ML18092A475
| ML18092A475 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 01/14/1985 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML18092A474 | List: |
| References | |
| NUDOCS 8501300122 | |
| Download: ML18092A475 (10) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 SAFETY EVALUATION PUBLIC SERVICE ELECTRIC AND GAS COMPANY ENVIRONMENTAL QUALIFICATION OF ELECTRIC EQUIPMENT IMPORTANT TO SAFETY SALEM NUCLEAR GENERATING STATION UNIT 2 INTRODUCTION Equipment which is used to perfonn a necessary safety function must be demonstrated to be capable of maintaining functional operability under all service conditions postulated to oc~ur during its installed life for the time it.is required to operate. This requirement, which is embodied in General*
Design Criteria 1 and 4 of Appendix A and Sections III, XI, and XVII of Appendix B to 10 CFR 50, is applicable to equipment located inside as well as outside containment. More detailed requirements and guidance relating to the methods and procedures for demonstrating this capability for electrical equipment have been set forth in 10 CFR 50.49, "Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants," NUREG-0588, "Interim Staff Position on Environme~tal Qualification of Safety-Related Electrical Equipment" (which supplements IEEE 's.tandard 323 and various NRC Regulatory.Guides and industry standards), and "Guidelines for Evaluating Environmental Qualification of Class lE Electrical Equipment in Operating Reactors" (DOR Guidelines).
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, "Environmental 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 qualification programs.
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2 On January 14, 1980, the NRC issued IE8 79-018 which included the DOR Guide-lines and NUREG-0588 as attachments 4 and 5, respectively. Subsequently, on May 23, 1980, Cormnission Memorandum and Order CLI-80-21 was issued and stated that the DOR Guidelines and portions of NUREG-0588 form the requirements 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 IE8 79-018 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 September 1980) and October 24, 1980 to a 11 *1 icensees. The August order required that the licensees provide a report, by November 1, 1980, documenting 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 a Safety Evaluation Report (SER) on environmental qualification of safety-related electrical equipment to the licensee on June 8, 1981. This* SER directed the licensee to "either provide documentation of the missing qualification information which demonstrates that safety-related equipment meets the DOR Guidelines or NUREG-0588 requirements or cormnit to a corrective action (requalification, replacement (etc.))." The licensee was required to respond to the NRC within 90 days of receipt of the SER.
In response to the staff SER issued in 1981, the licensee submitted additional information regarding the qualification of safety-related electrical equipment. This information was evaluated for the staff by the Franklin Research Center (FRC) in order to:
- 1) identify all cases where the licensee's response did not resolve the significant qualification issues, 2) evaluate the licensee's qualification documentation in accordance with established criteria to determine which equipment had adequate documentation and which did not, and 3) evaluate the licensee's qualification documentation for safety-related electrical equipment located in harsh environments required for TMI Lessons Learned Implementation. A Technical Evaluation Report (TER) was issued by FRC on July 15, 1982. A Safety Evaluation Report was subsequently issued to the Public Service Electric and Gas Company on January 19, 1983, with the FR~ TER as an attachment.
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3 A final rule on environmental qualification of electric equipment important to safety for nuclear power plants became effective on February 22, 1983. This rule, Section 50.49 of 10 CFR 50, specifies the requirement to be met for demonstrating the environmental qualification of electrical equipment important to safety located in a harsh environment.
In accordance with this rule, equipment for Salem Unit 2 may be qualified to the criteria specified in either the DOR Guidelines or NUREG-0588, except for replacement equipment.
Replacement equipment installed subsequent to February 22, 1983 must be qualified in accordance with the provisions of 10 CFR 50.49, using the guidance of Regulatory Guide 1.89, unless there are sound reasons to the contrary.
A meeting was held with each licensee of plants for which a TER had been prepared for the staff by FRC in order to discuss all remaining open issues regarding environmental qualification,.including acceptability of the environmental conditions for equipment qualification purposes, if this issue had not yet been resolved.
On April 24, 1984 a meeting was held to discuss Public Service Electric and Gas Company's proposed method to resolve the environmental qualification deficiencies identified in the January 19, 1983 SER and July 15, 1982 FRC TER.
Discussions also included Public Service Electric and Gas Company's general methodology for compliance with 10 CFR 50.49, and justification for continued operation for those equipment items for which environmental qualification is not yet completed.
The minutes of the meeting and proposed method of resolution for each of the environmental qualification deficiencies are documented in a June 8, 1984 submittal from the licensee.
Additional information was transmitted by letters of September 7 and November 9, 1984.
