ML20237F181
| ML20237F181 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 12/21/1987 |
| From: | Bird R BOSTON EDISON CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 87-201, NUDOCS 8712290415 | |
| Download: ML20237F181 (3) | |
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.j,-e-j Ki SOS 70NEDfSON Executive Offices 800 Boylston Street.
i Boston, Massachusetts 02199 Ralph G. Bird Senior Vice President - Nuclear December 21,.1987 BECo Ltr. #87 201 U.S. Nuclear Regulatory Commission
-l Attention: Document Control Desk d
Washington, DC 20555 License No. DPR-35' Docket No. 50-293
Subject:
NRC Inspection Report 50-293/87-32
-l
Dear Sir:
Attached is the Boston Edison Company response to the Notice of Violation-50-293/87-32-01.
l This violation deals with the issue of environmental equipment qualification to peak temperatures resulting from a postulated steam line break in the drywell.
Please contact me directly if you have any questions on this response.
A R.G.
rd BPL/la Attachment cc: Regional Administrator, Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 Sr. Resident Inspector 87122904158%uh3
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ATTACHMENT Rftsponse to Notice of Violation 50-293/87-32-01 Boston Edison Company
. Docket No. 50-293 Pilgrim Nuclear Power Station License No. DPR-35 Notice of Violation As a result of the inspection conducted on August,3-7,10-14 and 20,1987 and in accordance with the NRC Enforcement Policy (10 CFR 2, Appendix C) the following violation was identified.
10 CFR 50.49(e)(1) requires for safety related electrical equipment located in a' harsh environment that the most severe design basis time dependent temperature be established and that the equipment be qualified for this most severe design basis temperature condition.
Contrary to the above as of August 20, 1987, the most severe design basis time dependent temperature had not been established for the following electrical equipment in the drywell; solenoid valve SV-220-44 and cable splice assemblies Q102A, Q102B, Q103A and Q103B.
It had been established only that the above devices were qualified for a large break Loss of Coolant Accident (LOCA) up to 290'F.
This temperature was 30*F lower than the temperature profile for a small break LOCA to which drywell equipment would be subjected.
Subsequent to the inspection, it was determined that these devices were actually qualified to the most severe temperature.
profile.
Resoonse Boston Edison has reviewed the facts presented in the Notice of Violation.
Cause:
When the Boston Edison program to comply with 10 CFR 50.49 was developed, the industry was in a state of flux concerning the use of Steam Line Break (SLB) conditions for establishing equipment qualification for BHRs. As a result, the Loss Of Coolant Accident (LOCA) was chosen as the most severe design basis accident affecting electrical equipment in the drywell.
l In response to industry developments on the drywell SLB issue, on November 8, 1986 two Potential Condition Adverse to Quality reports (PCAQ NED 86-164 and PCAQ NED 86-165) were initiated by Boston Edison. These reports documented that SLB peak temperatures were higher than the LOCA peak temperatures and the drywell equipment had not been evaluated for the SLB temperature profile. Corrective action was in progress; however, it had not been completed at the time of the inspection.
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ATTACHMENT (Cont.)
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l Corrective Actions Taken and Results Achieved:-
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1 The following actions provided the basis and mechanism for i
establishing qualification to the SLB profile for existing drywell
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equipment and for future drywell replacement or modified equipment.
A composite temperature profile of the drywell environment resulting from a spectrum of SLBs was incorporated to Drawing No. M632, " Temperature and Pressure, Pipe Break Inside Containment" in September,1987.
"Hork Instruction for Preparing Equipment Qualification Evaluation Work Sheets", NEDHI No. 278, was revised on October 19, 1987 to reference the revised Drawing No. M632.
Environmental Qualification (EQ) to the SLB was established for the drywell equipment required to be qualified in accordance with 10 CFR 50.49.
Documented test reports within the PNPS EQ reference files as of November 30, 1980, provided sufficient basis to establish this qualification.
Corrective actions to be taken and additional actions to avoid future violations:
The affected EQ equipment files are being updated to establish an auditable trail that demonstrates SLB qualification and will be completed prior to plant startup.
A Quality Assurance audit of the EQ program using independent technical expertise is in progress.
This audit will provide additional assurance that the EQ program is in compliance with 10 CFR 50.49.
Safety Consequences:
No adverse safety consequences resulted from this violation as the drywell equipment was found to be qualified to the SLB composite temperature profile.
Date of Full Compliance:
Full compliance for the SLB issue will be documented prior to plant startup when the update of the affected drywell EQ equipment files is completed.
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