ML18046B355
| ML18046B355 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 03/05/1982 |
| From: | Crutchfield D Office of Nuclear Reactor Regulation |
| To: | Novak T Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML18046B356 | List: |
| References | |
| LSO5-82-03-029, LSO5-82-3-29, NUDOCS 8203150275 | |
| Download: ML18046B355 (8) | |
Text
LSOS-82-03-029 MEMORANDUM FOR:
FROM:
SUBJECT:
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 March 5, 1982
./,
Thomas M. Novak, Assistant Director --
for Operating Reactors, DL Dennis M.. Crutchfield, Chief Operating Reactors Branch #5, DL ENCLOSURE 1 ENVIRONMNETAL QUALIFICATION OF ELECTRIC EQUIPMENT FOR NUCLEAR POWER PLANTS - MB-60 PALISADES PLANT The FRC review of the Palisades 90 day response to our Environmental Qualification SER stated t~at (1) the licensee has not completed its response to the deficiencies stated in the SER and (2) the.licensee had not provided adequate technical basis as a justification for.
continued operation for the equipment which it has committed to replace.
Our review has determined that *FRC did not review the submittal dated December 4, 1981 from the licensee, apparently because it-was never forwarded to them by EQB.
That submittal resolves the deficiency noted
- in item 1 of the FRC conclusion above.
Hith regard to item 2, we met with the licensee on Febru~ry 19, 1982 and the licensee provided
- additional information by supplementary submittal dated* February 24, 1982~
All equipment which is to be_replaced was either replaced during_ the recent refueling outage (117 solenoid valves and one pressure t_ransmitter) or adequate justification was provided for continued operation until replacement is complete.
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- h. tL>>f c!L,41 Dennis M. Crutchfield, C~
Operating Reactors Branch #5 Division of Licen~ing
ENCLOSURE 2 TER-C525 7-452 APPENDIX D -
REVIEW OF LICENSEE'S RESPONSE TO NRC EEQ SER CONCERNING JUSTIFICATION FOR INTERIM OPERATION
- 1.
BACKGROUND The NRC Safety Evaluation Report (SER) concerning equipment environmental qualification (EEQ) states [82]:
"Subsection 4.2 identified deficiencies that must be resolved to establish the qualification of the equipment; the staff requires that the information lacking in this category be provided within 90 days of receipt of this SER.
Within this period, the licensee should either pro-vide documentation of the missing qualification information which demon-strates that such equipment meets the DOR guidelines or NUREG-0588 or commit to a corrective action (requalification, replacement, relocation, and so forth) consistent with the requirements to establish qualification by June 30, 1982.
If the latter option is chosen, the licensee must provide justification for operation until such corrective action is complete."
On January 19,.1982, FRC representatives met with NRC Division of Licensing personnel. at NRC offices to discuss the potential for FRC to assist the staff in the technical review of licensees' statements-regarding justifica-tion for interim plant operation submitted in response to outstanding qualifi-catio.n deficiencies in the NRC EEQ SERs.
The results of the meeting were as follows:-
(1) FRC was requested to proceed. immediately with the technical
. review of licensees' *justification for interim operation:. (2) the-format was established, and (3) the criteria for the review were established.
These criteria are pr~sented in Section 2 of this appendix.
On January 21, 1982, the NRC provided the following modifica.tion to Final
. Assignment 13 concerning this subject:
"The FRC review will consist of:
o Review the licensee's justification of interim operation and provide_
FRC independent analysis which shows whether or not licensee provided technically sound rationale* as a basis for justification for continued plant operation.
~nklin Research Center A Division of The. Franklin Institute D-1
TER-C525 7-452 o
On January 27, 1982, FRC shall provide a list of those power reactors that have provided technically sound justification for contin~ed.
operation.
FRC shall also provide a list of those power reactors which have not provided technically sound justification for continued operation.
In addition to the lists, FRC may* provide any additional information which in FRC's judgment is necessary to support the conclusions regarding justification for continued operation."
On January 25, 1982, the NRC was provided with the completed re~_iew of
. ~.*
the licensees' statements presented as a basis for justification for. iht~'~i~*:*.
operation i1~ response to the NRC EEQ SER.*
On February 5, 1982, at the NRG' s request, the NRG was provided with actual examples of licensees' responses to the NRC,EEQ SER that provide adequate rationale as a basis for justification for interim operation.**
- 2.
GENERAL DISCUSSION In general, licensee-submitted justifications for interim operatiori are
_based on systems considerations, equipment operability evaluations, or failure-modes-and-effects analyses.
Systems considerations often involve the availability of backup equipment capable of performing the particular safety function of concern.
