ML13330B267

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Informs of Action Planned to Correct Deficiencies in Environ Qualification Program.Work Being Performed Will Result in Equipment Being Qualified for Postulated Harsh Environ Before Restart from Current Maint Outage
ML13330B267
Person / Time
Site: San Onofre 
Issue date: 03/11/1988
From: Medford M
SOUTHERN CALIFORNIA EDISON CO.
To:
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
TAC-67758, NUDOCS 8803230242
Download: ML13330B267 (2)


Text

Southern California Edison Company P. 0. BOX 800 2244 WALNUT GROVE AVENUE ROSEMEAD, CALIFORNIA 91770 M. 0. MEDFORD TELEPHONE MANAGER OF NUCLEAR ENGINEERING (818) 302-1749 AND LICENSING March 11, 1988 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Gentlemen:

Subject:

Action Planned to Correct Deficiencies in Environmental Qualification Docket No. 50-206 San Onofre Nuclear Generating Station Unit 1 The purpose of this letter is to describe deficiencies which have been identified in the Unit 1 Environmental Qualification (EQ) Program. These deficiencies involve installed electrical components which have not been environmentally qualified as required and which were identified as a result of a comprehensive review of the set of electrical equipment which falls within the definition set forth in paragraph (b) (1) of 10 CFR 50.49. Work presently being performed will result in this equipment being qualified for the postulated harsh environment before restart from the current maintenance outage or appropriate justification will be established for startup with any deviations. Also, a Licensee Event Report (LER) describing these deficiencies in detail will be submitted by March 28, 1988.

The original scope of the EQ program at San Onofre Unit 1 was defin ed in SCE's letter dated October 31, 1980 and supplemented by letter dated November 4, 1981. The list of safety related equipment identified constituted the EQ Master List at that time. This list of safety related equipment underwent a prolonged review by the NRC and its consultants, the Franklin Research Center. This review did not include equipment added as a result of TMI.

As a result of SCE's continuing EQ efforts, the original scope of equipment reviewed by the NRC and the TMI equipment were combined to form the base EQ Master List which was reviewed by the NRC prior to plant startup in 1984.

SCE's current design control processes for ensuring EQ of new equipment were not in place until 1984. As a result equipment added prior to that time, including TMI equipment, was not adequately reviewed for environmental qualification requirements. In other cases, equipment should have been added to the EQ Master List and qualified because of a redefinition of safety function based upon completion of additional reviews such as those undertaken pursuant to the NRC's Systematic Evaluation Program. For example, several solenoid valves associated with minimum flow recirculation at the main feedwater pumps fall in this category. A detailed discussion of the root causes will be provided in the LER.

880.3230242 880311 PDR ADOCK 05C)002)6.

P U1DD'I

Document Control Desk March 11, 1988 This programmatic deficiency was corrected with the implementation of our current design control processes in 1984. At the present time, all design changes at all units at San Onofre are reviewed for environmental qualification requirements. This review occurs at the onset of design.

SCE is confident that a similar problem does not exist at Units 2 & 3 based upon the commitment to the IEEE-323 standard described in the Preliminary Safety Analysis Report. Environmental qualification was addressed from the beginning of the San Onofre Units 2 & 3 Project.

In addition, to the work described above relative to 10 CFR 50.49 (b) (1), SCE has also initiated a review of the scope of equipment which falls under the definition of 10 CFR 50.49 (b) (2).

At present SCE continues to rely on the methodology previously described in the submittal dated November 19, 1984 and approved by the NRC in its letter dated March 11, 1985,

Subject:

"Environmental Qualification of Electric Equipment Important to Safety".

However, SCE's current review will be a comprehensive reexamination to assure that all equipment within the scope of paragraph (b) (2) of 10 CFR 50.49 is included on the EQ Master List. This effort is scheduled to be complete by August 31, 1988. Any discrepancies identified as a result of this review will be dispositioned in accordance with the NRC's regulations.

If you have any questions on this matter please let me know.

Very truly yours, cc: 3. B. Martin, Regional Administrator, NRC Region V F. R. Huey, NRC Senior Resident Inspector, San Onofre Units 1, 2 and 3