ML20210U278
| ML20210U278 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 02/06/1987 |
| From: | Turbak M COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 2685K, NUDOCS 8702180430 | |
| Download: ML20210U278 (6) | |
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') Commonwealth Edison
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~ ' One Fird National P'aza, Chicago Illinois l
\\'v'/ Address Reply to: Post Office Box 767 Chicago, Illinois 60690 - 0767 February 6, 1987 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Quad Cities Station Units 1 and 2 Response to IE Inspection Reports Nos. 50-254/86016 & 50-265/86016 NRC Docket Nos. 50-254 and 50-265 Reference (a): Letter from J. G. Keppler to C. Reed dated January 3, 1987
Dear Mr. Keppler:
This letter is in response to the inspection conducted by your staff during the period October 9 through December 4, 1986, of certain activities at Drecden Station. The referenced letter indicated that certain activities appeared to be in noncompliance with NRC requirements and required a written response. The Commonwealth Edison Company's response to the Notice of Violation is provided in Attachment A.
Your staff also requested an assessment of drywell head gasket material compatibility sufficient to support an independent evaluation in i
the above referenced inspection report. Our assessment can be found in Attachment B to this letter.
If you have any further questions regarding this matter, please contact this office.
Very truly yours, W.M H. S. Turbak Operating plant Licensing Director cc: NRC Resident Inspector - Quad Cities 2685K 8702180430 870206 DR ADOCK 0500 4
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i ATTACIWWNT A-COlW0NWEALTH EDISON COMPANY RESPONSE TO NOTICE OF VIOLATION 1-i As a result of the inspection conducted on October 9 through 4
December 4, 1986, and in accordance with " General Policy and Procedures for.
I NRC Enforcement Actions," 10 CFR Part 2, Appendix C, (1985), the following violation was identified:
4 Item of violation:
i 10 CFR 50, Appendix B, Criterion XVII, as implemented by CECO Quality Assurance Manual, Quality Requirement l'i.0, requires that Quality Assurance records include items which are related to the safe operation of the Station; which document the repair or modification of station equipment; and which provide inspection data for results of reviews, tests and material analysis.
4 Contrary to the above, the drywell head flange gasket was changed from one recomended by the flange designer, Chicago Bridge and Iron, and made of Garlock Material No. 8364, to one made by J-BAR Incorporated, Compound No. 3301, without documented evidence of a design evaluation or material analysis review to determine whether the gasket materials were compatible.
Discussion:
In the late 1970's, the station ordered 40 durometer silicone rubber compound gasket material to replenish stock gasket material. The station received 40 durometer, silicone rubber gasket material manufactured by J-BAR.
This material was deemed adequate for use in the drywell head since the Garlock material was also a 40 durometer, silicone rubber
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compound. At that time all gasket material had been purchased as non-safety related.
Corrective Action Taken and The Results Achieved:
I On April 23, 1984 the classification of the Drywell Head gasket material was reclassified from non-safety related to safety-related through the use of a " classification of Spare Parts Evaluation". Previously purchased and stored gasket material was upgraded to safety-related commer-cial grade by Discrepancy Record #4-2039 and Quality-Receipt Inspections
- 84-965 and 84-966. The store's item numbers were also changed to reflect the new safety-related classification. Also, Action Item Record #86-01 was 4
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. initiated on January 17, 1986 to investigate the availability of an improved gasket seal material. The station has returned to using the Garlock #8364-gasket material in the Drywell Heads and will continue using this material until a better alternative is identified.
i corrective Action to be Taken to Avoid Further violations:
l The station now has in place two vehicles for use in the evaluation of safety-related parts for use in the systems. Procedure QAP 600-4, Technical Evaluation of Replacement parts, is used to ensure the technical adequacy of safety-related replacement parts which have been purchased from an alternate supplier. Parameters such as material composition, physical changes, and dimensional fit are evaluated for compatibility with the original part. The use of checklist QAP 1500-S2,2 Red Tag Parts / Material suitability of Application Data, allows for the evaluation of a safety-related part to be used'in a different application other'than j
originally intended. The utilization of these two vehicles will prevent any further violations of this type.
Date When Full Compliance Will Be Achieved:
The station is currently in full compliance. The safety-related classification of drywell head flange gasket material in conjunction with the present program for replacement parts and material suitability provides adequate assurance that required analysis reviews are properly documented.
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ATTAC15ENT B "J-BAR AND GARLOCK GASKET MATERIAL COMPATIBILITY ASSESSMENT" Two (2) different materials have been used to seal the Drywell Heads at Quad Cities Station. The original material was Garlock 84801.