The backup equipment is either environmentally qualified, unqualified but not exposed to a harsh environment at the same time as the primary equipment, or located so
.that it is unlikely that both the primary and backup equipment would be simultaneously exposed'to a severe environment.
In general, these systems discussions should consider (1) the possibility of a single-active failure
- C. J. Crane Letter to R. A. Clark, NRG.
Subject:
Transmittal of FRC Review of Licensees' Responses.to NRG EEQ SER Concerning Justification for Interim Operation FRC,* 25-Jan-82
- C. J. Crane Letter to R. A. Clark, NRC.
Subject:
Transmittal of Actual Examples.of Licensees' Responses to NRC EEQ SER Which Provide Adequate Rationale as a Basis for Justification of Interim Operition FRC, 5-Feb-82
~
D-2
~- __ FrankJin Research Center
!. Division of The Franklin Institute
TER-C525 7-452 disabling the backup equipment, (2) any major differences in the characteristics of the primary and backup equipment (unless it is obvious that the equipment is essentially identical), (3) the possibility of electrical
- failure of the primary equipment causing an adverse effect on other safety-related equipment or power supplies, and (4) in the case of display instrumentation, the possibility of an operator being misled by the failed primary equipment.
Where equipment has not been demonstrated to be qualified, some* justifications discuss administrative procedures or revised operating procedures in effect.
Depending upon the specific equipment involved, each of the above considerations* need not be discussed in every ~nstance, but, *. 1n general, a complete systems discussion would consider the above points.
Where equipment qualification evaluations were used, licensees generally (1) received additional information from manufacturers, (2) applied engineer-ing judgment, (3) performed material analysis, and/or (4) used partial test data in support of ~he original qualification documentation.
Where these
.evaluations were performed, the licensees* determined that, although full qualification was not documented, there was suffic!ent evidence to suggest tJ::iat the equipment would perform its intended *safety function, thereby justifying int~rim operation until qualified equipment is installed.
Some licensees provided detailed failure-modes-and-effects analyses of
- electrical circuitry'to demonstrate that, under au* identified failure modes, the safety function of the equipment tould still be accomplished.
Other justifications involved a combination of qualification information and systems information.
For example, if a licensee has qualification*
information (such as a generic test report or other partial qualification documentation) that tends to confirm the ability of the equipment to.remain operable for a specified period of time, justification for interim operation often was based upon a discussion of the required safety function being
- performed prior to the potential failure.
This type of discussion often applies to equipment which performs a short-term trip or isolation function in the early stages of an accident.
- ~nklin R~search C~riter D-3 A Di\\'ision of The Franklin Institute
- TER-C5257-452
- 3.
PLANT-SPECIFIC REVIEW As a result of the review, this plant was evaluated and the results
- .. **documented on. the "Summary of Review of Licensee's 90'-Day Response" form reproduced below:
"EQUIPMENT ENVIRONMENTAL QUALIFICATION (EEQ)
Review of Licensees' Resolution of Outstanding Issues From NRC Equipment Environmental Qualification Safety Evaluation Reports
SUMMARY
OF REVIEW OF LICENSEE 90-DAY RESPONSE Utility:
Consumers Power Company Plant Name:. Palisades Nuclear Plant NRC Docket No. 50-255 NRC TAC No. 42517 NRC Contract No. NRC-03-79-118 FRC Project No. C5257 FRC Assignment No. 13 FRC Task No. 452
References:
A.
D. P. Hoffman Letter to D. M. Crutchfield, NRC.
Subject:
Palisades P-lant, Response to Environmental Qualification of Electrical Equipment Consumers Power Company, 7-0ct-80 B.
D. P. Hoffman Letter to D. M. Crutchfield, NRC.
Subject:
Palisades Plant -
Ri:vision 2 to October 7, 1980 Submittal on Environmental Qualification to Electrical Equipment
.Consumers Power Company, ll-Jun-81 C.
D. P. Hoffman Letter to D. M. Crutchfield, NRC.
Subject:
Palisades Plant, Response to Environmental-Qualification of Safety-.Related Equipment Consumers Power Company, 23-Feb-81 D.
D. P. Hoffman Letter to D. M *. Crutchfield, NRC.
Subject:
Palisades Plant -
Environmental Qualification of Safety-Related Electrical Equipment -
Response to Safety Evaluation Report Consumers Powers Company, 03-Sep~81.
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D-4 i-. Dr.1sion of The Frz.nklin Inst tut~
TER-C5257-452 E.
