ML20106C697

Request for Show Cause Order,Per 2.206,to Suspend or Revoke OL Due to Hazardous Conditions at Plant Site

ML20106C697
Person / Time
Site:	Pilgrim
Issue date:	10/20/1984
From:	Doherty J DOHERTY, J.F.
To:	Office of Nuclear Reactor Regulation
Shared Package
ML20106C679	List: ML20106C676 ML20106C697
References
2.206, NUDOCS 8410240269
Download: ML20106C697 (15)

Text

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Octob;r 20, 1984

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE DIRECTOR OF NUCLEAR REAC-TOR RsGULATION In re:

BOSTON EDISON CO. Docket No. 50-293

'(Pilgrim Station)

JOHN F. DOHERfY'S PETITION /RE UEST s FOR SHOW CAUSE ORDER Pursuant to 10 CFR 2.206 of the Commission's Rules of Practice, John F. Dohorty, of 318 Summit Avenue, Suite No.3, Brighton, Massachusetts 02^35, (617) 232-3853, now files this' Fetition/Ee-uest for an Order to Show Cause under 10 CFR 2.202, to the Director of Nuclear Reactor Regulation, that the Director institute a proceeding to susoend or revoke the Onerating License for the Pilerim Station ( OL Uumber: DPR-35) by serving the Licensee, Boston Edison Comunay,with an Order to Show Cause why the said Operatine uicenseshould not be revoked or sus-nended due to the hazardous conditions at the Pilgrim Station enumerated in this petition / request. (infra.)

BASIS FOR THE PETITION / REQUEST The twenty four items below were develooed after review of a technical evaluation report (TER) for the Pilvrim Station, oerformed br the Franklin Research Center, (NRC Controet No. 03-79-118)and Reolies by the Boston Edison Comnar.y (BeCo) in a letter from William D. Harrington (BeCo) to Domenic B. Vassallo (NBC) of May '7,1983 (NRC a+ 9sion No. 9305200447).

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O kihen summed, the several currant cualification deficiencies in the items indicate the Pilcrim Station now cannot be safely ooerated, and that the licensee should be required to~ show cause under 10 CFR 2.202 and 10 CFR 2.206 why its license to coerate should.

not be susnended until the hazards are corrected or revoked if.they are not to be corrected.

The twenty-four items follow:

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.(d) Rockbestos Corp. manufactured cables are used in the nobla gas monitoring system. These cables have been found I

to have been -ualified by testing single conductors only when the cables were multiconductor cables. In addition these cables failed qualification tests due to the for-mation of voids in. oxidized, extruded dielectric which occured during thermal qualification testing. Fockbestos then re-ualified.using an aged cable . jacket in the manu-facturing nrocess, however Pilerim Station does not have such cables in the noble gas monitoring system. In event of a reactor accident the release of Krypton and Radon, two noble gases might well go unmonitored if these cables are not qualified.

. (2) Fenwal Temoerature switches (Model No. 1700240) are in ese in the HPCI ous, room to control the'HPCI area cooler. The TER states the switches had not been reolaced, but. the BeCo Justification for. Oneration (JuCO) indicates t re,lacement was made. However BeCO states the switches.

are cualified because an LOCA of magnitude sufficient to exceed the qualifications of the switches would be so great as to preclude the mitigation use of the HPCI. This reason-

. ing.is based on the idea that all circumstances have been

[ envisioned, rather on conservatism which is the basis of I good fortune. Such conservatism should be olaced in the device in order to maximize the chances of mitigating the most severe LOCA's since severe LOCAs entail the greatest threat to persons and plant.

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(3) The hydrogen analyzer (Comsin Delohi Model KIV)was not qualified in the TER due to insufficient data. BeCO in its May 1983 reoly or JUC0 states that the radiation 6

testing of the equipment was to 1 x 10 rads, while the a0 years plus LOCA dose is identical. Radiation dose to units in sections of a clant are difficult to measure with certainty. For instanc., if the broken pipe is aimed Ot a comoonent the subsequent radiation field will differ from a pipe which hapnens to point 180 away from the co=-

nonent on break. On aging cualification, BeC0 has not committed to any time when its aging qualification will be. completed.

(4) The Pilerim Station uses Barten Model 238 to indicate whether automatic isolation of the RCIC syste, has occured.

Licensee cited material for showing a61ng qualification has been indicated in the TER as not being similar enough to the case of this model to cualify it. In addition hueidity testin6 was not checked for duration in even these tests.

