ML13308A898
| ML13308A898 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry, Kewaunee, Haddam Neck, San Onofre, 05000000, Crane |
| Issue date: | 12/23/1985 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML13308A897 | List: |
| References | |
| TAC-56906 DD-85-20, DD-85-24, NUDOCS 8601080203 | |
| Download: ML13308A898 (17) | |
Text
DD-85-20 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Harold R. Denton, Director In the Matter of
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Docket Nos. 50-289 GPU NUCLEAR CORPORATION
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50-206 (Three Mile Island Nuclear
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50-305 Station, Unit 1)
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50-213 SOUTHERN CALIFORNIA EDISON COMPANY (San Onofre Nuclear Generating (10 CFR 2.206)
Station, Unit 1)
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WISCONSIN PUBLIC SERVICE CORPORATION
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(Kewaunee Nuclear Power Plant)
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CONNECTICUT YANKEE ATOMIC POWER
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COMPANY
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(Haddam Neck Plant)
DIRECTOR'S DECISION UNDER 10 CFR 2.206 INTRODUCTION On November 19, 1984, the Nuclear Regulatory Commission (NRC) promulgated its final rule on environmental qualification of electric equipment (49 Fed.
Reg. 45571). The rule requires licensees of operating power plants to meet the schedule for environmental qualification set out in the rule, specifically, 10 CFR 50.49(g). In adopting the final rule, the Commission directed the Director of the Office of Nuclear Reactor Regulation to consider pursuant to 10 CFR 2.206 four comments filed in response to the Notice of Proposed Rulemaking issued on March 7, 1984 (49 Fed. Reg. 8445). Each of the four comments alleged equipment qualification deficiencies at specific plants. The Commission's action had the effect of requiring the Director of the Office of Nuclear Reactor Regulation to issue a formal decision pursuant to 10 CFR 2.206 considering the plant-specific 8601080203 851223 PDR ADOCK 05000260 P
PDR-
-2 comments filed in the rulemaking proceeding noted above. The comments filed by the Union of Concerned Scientists (hereinafter referred to as Petitioner) dated May 23, 1984 were among those identified by the Commission for consideration.
Those comments alleged equipment qualification deficiencies at four plants:
Three Mile Island Nuclear Station, Unit 1; Kewaunee Nuclear Power Plant; San Onofre Nuclear Station, Unit 1; and the Haddam Neck Plant (hereinafter referred to as the facilities). On January 4, 1985, 1 advised the Petitioner by letter that I would issue a formal decision regarding the Petitioner's comments concerning these facilities in the reasonably near future. My decision in this matter has been formulated after extensive staff review and is as follows.
DISCUSSION Petitioner's comments relate to alleged inadequacies in a number of equipment qualification items including certain items identified by the Franklin Research Center (FRC) and set out in its Technical Evaluation Reports (TERs) for the facilities. 1/
It is important to recognize that the FRC studies to which the Petitioner refers were initiated by the Nuclear Regulatory Commission itself 1/ The licensees of the facilities are GPU Nuclear Corporation for Three Mile Island Unit 1, Wisconsin Public Service Corporation for Kewaunee, Southern California Edison Company for San Onofre Unit 1 and Connecticut Yankee Atomic Power Company for Haddam Neck (hereinafter referred to as Licensees).
-3 to assist in assessing the adequacy of the Licensees' electrical equipment qualification programs at the facilities. The TERs provided by FRC have been available to the NRC staff since the fourth quarter of 1982 and have been specifically addressed by both the Licensees and the NRC staff.
On February 8, 1979, the NRC Office of Inspection and Enforcement issued IE Bulletin 79-01, "Environmental Qualification of Class IE Equipment." The Bulletin, together with IE Circular 78-08 (issued on May 31, 1978), requested affected licensees to perform reviews to assess the adequacy of their environmental qualification programs. The NRC staff's review in this area for TMI Unit 1, Kewaunee, and San Onofre Unit 1 was discussed in the final Safety Evaluation for each plant, Attachments 1 through 3. The final program review for Haddam Neck has not been completed.
