ML17213B323
| ML17213B323 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 04/21/1983 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17213B322 | List: |
| References | |
| IEB-79-01B, IEB-79-1B, NUDOCS 8305020603 | |
| Download: ML17213B323 (10) | |
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t UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION FLORIDA POWER AND LIGHT COMPANY ST.
LUCIE UNIT NO.
1 DOCKET NO. 50-335 Enclosure I ENVIRONMENTAL QUALIFICATION OF SAFETY-RELATED ELECTRIC EQUIPMENT INTRODUCTION General Design Criteria 1 and 4 specify that safety-related electrical equipment in nuclear facilities must be capable of performing its safety-related function under environmental conditions associated with all
- abnormal, abnormal, and accident plant operation.
In order to ensure compliance with the criteria, the NRC staff required all licensees of operating reactors to submit a re-evaluation of the qualification of safety-related electrical equipment which may be exposed to a harsh environment.
BACKGROUND On February 8, 1979, the NRC Office of Inspection and Enforcement (IE) issued to all licensees of operating plants (except those included in the systematic evaluation program (SEP))
IE Bulletin (IEB) 79-01, "Environ-mental qualification of Class IE Equipment."
This Bulletin, together with IE Circular 78-08 (issued on May 31, 1978), required the licensees to perform reviews to assess the adequacy of their environmental qualifica-tion programs.
On January 14,
- 1980, NRC issued IE Bulletin 79-01B which included the DOR guidelines and NUREG-0588 as attachments 4 and 5, respectively.
Subsequently, on May 23,
PDR-
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f(V gg'u'
-2" was issued and stated that the DOR Guidelines and portions of NUREG-0588 form therequirements that licensees must meet regarding environmental qualification of safety-related electrical equipment in order to satisfy those aspects of 10 CFR 50, Appendix A, General Design Criterion (GDC) 4.
Supplements to IEB 79-01B were issued for further clarification and definition of the staff's needs.
These supplements were issued on February 29, September 30, and October 24, 1980.
In addition, the staff issued orders dated August 29, 1980 (amended in'eptember 1980) and October 24, 1980 to all licensees.
The August order required that the licensees provide a report, by November 1, 1980, docu-menting the qualification of safety-related electrical equipment.
The October order required the establishment of a central file location for the maintenance of all equipment qualification records.
The central file was mandated to be established by December 1, 1980.
The staff subsequently issued Safety Evaluation Reports (SERs) on enviromental qualification of safety-related electrical equipment to licensees of all operating plants in mid-1981.
These SERs directed licensees to "either provide documentation of the missing qualification information which demonstrates that safety-related equipment meets the DOR Guide-lines or NUREG-0588 requirements or commit to a corrective action (re-qualification, replacement (etc.))."
Licensees were required to respond to NRC within 90 days of receipt of the SER.
In response to the staff SER issued on Hay 29, 1981, the licensee submitted additional information regarding the qualification of safety-related electrical equipment.
EVALUATION The acceptability of the licensee's equipment environmental qualification program was'esolved for the Division of Engineering by the Franklin Research Center (FRC) as part of the NRR Technical Assistance Program in support of NRC operating reactor licensing actions.
The consultant s
review is documented in the report "Review of Licensees'esolutions of Outstanding Issues from NRC Equipment Environmental gualification Safety Evaluation Reports," which is attached.
Me have reviewed the evaluation performed by our consultant contained in the attached Technical Evaluation Report (TER) and concur with its bases and findings.
CONCLUSIONS Based on the staff's review of the attached Technical Evaluation Report, the following conclusions are made regarding the qualification of 3
safety-related electrical equipment.
The major qualification deficiencies that have been identified in the attached FRC TER (Tables 4-1, 4-2, 4-3 and 4-4) must be resolved by the licensee.
Items requiring special attention by the licensee are summarized below:
o Submission of information for items in NRC cateqories I.B and IV for which justification for continued operation was not previously submitted to NRC or FRC,
4-o Resolution of the deficiencies as'sociated with Equipment Items Nos.
104 thru 108 and 113 thru.116 that have been assigned to NRC Category II.B (Equipment Not gualified),
o Resolution of the staff concern regarding the radiation dose inside containment (Section 4.3.3.3 of the FRC TER).
The staff is continuing to review the licensee's environmental qualification program.
If any additional qualification deficiencies were identified during the course of this review, the licensee would be required to reverify the justification for continued 'operation.
The staff will. review this infor-mation to ensure that continued operation until completion of the licensee's environmental qualification program will not present undue risk to the public health and safety.
The licensee must provide the plans for quali-fication or replacement of the unqualified equipment and the schedule for accomplishing its proposed correction action in accordance with 10 CFR
- 50. 49.
PROPRIETARY REVIEW Enclosed in the FRC Technical Evaluation Report (TER) are certain identi-During the preparation of the attached
- TER, FRC used test reports and other documents supplied by the licensee that included material claimed to be proprietary.
NRC is now preparing to publicly release the FRC TER and it is incumbent on the agency to seek review of all claimed proprietary material.
As such, the licensee is requested to review the attached TER and notify NRR whether any portions of the identified
pages still require proprietary protection.
If so, the licensee must clearly identify this information and the specific rationale and justi-fication for the protect:on from public disclosure, detailed in a written response.