(5) The Pilerim Station uses Fenwal Model 1700240 temper-oture switch in the RHR piping room for elem up leak de-tection. This safety related switch was indicated in the TER to be not cualified in a cost accident (LOCA) radiation cnvironment. BeC0 indicates the cocoonent has been suc-cessfully tested to 1 7 x 100 rada. However, exposure will be 2.86 x 10 5 rads at twelve years (1985).2 / liot withstanding BeCo believes the nresence of asbestos in the most limiting

• / That is, when Filerim Station has 12 years of operation.

r radiation cualification substance in the equipment will

. enhance operability of the item, plus there will be ceri-odic surveillance. This does not cualify the switch in event _of a LOCA. On this same item, the TER found that the licensee referenced document on pressure qualification

'did not cualify the temperature switch for "various pressure environments". The item is recuired for detection of a main steam line break (MSLB). While the MSLB is bounded by the double ended nipe break, detection of the MSLB is oresumed in its analysis. Cn areing, the TER found the licensee referenced document inadecuate to demonstrate

~ualification. BeCo merely states it will continue ageing evaluation, with no commitment as to comoletion.

(6) The Pilerim Station uses Conax Coro Model " Modular Tyoe" electrical penetrations for the drywell, which, of course, control containment leakage from the dry-well. The licensee submitted a recort which the TER cited did not cualify these for ageing, or qualification time. As these devices are located in the center of the containment, they are not easfly renlaced. The TER states they cannot determine if Teflon or Polysulfone was used in the manufacture of these electrical penetrations, a fact of evident importance to them. The licensee only states it will attemot to provide additional documentation at a future date, and ignored this implied question. This disreEard is disturbing in view of the TER's special con-cern.

.(7) Pilerim Station uses the Barton Model 289A D/P switch to send a low flow trio signal to the control room. The TER states the ,rincioal " environmental service condition" is radiation for this component, and that original material cubmitted for cuelification by the licensee was insufficient.

6 The BeCo JUC0 cites a test reference recort showing 3 x 10 rads cualification where the accident dose plus normal 40 years dose is 1.14 x 10 7 rads. Hence this item has not been shown to cualify for radiation exnosure for up to one-third of the maximum dose it may be recuired to sustain in the max-mum accident.. The peak service temoerature for this compon-ent is 248 F, while the ceak -ualification temoerature is 212 F. BeCo justifies continued operation on the basis that the maximum service temperature is for less than a minute. The ability of the plant operator to know what is going on during a reactor accident is critical to safe shutdown of the olant. If small parts (low mass) in these switches are destroyed by temoeratures in excess of 212 F, the information critical as it may be, will be lost in this safety related system.

(8) Pilgrim Station uses the Barksdale Corp Model B2TA12SS

. pressure switch for the SCRAM-High Pressure signal transmission.

The licensee has not -ualified these for radiation, and its first submission for the TER did not nualify the swithhes for humidity and temperature because the test conditions did not envelope the design basis accident conditions. The May 1983,JuCo baldly states the switches are qualified for steam exoosure, without citing conditions or results of such tests.

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Pilgrim Station uses Limitor-ue Model SMB3 motorized (9) valve actuators for a block valve for the core scray in-jection loop. In I &E Insnection Notice 83-72 (Oct. 28, 1983.at p. 15), it states, "Limitorcue has verbally stated that the class B insulation motors rated for a 40 00 ambient temne'ature have act undergone qualification testing in accordance with IEEE Standard 382-1972 for the specified normal, accident, and costaccident environment." Failure of these valves due to long term ageing could result in re-actor cressurization, or in the LOCA secenario could result in inability to bring in the mitigation effects of the low pressure ECCS systems of Pilerim Station.

(10) In an enclosure to a letter of May ll,1983, from Domenic B. Vassallo (NRC) to A. Victor Morisi (BeCo) Mr.

Vassallo states by is,lication that the automatic depres-urization system (ADS) accumulators have not been verified as environmentally cualified for harsh environments in that they may not be certain to be leak croof. The ADS system is safety related and a first line of defense in event of ATWS or many reactivity insertion events. Failure of the accum-ulators, mirht also result in at least one partially opened safety / relief valve resulting in a small break LOCA event cumulative to a LOCA or PB00 event.