2/ The background associated with the NRC staff's review of three of the Licensees' equipment qualification programs is provided in Attachments 1 through 3; Safety Evaluation, Office of Nuclear Reactor Regulation, Equipment Qualification Branch, Three Mile Island Nuclear Station, Unit 1, Docket No. 50-289 (hereinafter referred to as the Three Mile Island SE);
Safety Evaluation, Office of Nuclear Reactor Regulation, Equipment Qualification Branch, Kewaunee Nuclear Power Plant, Docket No. 50-305 (hereinafter referred to as the Kewaunee SE); Safety Evaluation, Office of Nuclear Reactor Regulation, Equipment Qualification Branch, San Onofre Nuclear Generating Station, Unit 1, Docket No. 50-206 (hereinafter referred to as the San Onofre SE). A final SE for Haddam Neck is not yet available.
-4 Following submittal by the Licensees of additional information from September 1981 to June 1982, the NRC staff asked FRC to evaluate that information in order to (1) identify all cases where the Licensees' response did not resolve the significant qualification issues, (2) evaluate the Licensees' qualification documentation in accordance with established criteria to determine which equipment had adequate documentation and which did not, and (3) evaluate the Licensees' qualification documentation for safety-related electrical equipment located in harsh environments consistent with TMI "Lessons Learned" implementation.
TERs dated June 7, 1982 for Haddam Neck, June 28, 1982 for San Onofre Unit 1, November 5, 1982 for TMI-1, and January 14, 1983 for Kewaunee, were prepared by FRC to document its evaluation. It is these documents to which the Petitioner makes reference. A Safety Evaluation (SE) was subsequently prepared by the NRC staff and issued to each of of the Licensees between November 1982 and January 1983 with the FRC TER as an attachment. 3/
These TERs identified a number of electrical equipment environmental qualification deficiencies and the SE concurred with the bases and findings of the TER. Based on these findings, the staff requested the Licensees to provide their plans for qualification or replacement of certain items and justifications for continued operation in the near term.
The staff reviewed the FRC TERs and the Licensees' justifications for continued operation and concluded that continued operation until completion of the Licensees' environmental qualification program would not present undue risk to the public health and safety. Furthermore, the staff continued to review the 3/ Three Mile Island Jnt I SE ed Decembibr 10, 1982; Kewaunee SE dated February 21, 1983; San Onofre Unit 1 SE dated November 30, 1982; Haddam Neck SE dated December 6, 1982.
-5 Licensees' environmental qualification program. If any additional qualification deficiencies were identified during the course of that review, the Licensees would be required to reverify the justification for continued operation.
Meetings were held with the Licensees from December 1983 to April 1984 in order to discuss the Licensees' proposed method of resolving the environmental qualification deficiencies identified in the SEs and FRC TERs. During these meetings with the Licensees, proposed resolutions for each of the deficiencies were discussed and the NRC staff found the Licensees' approach for resolving them acceptable. The approaches described by the Licensees for addressing and resolving the identified deficiencies included replacing equipment, performing additional analyses, utilizing additional qualification documentation beyond that reviewed by FRC, obtaining additional qualification documentation, or determining that some equipment was outside the scope of 10 CFR 50.49 and therefore not required to be environmentally qualified. The discussions also included the Licensees' general methodology for compliance with 10 CFR 50.49 and justification for continued operation with those equipment items for which environmental qualification was not yet complete.
Subsequent to the 1983 and 1984 meetings, the Licensees provided further information for resolution of the identified deficiencies. With the exception of Haddam Neck, the NRC staff completed its evaluation of the acceptability of the Licensees' electrical equipment environmental qualification program, including the type of documentation the Licensees indicated they had retained.
The staff's findings for TMI Unit 1, Kewaunee, and San Onofre Unit 1 are provided in Attachments 1 through 3, respectively.
-6 The final Safety Evaluation for Haddam Neck is presently in preparation and will be issued in the near future. An interim SE for Haddam Neck was issued on December 6, 1982. Subsequently, a schedular extension for equipment qualifica tion was issued on March 28, 1985. By letter dated September 30, 1985, the Licensee requested an extension until January 4, 1986 to complete the remaining plant modifications. By letter dated November 14, 1985, the Commission granted the requested extension. The final SE has been delayed because of an issue concerning approximately 20 equipment items with about 120 discrete components located outside containment that have not been included in the environmental qualification program for Haddam Neck. The staff is evaluating the Licensee's position on this issue, and will verify that the Licensee's program is adequate to ensure the continued protection of the health and safety of the public.
The final SE will include the resolution of this issue along with the conclusion of the staff with regard to the Licensee's equipment qualification program.
