ML20198N521
| ML20198N521 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 01/16/1998 |
| From: | Olivier L BOSTON EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-293-97-12, BECO-2.98.005, NUDOCS 9801210103 | |
| Download: ML20198N521 (4) | |
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Soston Edisem 10 CFR 2.201 Pilgrirn Nudear Power Station Rocky Hill Road Plymouth, Massachusetts 02360 LJ.OIMor Vce President Nuclear and Staten m actor January 16,1998 BECo Lir. 2.98.005 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 License DPR-35 Docket 50-293
SUBJECT:
REPLY TO NOTICE OF VIOLATION (REFERENCE NRC INSPECTION REPORT NO. 50-293/97-12)
Enclosed is Boston Edison Company's reply to the Notice of Violation contained in Inspection Report 50-293/97-12.
Full compliance for the specific penetrations was achieved June 30,1997.
t The following commitment is made:
The " Boston Edison Company Design Guide for Environmental Qualification of Electrical Equipment (TO3)" will be revised by_ April 16, 1998, to reflect the qualification concems identified in this notice of violation to preclude recurrence.
Please do not hesitate to contact me if there are any questions regarding the enclosed reply.
b L. J. Olivier PMK/dg/vio9712a : Reply to Notice of Violation
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cc:
Mr. Alan Wang, Project Manager Project Directorate 13 Office of Nuclear Reactor Regulation.
Mail Stop: ~ OWF.1482 '
U. S. Nuclear Regulatory Commission 1 White Flint North 11555 Rockville Pike Rockville, MD 20852 -
U.- S. Nuclear Regelatory Commission Region 475 Allendale Road King of Prussia, PA 19406 Senior NRC Resident inspector Pilgrim Nuclear Power Station
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Boston E'dison Docket No. 50 293 Pilgrim License No. DPR-35 Reply to Notice of Violation 97-12-02 VIOLATION During an NRC inspection conducted from October 6-10, 1997, the following violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the violation is restated below:
10 CFR 50.49(f) requires each item of electric equipment important to safety to be qualified.10 CFR 50.49(k) allows certain electric equipment to be qualified :n accordance with " Guidelines for Evaluating Environmental Qualification of Class 1E Electrical Equipment in Operating Reactors,"
November 1979 (DOR Guidelines).
DOR Guidelines, Section 5.1, specified tha acceptable qualification methods: As a minimum, the qualification for severe temperature, pressure, and steam service conditions for Class 1E eqt.;pment should be based on type testing.
The licensee selected the DOR Guidelines for the qualification of nine General Electric electrical containment penetrations (Q100E, Q101B, Q102A&B, Q103A&B, Q105A&B, Q106B).
1 Contrary to the above, the nine penetrations, which were equipment important to safety, subject to severe temperature, were not qualified in that the qualification methodology (thermogravimetric analysis and linear slope comparison analysis) used by Boston Edison had not been validated by test results to be equivalent to type testing.
This is a Severity Level IV violation (Supplement I),
REASON FOR THE VIOLATION The subject penetrations were qualified prior to raising the acceptable ultimate heat sink temperature from 65* to 75* Analysis associated with raising the ultimate heat sink temperature resulted in a higher analyzed containment peak temperature that was not enveloped by the original penetration qualification dati Use of analysis and data from a type test report that did not envelope the new cor.tainment analysis peak temperature resulted in the use of thermogravimetric analysis (TGA) test data to qualify the penetrations for the new analytical peak temperature. Section 5.1 of the DOR Guidelines allows the us, of separate tests to establish qualification and states that exceptions to the general guidelines can be justified on a case-by-case basis. In this case, we incorrectly believed using the TGA test data was acceptable.
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8 CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED During the n going evaluation noted above, General Electric provided a test report for their FO2 series of penetraaons (" Low Voltage Power and Control Nuclear Containment Loss of Coolant Accident Qualification Test for 100 Series Electrical Penetration FO2 Program," dated September 13, 1973).
This series of penetrations, having epoxy seals similar to the Pilgrim penetrations, was tested under conditions exceeding those required at Pilgrim. This test report envelopes the peak Pilgrim conductor temperature, eliminating the need to reference the General Electric TGA test data. As discussed in NRC Special Inspection Report 50-293/97-12 " linear slopes analysis" using Arrhenius methodology shows that substantial margin exists between the Pilgrim postulated accident profile and the General Electric test profile to account for the periods where the Pilgrim postulated accident profde is not enveloped. The use of Arrhenius methodology in this application was justified via a materials analysis report (" Oxidation Degradation of Polymeric Materials," dated April 11, 1997) performed by Attran Corporation.
Pilgrim's EQ Document File Ref. 98 Rev. E4 (Wyle Laboratories Report 47066-PEN-1.1 Rev. G) removed reference to the TGA test data and added reference to the General Electric FO2 test report as the basis for qualification of the General Electric primary containment electrical penetrations for the peak conductor temperature expected at Pilgrim.
The Equipment Qualification Data Files for the nine Genera! Electric primary containment penetrations referenced in the NRC inspection report have been revised to reflect the above information.
All EQ files were reviewed to insure that the use of TGA test data to justify the peak required temperature was unique to the subject General Electric electrical penetration. The EQ files were ab o reviewed, based on discussions with NRR personnel, to ensure sufficient margin exists between the required temperature profile and the available test profile when using Arrhenius methodology.
The above issue has been discussed with Boston Edison personnel involved in Pilgrim's Environmental Qualification process.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS The " Boston Edison Company Design Guide for Environmental Qualification of Electrical Equipment (TO3)" will be revised by April 16,1998, to reflect the qualification concems identified in this notice of violation to preclude recurrence.
The use of TGA test data to justify the peak required temperature was unique to the General Electric electrical penetrations; therefore, further corrective steps specific to the enumerated penetrations to avoid further violations of this nature are unnecessary.
DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full compliance was achieved for the enumerated peretrations on June 30,1997, with the approval of the Equipment Qualification Data Files for the General Electric primary containment electrical penetrations.
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