Letter Sequence Other |
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Results
Other: 05000206/LER-1988-001-02, :on 880225,several Components Requiring Environ Qualification Found Omitted from Equipment Qualification Master List.Caused by Inadequate Methodology During List Generation.Installed Equipment Reviewed, ML13316A023, ML13316B916, ML13316B920, ML13324A480, ML13324A499, ML13324A563, ML13324A571, ML13330B267, ML13330B285, ML13330B289, ML13330B298, ML13330B309, ML13330B315, ML13330B343, ML13330B348
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MONTHYEARML13324A4801984-11-0303 November 1984 Forwards Justification for Continued Operation of Equipment Requiring Environ Qualification,As Part of Efforts to Return Unit 1 to Svc Project stage: Other ML13324A4981984-11-19019 November 1984 Documents Results of 831220 Meeting W/Nrc in Bethesda,Md Re Environ Qualification of safety-related Electrical Equipment.Addl Info Re Environ Qualification Program Encl, Per 840509 Request Project stage: Meeting ML13324A4991984-11-19019 November 1984 Informs of Completion of Environ Qualification of Listed Electrical Equipment,Including Reactor Coolant Temp Detectors & Containment Hydrogen Monitors.Qualification Packages for Equipment Will Be Completed by 850331 Project stage: Other ML13324A5631985-02-26026 February 1985 Submits Certification of Compliance Re Environ Qualification of Electrical Equipment Per 10CFR50.49.Environ Qualification of All Equipment Will Be Completed by 850331 Project stage: Other ML13324A5711985-03-11011 March 1985 SER Supporting Environ Qualification of Electric Equipment Important to Safety,Per Requirements of 10CFR50.49 Project stage: Other ML13324A5681985-03-11011 March 1985 Forwards SER Re Environ Qualification of Electric Equipment Important to Safety.Equipment Qualification Program in Compliance w/10CFR50.49.Final Environ Qualification of Electric Equipment Will Be Completed by 850331 Project stage: Approval ML13333A6271987-12-11011 December 1987 Forwards Safety Evaluation Re Util 871016 Submittal of ESFs Single Failure Analyses & 871201,08 & 09 Submittals of Analyses Justifying Operation of Plant for Remainder of Current Operating Cycle.Justification Acceptable Project stage: Approval ML13333A6321987-12-11011 December 1987 Safety Evaluation Supporting Util Justification for Interim Plant Operation Re ESF Single Failure Vulnerability Project stage: Approval ML13316B8971988-02-26026 February 1988 Summary of 880225 Mid Level Mgt Meeting W/Util Re Status of Licensee Root Cause Evaluation of Environ Qualification Problem W/Unit 1,control of Boron Concentration & Focus of NRC Programs Toward Insp of Utils in Future Project stage: Meeting ML13330B2671988-03-11011 March 1988 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 Project stage: Other ML13330B2801988-03-22022 March 1988 Notification of 880324 Meeting W/Licensee in Region V Ofc to Discuss Environ Qualification Concerns & Corrective Actions to Be Taken by Licensee Before Startup Project stage: Meeting ML13330B2751988-03-22022 March 1988 Confirms 880316 & 18 Telcons Between Ph Johnson & Ma Wharton Re 880324 Mgt Meeting in Region V Ofc to Discuss Facility Environ Qualification Deficiencies & Planned Corrective Actions Before Resuming Operation.Meeting Notice Encl Project stage: Meeting ML13330B2851988-03-30030 March 1988 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 Project stage: Other 05000206/LER-1988-001-02, :on 880225,several Components Requiring Environ Qualification Found Omitted from Equipment Qualification Master List.Caused by Inadequate Methodology During List Generation.Installed Equipment Reviewed1988-03-30030 March 1988
- on 880225,several Components Requiring Environ Qualification Found Omitted from Equipment Qualification Master List.Caused by Inadequate Methodology During List Generation.Installed Equipment Reviewed
Project stage: Other ML13330B2891988-04-0101 April 1988 Describes Util Compliance w/10CFR50.49.Util Believed All safety-related Equipment Was Included on Environ Qualification Master List (Eqml) & Fully Qualified After Returning to Svc from Cycle 9 Refueling Outage.Eqml Encl Project stage: Other ML13330B2981988-04-26026 April 1988 Discusses Plant Comprehensive Program Addressing 10CFR50.49(b)(2) Equipment Environ Qualification.Util Decided to Perform Program on Accelerated Schedule Prior to Unit Restart Project stage: Other ML13330B3091988-05-11011 May 1988 Confirms 880509 Telcon Re Environ Qualification (Eq). Licensee Made Commitment to Provide Ltr Describing Recent EQ Review Effort,Including Description of Program,Review Methods,Findings & Corrective Actions,By 880520 Project stage: Other ML13330B3151988-05-27027 May 1988 Forwards Info to Resolve Discrepancies Identified During Review of Environ Qualification Master List,Including Results of Review of 10CFR50.49b(1) & (2) Equipment.Cables, Including Cables Traversed in Harsh Environs Also Reviewed Project stage: Other ML13316B9161988-06-10010 June 1988 Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $150,000.Noncompliance Noted:Listed Electric Components,Required to Be Qualified Per 10CFR50.49(b) Not Included in Master List of Qualified Equipment Project stage: Other ML13330B3431988-06-16016 June 1988 Responds to 880527 near-final Results of Environ Qualification of Electrical Equipment Review.Subj to Successful Completion of Cable walk-downs & Actions Described in Ltr,Returning to Svc Acceptable Project stage: Other ML13330B3481988-07-0909 July 1988 Forwards Update of Progress Made Re Environ Qualification Program at Facility.List of 10CFR50.49 b(1) Equipment & Corrective Actions Encl Project stage: Other ML13316B9201988-07-11011 July 1988 Responds to NRC Re Violations Noted in Insp Rept 50-206/88-10 & Proposed Imposition of Civil Penalty. Corrective Actions:Task Force Established to Ensure Responsibility for Engineering & Technical Work.Fee Paid Project stage: Other ML13330B3661988-07-29029 July 1988 Advises That NRC Reviewed Util Two Justifications for Operation & Agrees W/Determination of Operability,Per Generic Ltr 88-07,per Updating Results of re-review of Environ Qualification of Electrical Equipment Project stage: Approval ML13316A0231988-08-0101 August 1988 Ack Receipt of & Payment of Civil Penalty in Amount of $150,000 Project stage: Other 1988-04-01
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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