The staff has initiated a two-year implementation inspection program to monitor the status of equipment qualification programs at operating reactors.
The inspections are designed to verify that licensees' files contain appropriate analyses and other necessary documentation to support the licensee's conclusions that their equipment is properly qualified. Additionally, the inspections will verify that the programs for surveillance and maintenance of environmentally qualified equipment conform to the licensees' prior assertions and are adequate to assure that the equipment is maintained in the as-analyzed or as-tested condition. The methods used for tracking periodic replacement of equipment
-7 will also be verified. As with any program of such complex and extensive proportions, discrepancies are expected to be identified. NRC regional personnel who are conducting the inspections will followup to ensure that appropriate corrective action is taken where deficiencies are identified.
TMI Unit 1 and San Onofre Unit 1 are among those plants that have under gone inspections. The staff.is satisfied that discrepancies identified during these inspections have been adequately addressed by the Licensees, and the overall implementation of the equipment qualification program has been found acceptable for these facilities. The inspection program will continue until the implementation of environmental qualification programs at all operating reactors has been found acceptable.
Petitioner's comments raised several specific concerns with respect to the state of equipment qualification at the facilities. These specific comments are addressed below:
A. THREE MILE ISLAND UNIT 1
- 1. Limitorque Valve Operators With regard to the Limitorque valve operators, the staff's initial evaluation of the qualification status of this and all other equipment was based primarily on summary type information supplied by the Licensee in response to IE Bulletin 79-01. More detailed qualification information was subsequently reviewed for the staff by FRC. FRC prepared a TER that identified equipment qualification deficiencies for this equipment, based on the information submitted to them for review. The staff met with the Licensee on October 5, 1983 and again on March 8, 1984 to discuss the Licensee's pronosed resolutions of the TER identified deficiencies.
-8 Subsequent to the meetings cited above, the staff performed several audits of the Licensee's TMI Unit 1 equipment qualification files, including audits on August 6, 1984 and January 29 and 30, 1985.
The sample of equipment audited included Limitorque valve operators.
Based on the audit results, the staff concluded that the Licensee had the documentation necessary to demonstrate that TMI Unit 1 Limitorque valve operators, modified to correct qualification deficiencies discovered for some of the operators during field walkdowns (hardware visual inspections), are environmentally qualified. Further, the staff then reviewed some of the operators to assure that the Licensee had corrected the deficiencies discovered during the field walkdowns.
Based on the review of TMI Unit 1 Limitorque Valve operators described above, the staff is satisfied that there is adequate assurance regarding environmental qualification, and thus there is no need to address each individual point raised by the Petitioner regarding these items of equipment.
In summary, the staff did not rely solely on the Licensee's assertions in meetings, nor on the information submitted by the Licensee in its February 10, 1984 letter, where the reference to Limitorque generic report B-0058 was contained. Rather, the staff independently verified that the Licensee has documented evidence that Limitorque valve operators are environmentally qualified.
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- 2. Emergency Feedwater System The Petitioner raises several questions about the qualification of the emergency feedwater system (EFW) at TMI Unit 1. The Petitioner's questions concerning EFW are fully addressed in a September 25, 1984 Director's Decision under 10 CFR 2.206 responding to an earlier petition filed by the Union of Concerned Scientists alleging deficiencies in the TMI Unit 1 EFW System. 4 The SE accompanying the September 25, 1984 Director's Decision provides the history of the review and detailed audits conducted concerning the TMI Unit 1 EFW. In particular, page 37 of the SE states:
"Based on the results of our audits, the staff finds that all electrical equipment requiring qualification, both EFW system equipment and equipment associated with the proper functioning of the EFW system, has been demonstrated to be environmentally qualified in accordance with the requirements of 10 CFR 50.49."
- 3. Justification for Continued Operation (JCO)
The Petitioner challenges the justification for continued operation, or lack thereof, for potential deficiencies regarding TMI Unit 1 equipment qualification. This issue is now moot. In the case of TMI Unit 1, the plant remained in a shutdown condition for the entire time of the staff's environmental qualification 4/ GPU Nuclear Corporation (Three Mile Island Nuclear Station, Unit 1, DD-84-22, 20 NRC 1033 (1984).
10 equipment review. The Licensee has now completed its program implementation thereby obviating the need for JCOs. The Licensee has documented qualification or replacement of equipment where environmental qualification was in question by letters dated June 28, 1985 and August 30, 1985.
