ML20041C160

Forwards Revised Equipment Qualification Rept Containing Itemized List of Changes Due to Equipment Deficiencies

ML20041C160
Person / Time
Site:	Pilgrim
Issue date:	02/08/1982
From:	Deacon W BOSTON EDISON CO.
To:	Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
82-40, IEB-79-01B, IEB-79-1B, NUDOCS 8202260287
Download: ML20041C160 (5)

Text

. -.4 BOSTON EDISON C O M PAN Y

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• FebruaIM 8* 1982 BOSTON. M ASSACHUSETTS D2199 s-

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Mr. Ronald C. Haynes re ~

g Office of Inspection and Enforcement 2

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@r? ff uclear Regulatory Commission 5

631 Park Avenue 4

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King of Prussia, PA 19406 eb p c4 s License No. DPR-35 Docket No. 50-293 Environmental Qualification of Electrical Equipment-

References:

(a) BECo Letter #81-213 to NRC dated September 11, 1981 (b) USNRC Letter to Boston Edison Company dated June 3, 1981

Dear Sir:

This letter transmits the attached revised Equipment Qualification Report for the Pilgrim Nuclear Power Station (PNPS). The attached report supersedes the previous report submitted via Reference (a) because it includes additional-infomation, notably an item-by-item justification for continued operation considering the equipment qualification deficiencies identified to date, and reflects changes resulting from our continuing equipment qualification efforts ~.

It should be noted that this report is still considered to be a partial response to your June 3, 1981 letter (Reference (b)).

As previously noted in Reference (a), BECo has significantly modified its equipment qualification program as required by Reference (b) and the clarifications provided in the staff's equipment qualification meeting (July 7-10, Bethesda, MD)..A' submittal is being made at this time because the supplemental information provided rep-resents a major milestone in our overall program and will benefit the staff in concluding that there is no concern relative to equipment qualification which would interfere with the continued safe operation of Pilgrim Nuclear Power Station.

Background:

Reference (b) transmitted the Safety Evaluation (SER) for the Environmental 9 'p Qualification of Safety Related Electrical Equipment for PNPS and requested 0

that we provide within 90 days additional information in the following areas

,I as requested in Section 3 and 4 of the SER:

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%l' 8202260287 020208 i #

PDR ADOCK 05000293 P

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-[02 TON E! CON COMPANY i Mr. - Ronald C. Haynes -

- February 8,1982 Page two

1) ' Systems List 2)

Display Instruments-

3) Submergence 4)

Containment Spray 5). Aging 6)

Radiation 7)

Resolutions Shortly thereafter, BECo attended a four-day. equipment qualification meeting in Bethesda, MD, in which the staff presentations indicated the need for BECo to expand the scope of its equipment qualification program in the following eleven specific areas:

1) A complete re-review of all equipment qualification documentation to develop detailed justification-for each-' applicable D0R guideline requirement.

2) A complete re-review of the systems list and restructuring ~ of it to relate the previously identified systems to each of six safety functions.

3) A _ complete re-review of the display instrumentation list and restructuring to facilitate review.

4) An investigation and evaluation of potential submergence outside

' containment beyond the level of detail described in previous high energy line break reports and' including through-wall leakage cracks in moderate energy fluid systems.

5) An investigation and evaluation of the effects of demineralized water on in-containment equipment resulting from manual actuation of containment spray.

6) A detailed status report of progress made on a component basis in evaluating materials susceptible to aging.

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7) A one or two page description of the existing replacement and surveillance / maintenance programs.

i

8) On a component basis the identification of expected life, replacement schedule and start date of schedule,

9) Plant specific radiation analyses for each case where the required value is lower than the staff screening criteria defined in the meeting.

10) For deficiencies identified in the SER, (Appendix B) a proposed cor-rective action or detailed justification when in disagreement with staff findings.

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02 ; TON EOi20N COMPANY Mr.L Ronald C. Haynes February 8,1982 Page three

11) A ' justification for continued operation of _ the facility on an item basis in view of the deficiencies identified in Appendix B of the SER.

I Boston Edison Company provided a partial response to the SER via Reference (a) but noted that a substantial effort was required in-order to provide all the information requested via Reference (b) and in the four-day meeting. ~ In order -

to be responsive to the staff's request, BECo elected to submit a partial

. response and to forward an updated report when it was completed.