EVALUATION The evaluation of the acceptability of the licensee's electrical equipment environmental qualification program is based on the results of an audit review performed by the staff of:
(1) the licensee's proposed resolutions of the environmental qualification deficiencies identified in the January 19, 1983
. SER and July 15, 1982 FRC TER; (2) compliance with the requirements of 10 CFR 50.49; and (3) justification for continued operation (JCO) for those equipment items for which the environmental qualification is not yet completed.
4 Proposed Resolutions of Identified Deficiencies The proposed resolutions for the equipment environmental qualification deficiencies, identified in the January 19, 1983 SER, and the FRC TER enclosed with it, are described in the licensee's June 8, 1984 submittal.
During the April 24, 1984 meeting with the licensee, the staff discussed the proposed resolution of each deficiency for each equipment item identified in the FRC TER and found the licensee's approach for resolving the identified environmental qualification deficiencies acceptable. The majority of deficiencies identified were documentation, similarity, aging, qualified life and replacement schedule. All open items identified in the SER dated January 19, 1983 were also discussed and the resolution of these items has been found acceptable by the staff. Additional information was transmitted by letters of September 7 and November 9, 1984.
The approach described by the licensee for addressing and resolving the identified deficiencies includes replacing equipment, performing additional analyses, utilizing additional qualification documentation beyond that reviewed by FRC, obtaining additional qualification documentation, and determining that some equipment is outside the scope of 10 CFR 50.49, and therefore not required to be environmentally qualified, e.g., located in a mild environment.
We discussed the proposed resolutions in detail on an item by item basis with the licensee during the April 24, 1984 meeting.
Replacing or exempting equipment, for an acceptable reason, are clearly acceptable
-methods for resolving environmental qualification deficiencies. The more lengthy discussions with the licensee concerned the use of additional analyses or documentation. Although we did not review the additional analyses or documentation, w_e discussed how analysis was being used to resolve deficiencies identified in the FRC TER, and the content of the additional documentation in order to determine the acceptability of these methods.
The licensee's equipment environmental qualification files will be audited by the staff during follow-up inspections to be performed by Region 1, with assistance from IE Headquarters and NRR staff as necessary. Since a significant amount of documentation has already been reviewed by the staff and Franklin Research Center, the primary objective of the file audit will be to veri-fy that they contain the appropriate analyses and other necessary documentation to support the licensee's conclusion that the equipment is
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5 qualified. The inspections will verify that the licensee's program for surveillance and maintenance of environmentally qualified equipment is adequate to assure that this equipment is maintained in the as analyzed or tested condition.
The method used for tracking periodic replacement parts, and implementation of the licensee's conmiitments and actions, e.g., regarding replacement of equipment, will also be verified.
Based on our discussions with the licensee and our review of its submittal, we find the licensee's approach for resolving the identified environmental qualification deficiencies acceptable.
Compliance With 10 CFR 50.49 In its June 8, 1984 submittal, the licensee has described the approach used to identify equipment within the scope of paragraph (b)(l) of 10 CFR 50.49, equipment relied upon to remain functional during and following design basis events. The licensee states that the flooding and environmental effects resulting from all postulated design-basis accidents documented in the Salem Updated Final Safety Analysis Report (UFSAR), including the Loss-of-Coolant Accident (LOCA) and the Steam Line Break Accidents (SLBA), were considered in the identification of safety-related electrical equipment which was to be environmentally qualified~ The flooding and environmental effects resulting from High-Energy Line Breaks (HELBs) outside containment were also considered in the identification of this equipment. Therefore, all design-basis events including accidents at Salem Unit 2 were considered in the identification of electrical equipment within the scope of paragraph (b)(l) of 10 CFR 50.49 (i.e., "Safety-related electric equipment ***
11 ).
The licensee's approach for identifying equipment within the scope of paragraph (b){l) is in accordance with the requirements of that paragraph, and therefore acceptahle.
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6 The method used by the licensee for identification of electrical equipment within the scope of paragraph (b)(2) of 10 CFR 50.49, nonsafety-related electric equipment whose failure under postulated environmental conditions could prevent satisfactory accomplishment of safety functions, is summarized below:
- 1.
A list was generated of safety-related electric equipment as defined in paragraph (b)(l) of 10 CFR 50.49 required to remain functional during or following design-basis Loss of Coolant Accident (LOCA) or High Energy Line Break (HELB) Accidents.