B. SAN ONOFRE UNIT 1 The Petitioner raised two concerns regarding the justifications for continued operation (JCOs) at the San Onofre Unit 1 facility and an additional concern regarding the Licensee's schedule to correct qualification deficiencies.
- 1. The Petitioner alleged that the Licensee by letter dated January 18, 1984 refused to submit JCOs to the NRC for 52 component types consisting of 100 separate pieces of equipment.
The staff's review of the docket found no such letter dated January 18, 1984. However, the staff did find a letter dated January 18, 1983 in which the Licensee did not refuse to submit JCOs but stated that, except for two items, all previously provided JCOs were still applicable. For the two remaining items, the Licensee provided JCOs in the January 18, 1983 submittal. After several meetings and further discussions with the NRC staff, the Licensee provided new JCOs for all non-qualified equipment items in a submittal dated November 3, 1984. The staff notes that San Onofre Unit 1 was shut down
for a seismic upgrading on February 27, 1982 and did not resume power operation until November 27, 1984. Thus, the facility did not operate until the new JCOs had been provided to the NRC.
These JCOs were reviewed by the staff and found acceptable for the reasons stated in the staff's March 11, 1985 SE (Attachment 2).
- 2. The Petitioner also alleged that the Licensee's JCOs were inadequate for the following items which were found to have qualification deficiencies in the FRC TER:
TER ITEM NO.
EQUIPMENT DESCRIPTION 53, 54, 55, 56, 59 electrical cable 1, 3, 4, 6, 7, 8 15 llmitorque valve actuators 10, 11, 13, 14, 15, 16, 17 19 solenoid valves 18, 20, 21, 22, 23 12 flow transmitters 28, 29 6 level transmitters 31, 32, 33, 34
-13 pressure transmitters 43, 44, 45 unspecified no. of electrical penetrations 47 2 long term recirculation pumps 49 2 safety injection pumps, and 50 1 motor driven auxiliary feedwater pump
12 Subsequent to the Petitioner's comments, the staff confirmed that its March 11, 1985 SE (Attachment 2), did evaluate new JCOs provided by the Licensee's November 3, 1984 submittal for all of the above items cited by the Petitioner. These JCOs were found acceptable by the staff for the reasons stated in the March 11, 1985 SE.
- 3. The Petitioner also alleged that the Licensee "has no immediate plans to correct the qualification deficiencies found by FRC and NRC." This statement was based on the Licensee's February 27, 1984 letter which requested that modifications required for environmental qualification of electrical equipment be removed from the Integrated Living Schedule of Backfits for San Onofre Unit 1 until a request for schedular exemption had been submitted to and approved by the NRC.
The NRC staff notes that, in accordance with 10 CFR 50.49(g),
the Licensee did submit requests for extension of equipment qualification deadlines on July 30, 1984, December 21, 1984, and March 15, 1985 for a total of 79 different pieces of equipment.
The NRC staff reviewed these requests and determined that there was good cause for the extensions based upon procurement lead time, test complications, and installation problems. Thus, the extension requests were found to be consistent with existing regulations in 10 CFR 50.49(g) and were approved by the NRC in letters dated November 26,,1984, February 15, 1985, and March 27, 1985. The extensions require the Licensee to have the electrical equipment qualified by November 30, 1985.
13 C. KEWAUNEE NUCLEAR POWER PLANT
- 1. Qualification Documentation The Petitioner comments that the Licensee's submittal of March 16, 1984 demonstrates poor qualification documentation.
This submittal was forwarded by the Licensee to document proposed methods of resolution for environmental qualification deficiencies discussed at a meeting with the Licensee held on January 20, 1984.
During this meeting, the staff discussed deficiencies in the Licensee's program. Among the deficiencies identified was documentation.
All open items identified in the SE dated February 2, 1983 were also discussed and the resolution of these items has been found acceptable. The Licensee utilized additional qualification documentation beyond that reviewed by FRC. The content of the additional documentation was discussed at the meeting. The staff concluded in its September 11, 1984 SE, that the Licensee's equipment qualification program is now considered acceptable.
- 2. Justification for Continued Operation The Petitioner alleges that the Licensee refused to submit JCOs for 25 Limitorque valve operators. The Petitioner cited the Licensee's April 22, 1983 letter as the document containing the alleged "refusal."