(11) Pileri, Station utilizec an ASCO Model HVA90405 solen-oid valve '.a the SCRAM soleroid. The SCRAM

• system is assumed

• The acronym stands for " Safety Control Rod Axe Man"

_g-to operate in all the accident scenarios of a serious nature to halt fissioning. Moreover, the Commission recently promulgated an ATWS: rule which in the case of Pilrrim requires no automatic actuation of the chief back-up system to SCRAM, because of clean-uo costs. A cartial failure to SCRAM occured at the Browns Ferry-III BWR on June 28, 1980. The use of environmentally unqual-ified equi 7tment in this significant safety system is unwise, and BeCo should not be permitted to operate un-less it can show thensA300 solenoid valves are environ-mentally cualified.

(12) Solenoid valves in the drywell interior (Target Rock Coro. Model 1/2SMSA01) of Pilgrim Station were cited in the Franklin Research Center TER as not qualified for ageing. These valves are for actuation of the ADS system, an essential system for alleviating LOCA events or reac-tivity insertion events such as turbine trips without byoass or loss of feedwater heater. Licensee referenced recorts (2) were found lac %ing, and one which was offered was subsequently not received by FRC. Therefore, it is unknown if these valves are qualified and Pilcrim Station has now aged 11% years. These valves should be shown en-vironmentally qualified for areing in order for the plant to continue oneration.=!

I/ C urrently Pil rim Station is off-line for pioing repairs.

Onoration is planned to resume in October, 1984

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(13) Pilerim Station uses a Cutler Hammer Coro. Model 6AF685046 motor control center (MCC) in its electrical distribution system. BeCo submitted in its May 1983 letter (enclosure) that this MCC had been radiation cualified to a dosage of 4.6 x10" rads. This is evi-dently the oermissible tolerance level for nylon. How-ever_the FRC TER states (Item #88, P. SA) that nylon is not the limiting material in view of a letter from Cutler Hammer renroduced on the same TER page. BcCo gives 1.3 it 10 0 rads as the 40 year plus accident event maximum service dose. Therefore the MCC is cualified for only 1/3 of the dose that would be ex-pected for the maximum service dose. While it is not given how much of the accident plus 40 years dose is from'the accident, it is true the plant has 11% years of' operation, the dose of which, when added to the accident event dose might well exceed t.he maximum test dose of 4.6 x 10" rads.

(14) Pilerin Station uses a General Electric Company electric motor in the secondary containment isolation and standby gas treatment processes. The motors (2) were found by FRC to be not qualified for radiation doses which could be expected in the event of DOBs.

The TER states the BeCo SCEW sheet renuires 2.8 x 10 7 rads dose,.but the units are qualified but to 5 5 x 10 0 rada. Continued operation where these motors appear greatly un-ualified in these systems which are both relied on to prevent radionuclide release appears un-justifiable.

1 (15) Information on core soray flow is provided to s

operators at the Pilgrim Station by a General Electric Model.555 Flow Transmitter. The TER and the BeCo sub-mittels are in disagreement as to whether this informa-tion performs part of an essential safety function. The FRC,found them (2) not cualified for radiation, temper-ature or ageing. Acolicant cites valve cosition indi-cation (a post-TMI requirement), pump discharge pressure, and motor amoeres (which oresumably are environmentally cualified) as oroviding defense in deoth. Resolution of this disagreement should be acheived before operation is justified.

(16) Pilerim Station uses a level switch in the torus to maintain correct water level. BeCo states that these switches are not recuired to mitigate the effects of a LOCA. Since the switch in used to notify operators the torus trough is too low, it appears safety related. The

" trough" is a seal between the torus compartment and the outside atmosohere. In event of an in containment pipe break radiation would be released to the atmosphere if the seal is not maintained. The coerator can maintain the seal by information from the switches, so these switches are indeed required to mitigate the effects of an accident.

(17) Pilgrim Station uses Yarway model 44180 level in-

-dicating switches in the SCRAM, containment isolation, main steam isolation valve (MSIV) trip, secondary con-

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tainment isolation,and recirculation pump trip. Licensee states this device has been analyzed to be able to with-6 stand radiation in the amount of 2 x 10 rads. It-further states the A0 year life plus DBA radiation does is 1.86 x 10 6 rads as justification for continued operation. There is no substantiation of this statement, and none of the references submitted ;o FRC show radiation testing. (TER, Item #210, p. Sc, 5d), Evaluation of radiation dosage re-quires many assumptions and is inexact in these circum-stances. Where the amount of margin between the " analyzed" tollerance and exoected dose is this close, justification for coeration is lacking. The TER (p. Sj, of this item) states, .. . the information provided is not sufficient to evaluate whether the device is qualified for temperature effects over the 30 day period the licensee states it is re uired... operable." The only test duration was 3% hours.