Office of Nuclear Reactor Regulation Safety Evaluation.Report for Palisades Nuclear Power Station Environmental Qualification of Safety-Related
- Electrical Equipment NRC, 28-May-81 Consumers Power Company submitted to the NRC a report entitled
'Environmental Qualification of Safety-Related Electrical Equipment' on October 7, 1980 [A].
The report was revised on October 20, 1980 and June 11, 1981' [B].
On February 10, 1981, the NRC transmitted by letter a preliminary evaluation of the Equipment Qualification Report to Consumers Power Company.
The evaluation was a draft of most of what was later to become a Safety Evaluation Report (SER) on the subject [E].
Consumers Power Company replied on February 23, 1981 [C].
In Reference C, the Licensee stated that the initial submittal [A] contained rationale on why plant operation could continue pending rectification of the deficiencies.
In Reference D, the Licensee stated that where a commitment has been made to replace the equipment, the deficiences from the TER have not been addressed as __
qualification is no longer an issue, and that justificatio~ for continued operation has not been changed.
Consumers Power Company feels that the arguments presented previously are sufficient to justify continued operation until the equipment is replaced.
Furthermore, it was assumed that the questions of the TER and the codes in the.SER were directed only _to qualification and not to justification for continued operation.
In Reference D, the Licensee has stated:
- 1When the SER and the TER were.received~ Consumers Power Company turned its efforts from the replacement of equipment to providing further information to the NRC on the qualification of existing equipment.
Although the draft version of the SER received with the February 10, 1981 letter raised questions regarding qualification, the nature of the*
questions was not clear.
With receipt of the details of the TER along with the final SER, further investigation of the qualification could resume in earnest.
This left_~ittle time to prepare the answers t~ all of the questions of the TER by the September 3, 1981 date for reply.
However, Consumers Power Company considers it important to prepare a complete response to the SER and is accordingly adding resources to work on equipment qualification.
This wilr permit the preparation of further submittals to provide detailed answers.
~nklin Research Center A Division of Th~ Franklin Institute D-5
TER-C525 7-452 Consumers Power Company intends to prepare two additional submittals on equipment qualification as follow-up to the current submittal:
- 1.
By approximately December 1, 1981, Enclosures 3, 4 and 5 of this submittal, the Equipment Qualification Report will be revised to reply to all questions contained in Section 4 of the TER except for questions relating to aging and to equipment that is being replaced.
(To FRC's knowledge, this document has not been submitted.)
- 2.
By approximately March 2, 1982, an additional submittal will address the aging problem in detail.'
FRC has reviewed Reference D and concludes that:
(1) the Licensee has not completed its response to the qualification deficiencies stated in the SER and (2) the Licensee has not addressed the deficiencies listed in the TER (and SER) for equipment which it has committed to replace; therefore, the rationale presented. previously in Reference A (and repeated in Reference D) does not, in may cases, provide an adequate technical basis as a justification for continued operation.
'It is recommended that the Licensee complete its response to the SER and specifically re-evaluate the rationale stated as justification for
.continued operation in light of the identified qualification defici~ncies."
- 4.
SUBSEQUENT REVIEW As a result of FRC's review of the Licensee's 90-day response, described
.in Section 3 above, a meeting was held on Feb.ruary 19, 1982 between members of
. *the NRC staff and Lice~see personnel.
On February 24, 1982 [ 101], the Licensee submitted a letter to provide a re-evaluation of the rationale stated as justification in previous submttals.
In Reference 101, the Licensee stated:
"Consumers Power Company intends, via this letter, to provide our re-evaluation of the rationale stated as justifications.
This re~evaluation was based on the discussions occuring in the February 19, 1982 meeting and on the four criteria used by FRC for their review and conside.red to provide this basis for adequate justification for interim operation.
This criteria is catego~ized by FRC as follows:
- 1.
Redundant equipment is av;iiable to substitute for' the unqualified equipment.
- 2.
Anothe~ system is capable of provitling the required function of.the system with unqualified equipment.
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- U~uG Frnnklin Research Center A Di;ision of The F rankJin Institute D-6
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TER-C5257-452
- 3.
The unqualified equipment will have performed its safety function prior to failure.*
- 4.
The plant can be safely shutdown in the absence of the unqualified.
equipment."
Evaluation An evaluation has been conducted of the information provided by the Licensee in Reference 101, reg~rci'ing* j~stificatbn for interim operation.
... ~-: ::.:.:..
After reviewing the technical basis of the License~.' s justification fot' continued operation for each item, it is concluded<*fhat the Licensee has provided sufficient technical basis to support justification for interim operation.
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- ulJUJ Franklin Research Center A Division of The "Franklin Institute D-7