ML19344D607
| ML19344D607 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 03/12/1980 |
| From: | Andognini G BOSTON EDISON CO. |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| IEB-79-01B, IEB-79-1B, NUDOCS 8004250156 | |
| Download: ML19344D607 (5) | |
Text
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y f'S" BOSTON EDISON COMPANY GENERAL offices 800 GovLsTON STREET SosTON. MASEACMUSETTs 02199 G. CARL AMOcaNIN8 EUPERINTENDENT NWILEAN OPERATIONS DEP&WTNENT March 12,1980 BECo Ltr. #80-50 Mr. Boyce H. Grier, Director Office of Inspection and Enforcement Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA.
19406 License No. DPR-35 Docket No. 50-293
References:
- 1) BECo Ltr. #79-55 to NRC; March 6,1979
- 2) BECo Ltr. #79-65 to NRC; March 28, 1979
- 3) BEco Ltr. #79-117 to NRC; June 15, 1979
- 4) BECo Ltr. #79-121 to NRC; June 19, 1979
- 5) BECo Ler. #79-125 to NRC; June 26, 1979
- 6) BECo Ltr. #79-171 to NRC; August 28, 1979
Attachment:
- 1) Pilgrim Unit #1 -IE Bulletin 79-01B 45 Day Response
Dear Sir:
By letter received January 17, 1980 Boston Edison was required by the NRC to address IE Bulletin 79-01B. This Bulletin requested two responses, a 45 day and a 90 day, with information as requested by Enclosure 1 of the Bulletin.
The requirements for the 45 days response as outlined in the Enclosure on Page 3 and clarified in the IE Region 1 Meeting held February 7, 1980 are:
- 1) Master list of safety related equipment located in hostile areas.
- 2) Written evidence of this equipment's qualifications.
3)
Environmental profiles for service conditions considered and qualification tests performed.
Boston Edison in Attachment 1 to this letter is providing its 45 day response for Pilgrim Station #1. We have been unable to supply all the information requested by the NRC at this time.
A discussion of our difficulties and an outline of the review process we have undertaken to comply with this Bulletin follows.
Availability of Oualification Documentation for PNPS #1 Boston Edison under the direction given by IE Circular 78-08 and IE Bulletin 79-01 initiated QA files searches for all relevant information on the qualification of safety-related electrical equipment. The output of that effort indicated the full gamut of types of qualification documentswere contained in our files. This ranged from none available (for much of the GE NSSS equipment), through manufacturer certificates of conformance to the requirements of procurement specifications, to
DOTON EDCON COMPANY Mr. Boyce H. Grisr, Director March 12, 1980 Page 2 detailed copies of type test data and certification of its applicability to Pilgrim. This range of documentation was anticipated based on the development of the 10CfR50 Appendix B' criteria during the project procurement and construc-tion phases and the perceived importance of the various components during these periods.
Please reference FSAR Amendment 20, Part V, comment D1 dated December 1, 1970.
In particular, please note our response to Criteria III, IV, VII (paragraph 2), and XVII. The quality of the documentation 'found in Edison files is in agree-ment with the information provided in our FSAR on our QA programs. Unfortunately,
this level of documentation inhibits a quick response for most aquipment requested by Bulletin 79-01B.
Edison Position on Existing Component Capabilities Edison believes that the environmental capability of electrical equipment, required to function under accident conditions, did receive adequate consideration, during the design and constr'uction phases of PNPS #1, consistent with the NRC and the nuclear industry's knowledge of those effects at that time.
For those electrical components in containment recognized as being essential to proper safety system performance, (i.e. cable, containment penetrations, motor operated valves), qualification tests to verify their capabilities were performed.
Other components were designed and installed using industrial codes, standards and state of the art engineering practices.
Component selections considered the range of service condition anticipated. Discussions with A/E personnel who participated in design evaluations at Pilgrim Station #1, confirmed our understanding that evaluations of safety related equipment capabilities were made.
In particular, detailed re-views of the effects of radiation and elevated operating temperatures were conducted.
Failure mode and effects analyses were also done to insure that system function cap-abilities could be demonstrated. Unfortunately retrievable records documenting these processes do not generally exist.
The only documented information of these evaluations '
is contained in the PNPS #1 FSAR which references such efforts in numerous sections.