The licensee in its JUCO states its belief,"' test duration'

-is not a hardware deficiency." Whether it is or not is academic. Where this device is recuired to function in the service of these systems and they were to be qualified for 30 days, it is clear the licensee cannot be heard to say that their duration is of no matter. It is not being conservative to assume operation of these systems can be orecluded simoly because no reuse of them can be forseen in the wake of the initiating accident. With regard to aceing the Licensee makes no commitment in terms of time to nualify these level indicating switches.

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(18) Pilerim Station uses two Yarway Model 4418EC's for reactor vessel water level indication. The TER for this item (Covered in item 210, on p. Sj), indicates that the test duration at elevated temoerature cualified these devices for only 3% hours. The Licensee believes the early part of any DBA shich these units cust with-

-stand will_be of such short duration, that the longer demonstration of operability is unneccessary. However, it is unwise to believe that water level indication will not be imoortant in the BWR vessel more than 3M hours post-accident. The unexoected oath of events at Three Mile Island, indicate that accident recovery may involve long ceriods of time. In a BWR recovery of correct water

-level would etso be significant in accident mitigation.

(19) Filc-im Station uses Robertshaw Coro. Model SL702A1 level switches located in the torus area and normally open, closing on high suppression pool level and signaling the ocerator that a valve should be opened. The TER in-dicates this switch should be required to meet environ-mental qualification rules (10 CFR 50.49) because the single alternative for providing this information is not single failu?>e oroof.and the operator would be required to manually shift to the alternative if this switch were to fail.

(20) BeCo identified to FRC General Electric cable S157279, which was located in the drywell interior for electrical distribution, FRC indicated it thought BeCo had misiden-tified the cable; to which BeCo reclied in its JUCO that it would locate caterial showing the cable cualified. Gen-eral Electric indicated there was no such cable number

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.x in its current index. Thus, there is no indication any information on this interior. cable's environmental cualifications will be' ascertainable.

(21) Pilerim Station uses four Accelerometers located in the drywell interior for SRV (safety / relief) valve monitoring. .The TER was not able to establish any cri-teria other than to indicate these devices failed at conditions greater than those expected during DBA con-ditions in Filerim Station. Thus it.is not established that these will survive accident conditions.

(22) Pilerin Station uses Fenwa,1 Corp. Model 1700240 for leak detection by tencerature in the main steam line, and cleanup systems. The TER considers these devices not cualified for ageing as there was no information on the resin used in the fibreglass insulation provided by the manufacturer.

(23) The Pilerim Station uses Namco Co. Model EA74050100 limit switches for control room display of containment isolation valve nosition, main steam isolation valve

. SCRAM display, and "SR" (safety / relief) valve display according to pp.B-41, and B-67 of the TER. The TER crit-icizes the heat ageing test submitted by BeCo. On p. 5g (Item '148) the LOCA temperature-time curve indicates the switches will be exposed to more than 10" secs of temperature in excess of 200 F., while the environmental cualification 0

test was for a temperature of 200 F. Licensee states, without supoort, that it will be able to cualify this item,in. its May, 1983, JUCO.

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(24) Pilerim Station uses General Electric Co. (GECo)

Model 238X60NLG electrical penetrations located in the drywell interior whose function is to orovide centain ent intecrity while permitting electrical cables to cass to varicus areas of the olant. FRC recorted that contact with GECo which it initiated, indicated that the BeCo submitted documentation of environmental -unlification tests applies to the GECo Tyne 100 penetrations, only. FRC believes the licensee '1as thus failed to meet DOR Guideline #2 which is recroduced on pg. 5b of item #127'of the TER. .The current BECo position is that with later submittals they will be able to -ualify these pene-trations for areing, -ualification time, and qualifi-cation method, but they are currently unqualified.

CONCLUSION The foregoin? twenty-four items with regard to the'Pilerim Station are provided to show that these various qualification deficiencies when summed lead a careful'decisionmaker to the conclusion the Pilgrim Station cannot reasonably.be expected to be operated safely under the current operating conditions granted the Licensee.

Thus, Petitioner / Requester urges the Director of Nuclear Reactor Regulation to revoke the sub. ject operat-ing License or.susnend it until such time as the Licenses

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.- has made changes required to-bring the subject safety related equipment in compliance with the Commission's rules and regulations.

Respectfully submitted, thisW of October, 1984 ohn F. Doherty b

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