The LOCA/HELB accidents are the only design-basis accidents which result in significantly adverse environments to electrical equipment which is required for safe shutdown or accident mitigation. The list was based on reviews of the Salem Updated Final Safety Analysis Report (UFSAR), Technical Specifications, Emergency Operating Procedures, Piping and Instrumentation Diagrams (P&IDs), and electrical distribution diagrams;
- 2.
The elementary wiring diagrams of the safety-related electrical equipment identified in Step 1 were reviewed to identify any auxiliary devices electrically connected directly into the control or power circuitry of the safety-related equipment* (e.g., automatic trips) whose failure due to postYlated environmental conditions could prevent the required operation of the safety-related equipment; and
- 3.
The operation of the safety-related systems and equipment were reviewed to identify any directly mechanically connected auxiliary systems with electrical components which are necessary for the required operation of the safety-related equipment (e.g., cooling water or lubricating systems). This involved the review of P&IDs, component technical manuals, and/or systems descriptions in the UFSAR.
- 4.
Nonsafety-related electrical circuits indirectly associated with the electrical equipment identified in Step 1 by common power supply or physical proximity were considered by a review of the original Salem Unit 2 electrical design including the use of applicable industry standards and the use of properly coordinated protective relays, circuit breakers, and fuses for electrical fault protection.
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The licensee states that the results of the above review indicated that no additional electrical equipment was identified which was not previously included on that "Master List.
11 Therefore, the list of electrical equipment provided in its June 8, 1984 submittal is judged by the licensee to address all electrical equipment within the scope of paragraph (b}(2} of 10 CFR 50.49.
We find the methodology used by the licensee is acceptable since it provides reasonable assurance that equipment within the scope of paragraph (b}{2} of 10 CFR 50.49 has been identified.
With regard to paragraph (b}(3} of 10 CFR 50.49, the licensee evaluated existing system arrangements and identified equipment for the five types of variables defined in R.G." 1.97, Rev. 3. A report outlining the results of the review, schedules for modifications.where necessary, and justification of devfations not requiring modifications has been submitted to the NRC for approval. Since the report is still under review by the staff, some of the equipment identified in the report has not been added to the 10 CFR 50.49 scope.
However, some of the equipment items jointly within the scope of NUREG-0737 and R.G. 1.97 have been included in the 10 CFR 50.49 scope.
When
- the R.G. 1.97 report and equipment lists contained therein have been finalized and accepted by the staff, appropriate equipment not already in the 10 CFR 50.49 scope will be added in accordance-with the R.G. 1.97 implementation schedule.
We find the licensee's approach to identifying equipment within the scope of paragraph (b)(3) of 10 CFR 50.49 acceptable since it is in accordance with the requirements of that paragraph.
Justificatiori for Continued Operation The licensee has provided, in its November 9, 1984 letter, justification for continued operation addressing each item of equipment for which the environmental qualification is not yet completed (see enclosure for the JCO*
equipment list).
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8 We have reviewed each JCO provided by the licensee in its November 9, 1984 letter and find them acceptable since they are based on essentially the same criteria that were used by the staff and its contractor to review JCO's previously submitted by licensees. These criteria, listed below, are also essentially the same as those contained in 10 CFR 50.49(i).
- a.
The safety function can be accomplished by some other designated equipment that is qualified, and failure of the principal equipment as a result of the harsh environment will not degrade other safety functions or mislead the operator.
- b.
Partial test data that does not demonstrate full qualification, but provides a basis for concluding the equipment will perform its function.
If it can not be concluded from the available data that the equipment wil) not fail after completion of its safety function, then that failure must not result in significant degradation of any safety function or provide misleading information to the operator.
- c.
Limited use of administrative controls over equipment that has not been demonstrated to be fully qualified. For any equipment assumed to fail as a result of the accident environment, that failure must not result in significant degradation of any safety function or provide misleading information to the operator.
CONCLUSIONS Based on the above evaluation, we conclude the following with regard to the qualification of electric equipment important to safety within the scope of 10 CFR 50.49.
0 Public Service Electric and Gas Company's electrical equipment environmental qualification program complies with the requirements of 10 CFR 50.49.
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9 The proposed resolutions for each of the environmental qualification deficiencies identified in the January 19, 1983 SER and FRC TER are acceptable.
Continued operation until completion of the licensee's environmental qualification program will not present undue risk to the public health and safety.
Principal Contributor:
P. Shemanski
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- 10 ENCLOSURE
- Justification for Continued Operation Equipment List Salem Tag Number TA-1564, TA-1576 XA 5699, XA 5700 XA 5705, XA 5706 XA 5711, XA 5712 XA 5713, XA 5714 NRC Tag Number None None Description Temperature Indicators Neutron Flux Monitors