However, that letter stated, "Limitorque operators identified in our submittals are qualified equipment (NRC Category 1.A) and no justification for continued operation
14 is required." The Licensee stated it had documentation in its equipment qualification files to support this statement.
Therefore, the staff found that JCOs were not needed and hence there was no "refusal."
D. HADDAM NECK Justifications for Continued Operation
- 1. The Petitioner comments that the JCO for the resistance temperature elements does not satisfy the Commission's criteria and attempts to excuse the lack of documented environmental qualification for the temperature elements.
The staff met with the Licensee on April 10, 1984 to discuss the resolution of the TER deficiencies. During that meeting, the Licensee informed the staff that the temperature elements, cited by the Petitioner as having a deficient JCO, will be replaced with qualified elements by March 31, 1985 in accordance with an extension granted by the NRC staff. By letter dated February 28, 1985 the Licensee requested an extension until November 30, 1985 to complete the replacement of the temperature elements. This extension was granted by the staff on March 28, 1985. The staff has reviewed and accepted the JCO for these elements submitted by the Licensee in letters dated October 19, 1984, November 30, 1984 and October 25, 1985.
15 The basis for the staff's acceptance of the JCO for these elements included the fact that back-up instrumentation, specifi cally, in-core exit thermocouples and the subcooled margin monitor, was available. The Licensee has stated that the in-core exit thermocouples consist of inorganic material and are not exposed to accident conditions more severe than normal operating conditions.
As such, they will be operational during a design basis accident.
All associated electrical equipment (e.g., cabling, cabinets) outside the reactor vessel and potentially exposed to a harsh environment is qualified pursuant to 10 CFR 50.49. The existing subcooled margin monitor is likewise qualified.
- 2. The Petitioner also comments that the Licensee has not provided either a JCO which satisfied the Commission's criteria or demonstrated environmental qualification for the in-core exit thermocouples.
In a submittal dated October 19, 1984, the Licensee stated that presently installed in-core thermocouples were not in the scope of 10 CFR 50.49, and thus no JCO was required. The staff agrees with this interpretation of 10 CFR 50.49. In any event, the in-core thermocouples are scheduled to be up-graded to meet the criteria of Regulatory Guide 1.97, with an expanded range (2000F. - 1600*F) capability as part of the effort to improve emergency response capability. 5/
The schedule for this effort is controlled by the 5/ Regulatory Guide !.97, "Instrumeration for Lhght-Water Cooled Nuclear Plants to Assess Plant and Environs Conditions During and Following an Accident."
16 Licensee's commitments to implement Supplement 1 to NUREG-0737, and is the subject of a Confirmatory Order dated June 12, 1984, 49 Fed. Reg. 26653 (June 26, 1984).
CONCLUSION In summary, the NRC staff has reviewed each of the items relied upon by the Petitioner. The FRC TERs and NRC's letters to the Licensees which were identified by the Petitioner do indicate various environmental qualification deficiencies. Those deficiencies were identified by the FRC and the NRC staff in reviewing the information available at that time. Thus, the Petitioner has not raised any environmental qualification issues of which the staff was unaware.
Since the TERs were issued, the Licensees have provided considerable additional information regarding the identified electrical equipment deficiencies and have proposed a resolution to each of them that has been found acceptable by the staff. The three attached final SEs document the staff's reviews which conclude that these Licensees have electrical equipment qualification programs which comply with the requirements of 10 CFR 50.49, that the proposed resolutions for each of the environmental qualification deficiencies identified in the FRC TERs are acceptable, and that continued operation until implementation of the Licensees' environmental qualifications programs are complete as scheduled will not result in undue risk to the public health and safety. With respect to Connecticut Yankee, the staff is in the process of completing the review of its environmental qualification program, and will ensure that appropriate corrective actions are taken to resolve any remaining discrepancies.
17 The staff will be continuing to monitor the Licensees' progress in developing and implementing their environmental qualification programs.
Consequently, I conclude that the overall state of equipment qualification of the facilities is adequate to assure protection of the public health and safety. Accordingly, I decline to take any additional action in this matter.
As provided by 10 CFR 2.206(c), a copy of this decision will be filed with the Secretary for the Commission's review.
Harold R. Denton, Director Office of Nuclear Reactor Regulation Attachments:
Safety Evaluations Dated at Bethesda, Maryland this 23rd day of December, 1985.