The. partial response provided a complete response to Items 1, 2, 3, 4 and 6 of the SER request and Items 1, 2, 3, 4, 5, 6, 7 and 9 of the four-day meeting request.

(All of the radiation values listed in the partial response exceeded the staff's screening criteria, therefore no response was required for Item 9.)

Immediately after making its submittal,'BECo began to_ pursue the remaining items ~.

-Aging (SER Item #5, Four-day Meeting Item #8)

Resolutions (SER Item #7, Four-day Meeting Item #10)-

Item-by-item justification for continued operation (Four-day _ Meeting Item #11)

In recent telephone discussions with BECo, the staff emphasized the need to provide the item-by-item basis for continued operation in an expeditious manner.

Boston Edison Company placed top priority on this task and is at this time sub--

mitting a revised report incorporating this information.

Discussion:

The attached report supersedes the previous report submitted via Reference :(a).

The following represent the most significant differences between this ' report and our previous submittal.

1.

This report includes a justification for continued operation of PNPS on an item-by-item basis in view of the equipment qualification deficiencies identified to date.

Our previous. submittal provided generic justifications and an itemized list'of considerations we applied in evaluating a component's ability to function considering its qualification deficiencies. These evaluations although' previously performed were not considered as being required for submittal. BECo.

was first made aware of-the staff's expectations in this regard at the four-day meeting.

As evidenced by the attached volumes necessary-to document the results of our evaluations, compliance with the staff's request involved a substantial effort justifying the need for additional time beyond the 90 day response period.

2.

The number of outstanding items in this report has been reduced. Ad-ditional information and further reviews of existing information have enabled our reviewers to close out a number or outstanding items.

.~

BO; TON EDEON COMPANY Mr'. -Ronald C. Haynes February 8, 1982 Page fourl

3. :Certain display instruments' identified.in our previous submittal have been listed as exempt in this submittal because further reviews have led us to' conclude that certain instruments are not important to safety.

4.

Appendix D of. this submittal of the report has been updated to reflect the current status of BECo's TMI-Related equipment installations.

5.

The item-by-item justification for continued operatica also includes.

a new outstanding item (DHT) associated with the high temperature condition that' existed in the drywell'as reported in LER 81-055/01T-0.

The effect of the high temperature was factored-in the equipment qualification evaluations and a justification for continued operation was provided for each' component effected.

6.

The' radiation doses associated with-specific components have been revised as a result of further evaluations considering _the exact location of the component and the layout of'the contaminated sources.

Current Status and Future Actions:

The information provided in this revision to the equipment qualification report represents a complete response to the staff's requests except for the following:

1) Aging 2)

Resolutions of outstanding items 3)

Radiation With respect'to aging, BECo has completed detailed material evaluations and aging analyses for all equipment in containment. On a case-by-case basis outside con-tainment equipment will be addressed as part of the total outstanding item resolution process.

Boston Edison Company is continuing its evaluation for a centralized preventative maintenance program.

For equipment. in containnent having a qualified life less than 40 years, we have identified the expected life, the replacement schedule and start date of schedule.

Replacement will still be monitored by the methods identified in Reference (a) pending incorporation into-the maintenance program.

Although BECo considers that its efforts to date have satisfied the intent of the staff's requests regarding aging, it will be continued as an open item pending submittal of the final report.

With respect to resolutions of outstanding items, BECo is continuing its effort; and is in the process of identifying corrective actions and establishing schedules for implementation.

The staff will be advised promptly of the results of these efforts via the final report.

s*

~*

BD3 TON. ERICON COMPANY ~

Mr. TRonald C. Haynes February 8,.1982 Page five With respect.to radiation, the analyses supporting component specific l

radiation doses less than the. staff's screening criteria are currently -

being documented and independently reviewed. These analyses will be submitted in the final report.

==

Conclusions:==

The~ attached report, although a partial response to Reference (b), contains considerable additional information which reinforces our previous.. conclusions

-that there is no concern relative to equipment qualification which would interfere with the continued safe operation of Pilgrim Nuclear Power Station.

i Very truly yours, eg William H. Deacon Acting Manager Nuclear Operations Support Department I

L' cc: Mr. Harold' R. Denton

Attachment:

r (1)

Equipment-Qualification Report Volumes 1 thru 8 L:

L..

02

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