0C NRC & Local PDRs EJordan PDIII-2 r/f BGrimes GHolahan ACRS (10)
MVirgilio JLee LLuther CTrammell PShemanski GKnighton AThadani Plant file
- See previous c/ rence PDIII-2 PDIII-2 PDV PDV PDV
- PShemans j
- LLuther
- CTrammell
- JLee
- GKnighton 12/29/88 12/29/88 12/29/88 1/6/88 1/10/89 SAD (A)AD:eSP35 AThadni MVirgilio GHolahan
\\
89
/9 89
Mr. Kenneth P. Baskin
- 3 and schedule to either test or replace the subject penetrations with ones which have been demonstrated to be qualified per the licensing criteria applicable to the facility. This information is necessary to enable the NRC to determine whether or not the license for your facility should be/rodified, suspended, or revoked. The information is sought to assess your timely compliance with the current licensing bases for your facility.
Sincerely, Gary M. Holahan, Acting Director Division of Reactor Projects III, IV, V, and Special Projects Office of Nuclear Reactor Regulation cc:
See next page DISTRIBUTION Docket file OGC NRC & Local PDRs Edordan PDIII-2 r/f BGrimes GHolahan ACRS (10)
MVirgilio JLee LLuther CTrammell PShemanski GKnighton AThadani Plant file e~FOIL PDIII-2 PDIII-2 PShemanski:dmj LLuther C rammell ton
- 2.
/' /88 12 /2q /88
/\\/88
/88
/ // /8F SAD (A)AD:DRSP35 (A)D:DRSP AThadani MVirgilio GHolahan
/ /88
/
/88
/
/88