ML20207L067

Advises That Startup from Jan 1989 Surveillance Outage Contingent Upon Resolution of Bunker Ramo Penetrations. Environ Qualification Test Should Be Conducted as Soon as Possible

ML20207L067
Person / Time
Site:	Braidwood
Issue date:	10/11/1988
From:	Holahan G Office of Nuclear Reactor Regulation
To:	Bliss H COMMONWEALTH EDISON CO.
References
NUDOCS 8810170165
Download: ML20207L067 (4)

Text

-

/

~%,

UNITED STATES

["

g NUCLEAR REGULATORY COMMISSION p

g

E WASHINGTON, D. C. 20655 October 11, 1988 Docket No. 50-457 Mr. Henry E. Bliss Nuclear Licensing Manager comonwealth Edison Company P.O. Box 767 Chicago, IL 60609

SUBJECT:

ENVIRONMENTAL QUALIFICATION OF BRAIDWOOD UNIT 2 BUNKER RAM 0 PENETRATIONS By letter dated August 31, 1988, Comonwealth Edison Company (CECO) provided additional information for NRC review which CECO believes, together with earlier information provided to the NRC, demonstrates environmental qualification of the Bunker Ramo penetrations presently being used at Braidwood Unit 2 pursuant to an NRC exemption. As a result, CECO believes that replacement of the four Bunker Ramo penetrations at Braidwood Unit 2 is no longer necessary and testing is not required to demonstrate environmental qualification.

As you know, the concern regarding these penetrations was initially identified during an equipment qualification inspection conducted at Braidwood Unit 2 in February and March 1988 by the NRC. Since that time, the NRC staff has discussed this problem on nup.erous occasions with you and other affected licensees and solicited qualification information from available sources.

Several months ago, the NRC staff requested that each utility, with an operating reactor that has Bunker Raro or Amphenol containment penetration assemblies installed, provide a copy of the qualification documentation that denenstrated the qualification status of the assemblies. The NRC staff completed its review of that information and concluded that 9 1 documentation provided by the licensees was not sufficient to demonstrate o,lification in accordance with the requirements of 10 CFR 50.49.

On August 4,1988, the NRC staff niet with representatives.of the Nuclear Utility Group on Equiptrent Qualification (NUGEQ) to discuss all available qualification information that is applicable to Bunker Ramo or Amphenol penetration assemblies. The objective was to provide industry representatives an additional opportunity to demonstrate qualification. The meeting also provided the NRC staff with the opportunity to discuss available qualification information in a single meeting with representatives from each affected utility.

I 8810170165 881011 p f[

DR ADOCK 0500 7

e

-2 NUGEQ presented information in the form of an affidevit from an engineer who participated in conducting environmental qualificr. en tests on the penetration assemblies in question during 1977 ar/.978.

An important element in the qualification of the penetration assemblie. 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 messurements 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 NRC staff has reviewed the information contained in your August 31, 1988 submittal.

The information available for review, 'ncluding 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 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 not in accordance with a test plan.

Further discussions without additional test data are likely to be of little value. The necessary action to establish oualification 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.

In part 2.0 of Facility Operating License NPF-77, for Braidwood Unit 2, the NRC granted a temporary exemption to 10 CFR 50.49(f) and 10 CFR 50.49(j) with the following condition:

'The exemption is required until startup following the Braidwood Unit 2 surveillance outage scheduled in January 1989 prior to which time the unqualified Bunker Ramo containment penetration j

assemblies in question will have been qualified or replaced with j

ones which have been previously demonstrated to be qualified per the licensing criteria applicable to the facility.'

. Since the information provided in the August 31, 1988 Ceco letter does not demonstrate environmental qualification of the Bunker Ramo penetrations in use at Braidwood Unit 2, License Condition 2.0 remains in effect and startup from the January 1989 surveillance outage will be contingent upon the successful resolution of this issue.

Sincerely, k}

i Gary M. Holahan, Acting Director Division of Reactor Projects III, IV, V, and Special Projects Office of Nuclear Reactor Regulation i

i I

(

-,----.-,_n

October 11, 1988

, Since the infomation provided in the August 31, 1988 CECO letter does not demonstrate environmental qualification of the Bunker Ramo penetrations in use at Braidwood Unit 2, License Condition 2.D remains in effect and startup from the January 1989 surveillance outage will be contingent upon the successful resolution of this issue.

Sincerely, 1

Gary M. Holahan, Acting Director Division of Reactor Projects III, IV, V, and Special Projects Office of Nuclear Reactor Regulation DISTRIBUTION

' Docket file.

OGC NRC & Local PDRs EJordan PDIII-2 r/f BGrimes GHolahan ACRS(10)

MVirgilio PDIll-2 plant file i

LLuther SSands PShemanski DMuller LShao AThadani qPDI

p. c.

PDIII-2 PDIII-PDIII-2 SSands:dmj PShemanski LLuthe DMuller

/0/ g /88

/d / 6 /88 a/o6/88

• • 10/ 6 /88 f,

j r.

(A)AD RS35 A

??

JCrai MVirgilio r

a,an

( o / fc)g/88 M/ 6 /88

/. / #( /88

h

^

/0lJ'&

-