The level of specificity necessary for such continued protection should be consistent with the criteria enumerated in 10 CFR 2.790(b) of the Commission's regulations.
Attachment:
FRC TER Principal Contributor:
P. Shemanski, OE
NRC has placed the following additional items in NRC gualification Category-II.B (not qualified):
St.
Lucie 1 item number 104, Level Transmitter Fisher and Porter Model 1302495KB St.
Lucie 1 item number 105, Level.Transmitter Fisher and Porter Model 1302495 St.
Lucie 1 item number 106, Level Transmitter Fisher and Porter Model 1302495KBNS St.
Lucie 1 item number 107, Pressure Transmitter Fisher and Porter Model 50EP1041 St.
Lucie 1 item number
- 108, Pressure Transmitter Fisher and Porter Model 50EP1041BCNS St.
Lucie 1 item number 113, Pressure Transmitter Fisher and Porter Model 50EP1041 ACNS St.
Lucie 1 item number 114, Pressure Transmitter Fisher and Porter Model 50EN1071BCXANS St.
Lucie 1 item number 115, Pressure Transmitter Fisher and Porter, Model 50EP1041BCXANS St.
Lucie 1 item number 116, Pressure Transmitter Fisher and Porter Model 50 EP1041BCNS (No JCOs were provided for these items)
ENCLO:.tJRE 3
PPOPRIETARY R. Ãi-"W GUIDELINES It is the policy of the Nuclear P;=gulatory Commission hat the records of.
the agency are available for ins~"tion and copyin" i.. the NRC Public Document Room, except for matters that are exempt pro-. public. disclosure pursuant to the nine exemptions of the Freedom of Inf"rmation Act.
(See 10 C. F. R. 2. 790)
- Recently, the NRC has liad its con.ractor, Franklin Research Qnter (FRC),
prepare Technical Evaluation Reports. for all 10 CFR Part 50 licensee's.
These reports evaluate and comment upon the references cited by the licensee as evidence of qualificaiion in accordance with the doc'umentation.
.. reference instructions.established by IE Bulletin 79-01B.
In a typical evaluation, FRC generates a report of ap.=roximately 750 pages.
Any page which mentions or commen:s upon a licensee's referenced material that was marked or claimed to be proprietary is marked at the top of the page with the legend "Proprietary Information".
F.-.C:.
s used this marking in a liberal manner and has not f;lly investigated the,licensee's claim to determine whether portionz of proprjetary reports tha they'eproduced or mentioned were in fact proprietary".
A repor't typic=lly contains 15 to 25 pages that are marked "Propriewry information":
L'sually, no more than 4 licensee proprietary references are so discussed In order to make any of the reports available to the public, FRC has pr duced two versions of each:
those containing proprietary information and th"se having the pro-prietary information removed.
Tl:= NRC now seeks t.'-e =-ssis.ance of Ticensdes in reviewina the proprietary v rs ons of the FRC r=pc-ts to determine whether still more information ca"i be made avail ab e a the public.
For this reason, each licensee has been sent the S-af-.
Equipment gualification SER and a copy of the proprietary version of the F.=,C TEchnical Evaluation Peport.
It is believed that the licensee can review:he ew pages containing pr'oprietary information in a rel a-.ively short period "
Mme.
The licensee is to send the third party owner of the reference rep=rt, which has been claimed to be proprietary, a copy of Dose pages fro".. th FRC report that relates to its test report.
The third party owner ca.; quickly review these pages and deter>nine wnetner the information-cia'..ed to be proprietary must still be so categorized.
All reviewers shoul be aware of the HRC s policy, as specified in SECY-81-ll9, that surmary "a.a on Equipment gualiiication testing will not b
treated as proprie =ry by the NRC. If the review identifies no data ha requires protectic.".,
the NRC should be notified and.that portion of the report;ail.l, be place"'n the Public Document Room.
If, however, the licensee identifi s
=o the NRC portions that, are still claimed to require proprietary pro ec.ion, then compliance must be
->ade with the
. e uire-,.:en:s for withholding u".='er'10 C.F.R. 2.790.
This can be accomplished in two ways:
(1) If the
.e-.=-rence proprietary report has previously been submitted to the NRC p rs
-=nt to 10 C.F,R, 2.790 and the HRC has made a determina=ion that portions ar=- proprietary, then
0 0
- hose same por.ions can be. protected again simply by notifying the NRC that this mat<<r ial i covered in the NRC's acceptance letter of a given date.
If the reference proprietary report has not-previously bees submitted to the NRC pursUant to 10 C.F.R. 2.790, then the licensee and the proprietary owner must at this time make such an application and request for withholding from publ i c disclosure.
The NRC recognizes that this proprietary review places an administrative burden upon its licensees and any third party owners.
However, it is the.
policy of the NRC to. make.al.l non.-proprietary information public, and the only way to protect the owner of proprietary information is to insure that the Franklin reports have been appropriately scrutinized.
The NRC will grant extensions of time for these reviews if necessary, on
- a case-by-case bas'is; Rf-you have any further questions regarding this review, please 'contact either Edward Shomaker, OELD, at 492-8653 or N al Abrams, Patent Counsel, at 492-8662.
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