Edison's Commitment to Qualification i
Boston Edison understands the requirements of Bulletin 79-01B and considers it appropriate to re-evaluate the qualification of the safety related electrical equip-ment used at PNPS #1. We also intend to re-evaluate this equipment's capabilities considering the guidance provided by recent standards, such as IEEE-323 '74, and other documents such as Attachment 4 to IE Bulletin 79-01B.
Edison is committed to supplying qualification information to the NRC in both an accurate and timely manner. We believe our process, which established priorities for equipment reviews, satisfies both the NRC and Edison's objective of insuring adequate
,l equipment performance.
Under the scope of 79-01B we believe there are 3 priority levels for equipment in i
hostile areas.
I - Equipment inside containment II - Equipment outside containment located in compartments where pipe breaks occur.
1 s
COMN EDl2ON COMPANY Mr. Poyco H. Grier, Dircctor March 12, 1980 Page 3 III - Equipment outside containment located in adjacent compartments which experience reduced effects of these pipe breaks.
For each of these categories a review process has been established which involves each of the following:
I A.
Listing of systems and equipment required to function.
i B.
Development of hostile environmental profiles, r
C.
An initial review of equipment capabilities to quickly identify components which may not be capable of functioning in the hypo-thesized environments.
l D.
A formal review of equipment to verify and document equipment capa-bilities in these environments.
j E.
Verification as necessary, of actual installations.
F.
Further review of equipment to identify components and materials susceptible to significant agitg.
Numerous activities exist under each of these categories. Boston Edison intends to:
1.
Re-examine the documentation which exists to re-verify its acceptability.
l t
2.
Re-develop any analyses or tests which were done and not documented using informaticn, testing and operating experience to date.
3.
Request additional information,.when necessary, from manufacturers, l
contractors, and sub-contractors to substantiate original certifica-tions or analyses.
4.
Request documentation from GE on NSSS components and GE's confirmation j
on the equipment capabilities to function.
5.
Perform tests or modify equipment as needed to insure operability.
i' 6.
Request manufacturers 'and testing labs to consider aging mechanisms for various materials based on service needs.
This process, used to reconfirm equipment capabilities, given the status of f
existing documentation, is a lengthy one.
It cannot be accurately done within a l
short time frame.
If information could be supplied to the NRC on all safety related electrical equipment within the abbreviated schedule required by 79-01B for PNPS #1, it could suffer from any one of the fo116 wing problems:
l
- Lack of substantiation for PNPS #1 equipment.
- Lack of applicability to PNPS #1 equipment.
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4
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. CorNi3N EDCON COMPANY Mr. Boyc3 H. Gricr, Dirtetor March 12, 1980 Page 4
- Poor definition of the requirements for components (i.e., safety function, required operating times, etc.)
- Unnecessary modifications to systems which have performed reliably over 8 years.
- A short term intense effort to satisfy Bulletin 79-01B which does not establish a process for review of future equipment replacements or modifications.
Status of Work to Date pnd Planned Submittal Schedule The status of the work progress to date is as follows:
- For Priority I (Equipment inside containment) Categories A, B, C, D, and E are essentially complete.
- For Priorities II, III Category A is completed.
Category C has been completed based on general estimates of environmental profiles.
Categories B and D are in progress.
This submittal provides information on the completed work to date. Future sub-mittals will be provided every 90 days to supplement this information until all the equipment listed in this submittal has been acceptably reviewed.
Summary Boston Edison believes that the quality of the information to be provided and the confidence level we can all place on these reviews are directly related to the thoroughness of these evaluations. References 1) thru 6) provided information on our work under Bulletin 79-01. We believe the content of these responses indicates our commitment to reporting and rectifying any conditions which our reviews indicate may involve unqualified equipment.
Should you have any questions or concerns regarding this matter please contact us at your convenience.
Very truly yours, n
Commonwealth of Massachusetts)
County of Suffolk
)
]
Then personally appeared before me G. Carl Andognini, who, being duly sworn, did j
state that he is Superintendent - Nuclear Operations Deportment of Boston Edison i
Company, the applicant herein, and that he is duly authorized to execute and file the submittal contained herein the the name and on behalf of Boston Edison Company and that the statements in said submittal are true to the t est of his knowledge and belief.
1 My Commiss on expires:
///7 7/
(Notary Public)
//
. CDOT'ON EOCON COMPANY Mr. Boyce H. Grier, Director March 12,1980 Page 5 i
cc:
U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement Division of Reactor Operations Inspection Washington, D. C.
20555 i
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