Later, a J-Bar material was substituted on the basis of the like-for-like nature of the specifications. Like the original material, J-Bar is red silicone rubber. An evaluation of the material specifications, which provide required lhaits for the behavior of the material under various conditions, demonstrates the similarity of the materials, leading to the j
conclusion that both materials should function alike in their application.
Furthermore, with regards to the differences in the specifications, it is
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unknown, even today, exactly what values and material properties or group of properties are necessary.
The following comparison shows the similarity of the material specifications for Garlock 84801 and J-Bar used as drywell head seal material.
The two (2) materials and specifications are:
I)
Garlock 84801 (Style 8364)
Specification: ASTM D-2000 Line call-out: 2GE407, A19, B37, E016, E036, F19, Gil, EA14 Mfr.
Garlock Inc.
Mechanical Packing Division 1666 Division St.
Palmyra, New York 14522-9355 315-597-4811 II) J-Bar Specification AMS 3301 (identifies specific material used at Quad cities)
Mfr.
J-Bar Silicone Corp.
One Brighton Ave.
Andover, New Jersey 07821 201-786-5000 l
. Both specifications describe the properties of rubber.. products.
ASTM D-2000, is entitled " Standard Classification System for Rubber Products in Automotive Applications", and the AMS 3301 is an Aerospace Manufacture's specification for silicone rubber.
Both specifications subject the material to the same tests and' produce similar results. Analytically, the properties for the red silicone rubber materials used are:
J-Bar Garlock-
' Test AMS3301 ASTM D2000 Evaluation Method
- 1) Hardness (Durometer 40 1 5 40 1 5 Same ASTM D2240 points)
- 2) Tensile Strength (psi) 500 min.
700 min.
Garlock 40%
ASTM D412 greater
- 3) Elongation (%)
250 min.
300 min.
Garlock 20%
ASTM D412 greater
- 4) Heat resistance:
ASTM D573 Chg. in hardness (pts)
-5 to +10
+10 max.
similar Chg. in tensile strength (%) -15 max.
-15 max.
same Chg. in elongation (%)
-20 max.
-20 max.
same NOTE: ASTM D573 suggests the test periods to be 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> and 70 hours8.101852e-4 days <br />0.0194 hours <br />1.157407e-4 weeks <br />2.6635e-5 months <br />. However, the J-Bar spec. uses a 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> test period and the Garlock Spec. uses a 70 hours8.101852e-4 days <br />0.0194 hours <br />1.157407e-4 weeks <br />2.6635e-5 months <br /> test period.
- 5) Fluid resistance: #1 Oil:
Chg. in hardness (pts)
-20 to +5 0 to -10 similar Chg. in tensile strength (%) -60 max.
-30 max.
similar within range (0 to -30)
Chg. in elongation (%)
-30 max.
-30 max.
same Chg. in volume (%)
O to +15 0 to +20 similar NOTE: (a) J-Bar material is tested for 70 hrs, at 347'F and Garlock is tested for 70 hrs, at 302*F.
The changes for the two materials are similar, however an exact evaluation can not be made due to the test temperature difference.
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NOTE (b) The Garlock material is also' tested in #3 oil (B036') for 70 hrs, at 302*F.
An evaluation cannot be made for J-Bar since it is not tested in
- 3 oil.
(c) This test is not of great importance, since the Drywell Head Seal :is not an oil environment.
J-Bar Garlock Test AMS3301 ASTM D2000 Evaluation Method
- 6) compression Set:
Percent of original deflection, max 72 25
~see note (a)
J (a) the compression set of the J-Bar spec. indicates that it retains some NOTE:.
resiliency, but less than Garlock.
(100% is zero resiliency)
- 7) Low Temperature Resistance:
Both specs. use test method ASTM D2137, Method A, and test for 3 minutes.
The Garlock is tested at -55'F and the J-Bar is tested at -65*F.
The acceptance criteria that both specs. state is that the materials " PASS" the strike test as described in the test method. This test is not of great significance since the Drywell Head Seal is not operated at such low temperatures.
- 8) Tear resistance:
Both specs. use test method ASTM D624, die B. The test conditions are specified by the method. The requirements of each spec are:
J-Bar (AMS 3301) 55 lbs per in.
Garlock (Gil)
-29 lb. Per in.
NOTE: The J-Bar material is more pliable than the Garlock because its spec.
requires a greater tear resistance.
- 9) Water resistance:
The Garlock spec. considers the changes in hardness and volume in a water environment. Test method ASTM D471 is performed for 70 hours8.101852e-4 days <br />0.0194 hours <br />1.157407e-4 weeks <br />2.6635e-5 months <br /> at 212*F.
The J-Bar spec. does not specify water resistance. However, it should be noted that the Drywell Head Seal is not subjected to water exposure.
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