ML13330B285

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Submits Info Re Environ Qualification of Electrical Equipment.Concludes That Risk Associated W/Any 10CFR50.49(b)(2) Equipment That Might Exists Considered Low & Discrepancies Identified Will Be Promptly Dispositioned
ML13330B285
Person / Time
Site: San Onofre Southern California Edison icon.png
Issue date: 03/30/1988
From: Medford M
SOUTHERN CALIFORNIA EDISON CO.
To:
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
TAC-67758, NUDOCS 8804010217
Download: ML13330B285 (2)


Text

40 Southem 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 30, 1988 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Gentlemen:

Subject:

Docket No. 50-206 Environmental Qualification of Electrical Equipment San Onofre Nuclear Generating Station Unit 1 By letter dated March 30, 1988 SCE transmitted to the NRC Licensee Event Report (LER) No.88-001.

This report identified and discussed in detail the events surrounding and the corrective actions undertaken to resolve the discrepancies identified in the Environmental Qualification Program at San Onofre Unit 1. This included equipment covered by 10 CFR 50.49 (b)(1), safety related equipment, and (b)(2) nonsafety related equipment whose failure could affect the performance of a safety function. The purpose of this letter is to explain SCE's basis for returning the plant to service.

Regarding the 10 CFR 50.49 (b)(1) equipment review, 55 components were identified which were not included on the Environmental Qualification Master List (EQML).

Some of these components involved (b)(2) interactions. As indicated in the corrective actions of the LER this equipment will be included on the EQML as appropriate and qualified if required prior to return to service from the current outage.

Regarding the 10 CFR 50.49 (b)(2) equipment, SCE's original compliance was described in a letter dated November 19, 1984 to the NRC, and was based on work done for the Systematic Evaluation Program, Fire Protection, NRC Bulletins and Orders and the ECCS Single Failure Analysis. This was approved by the NRC in their March 11, 1985 safety evaluation on environmental qualification for San Onofre Unit 1. SCE has initiated a program to review in detail all electrical components requiring environmental qualification for possible unidentified (b)(2) equipment. This current review of electrical equipment using the criteria of 10 CFR 50.49 (b)(2) will be conducted using rigorous methodology, and is expected to be completed by August 31, 1988.

The review of (b)(2) equipment is being done on the following priority basis:

(1) Most severe environment first (inside containment)

(2) Most important systems first (ECCS, AFWS, CIS)

(3) Most important equipment first (motors, valves) o 83040e 217 88033(

PDR ADOCK 05000206 P

DCD

Document Control Desk March 30, 1988 Review of all equipment of the most important systems located inside containment is scheduled to be done by the end of April.

Review of all equipment of all systems located inside containment is scheduled to be done by the end of May. On this basis the risk represented by the uncertainty over potential unidentified electrical interactions rapidly diminishes as the program progresses from higher to lower priority areas. It is concluded that this risk is already small as discussed below.

By its very nature, (b)(2) equipment involves a secondary effect, e.g.,

electrical interaction with a qualified piece of equipment. Such an interaction can occur when an unqualified component experiences deterioration in a harsh environment. This deterioration will not be immediate but will take time and the resulting equipment failure is unpredictable. The deterioration is only harmful if specific types of failures develop. In addition, emergency repairs can often be undertaken to restore affected equipment. Thus the risk of any harmful interaction associated with (b)(2) equipment is small.

If any discrepancies are identified as a result of the (b)(2) review, SCE is required to deal with the consequences of these discrepancies at the time of their discovery. This will entail one of the following measures:

(1) Determining that continued operation is justified based on failure effects, interim qualification data, or safety analysis, or (2) Undertaking temporary modifications or prompt repair to eliminate the potential interactions, or (3) Shutting down the plant if required by operability considerations until modifications are made.

In summary, while SCE cannot predict the outcome of the review using the criteria of (b)(2), it is concluded that the risk associated with any (b)(2) equipment that might exist is low and any discrepancies which are identified will be promptly dispositioned as discussed above.

If you have any questions regarding 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