ML18139B193
| ML18139B193 | |
| Person / Time | |
|---|---|
| Site: | Surry, North Anna  |
| Issue date: | 01/30/1981 |
| From: | Sylvia B VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML18139B194 | List: |
| References | |
| 061, 61, IEB-79-01B, IEB-79-1B, NUDOCS 8103240567 | |
| Download: ML18139B193 (4) | |
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January 30, 1981 Mr James P. O'Reilly, D.irector Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303
Dear Mr. O'Reilly:
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Serial No. 061 NO/RGS:jmj Docket Nos*
' License IE BULLETIN 79-0lB (SUPPLEMENT No.* 3)
SURRY POWER STATION UNIT NOS. 1 AND 2 NORTH ANNA POWER STATION UNIT NO. 1
.,. 3 '1 This is in response to IE Bulletin 79-0lB, Supplement No. 3 "Environmental Qualification of Class lE. Equipment" dated October 24, 1980 on Cold Shutdown requirements and TMI Action Plan equipment.
Also included is Revision 3 to our 90 - Day Review report.
NRC Request
"(1)
Supplement No. 2 {Q.l, Q.5) addressed the minimum cold shutdown require-ments.
The staff position on this issue is that the licensee must identify and environmentally qualify the equipment needed to complete one method (path) of achieving and maintaining a.cold shutdown condition.
The equipment of other paths must be reviewed to assure that its failure will not aggravate or contribute to the accident (ref. Q.5 Supp. No. 2).
Due to an inconsistency between Supplement No. 1 and Supplement No. 2, the staff position on this issue was unclear.
Therefore, the following will apply:
- a. The qualification information for equipment needed to achieve and maintain a Hot Safe Shutdown condition must be submitted not later than November 1, 1980.
- b. The qualification information for equipment required to achieve and maintain a Cold Shutdown condition (ref. Q.l and Q.5 of Supplement No. 2) must be* submitted not later than February 1, 1981."
Response
(l)a. In Vepco letter Serial No. 887 dated October 31, 1980, we submitted the
~ the results of our review of IE Bulletin 79-0lB, Supplement 2.,
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VIBGINIA ELBCTBIC AND Powza COMPANY TO Mr. James P. O'Reilly,. Director 2
(l)b. In: response to your request for a list of equipment required to achieve and.maintain a Cold Shutdown condition, we have enclosed the requested information for your review. However, we must take exception to your request to provide the "qualification information" for this equipment.
The implication by statement (l)b that this equipment should.meet: the criteria established in IE Bulletin 79-0lB.for the environmental quali-fication.of Class lE*electrical equipment is inappropriate. The equip-ment:utilized to*achieve a Cold Shutdown condition was not designated as Class lE safety-related equipment in the design basis of the Surry and North Anna Unit 1 FSAR.' s**.
Further, North Anna. Unit 2 was granted **
a* full power license by:. the NRC on August 21,: 1980, without indication*
from the NRc* that*the Hot. Shutdown Condition was not a safe normal or abnormal mode of operation.
We are aware-that. Supplement. No. 3 to the*
Bulletin was issued on.the same day (October 24, 1980) that an Order for*Modification of License Concerning Environmental Qualification of*
Safety-Related Electrical Equipment was issued.
The. Order provides that all safety-related electrical equipment must be qualified to the:
DOR Guidelines or NUREG-0588* by June. 30,. 1982, therefore* Supplement No *. 3..
is* within the *scope of: 'the Order.
- In your letter of January 19, 1981 on the Cold. Shutdown issue*, you stated that "This.* Bulletin requirement was not. intended.to. invoke a change in the licensing basis of the plant".
You-indicated. that "Regula-tory Guide, 1.139 contains: the implementa.tion plans for. the cold. shutdown requirements,. of which* E-Q
- is-a part".
- How-ever,, Regulatory Guide* 1.139-contains a-backfit clause for plants docket*ed before... January 1,. 1978-by establishing the position that "All applications docket before,January 1, 1978,.will be reviewed against this. guide, on a case-by-case basis"~
- Based on* this ambiguous position,,. -
we*can only conclude, that: it is.your*intent to require* that all Cold
- Shutdown* condition and TMI Action Plan equipment be. enviromnentally*
qualified by June 30, 1982. It appears that the NRC is: considering back--
fitting this new requirement, but the appropriate regulatory pi;ocedures have-not been followed. Vepco has not been given opportunity* for comment
- to the. ;Bulletin requirements. To our knowledge. the NRC has not developed a value. impact assessment... It is our contention. that a new requirement
. of this magnitude should *not* have been-.established by-Supplements No. 2 and No. 3 of IE. Bulletin 79-0lB.
NRC Request..
"(21 IEB 79-0lBrequired* a 90 day* response which was, due in.mid-April 1980.
Supplement* l. (Feb. 1980) informed licensees that equipment which was, "planned"* to*be installed as* a result of lessons learned need not be addressed in that response-.
Some* of: this equipment has since been installed* *. Supplement No *. 2 (Q.S *. Q.* 21) identified that the staff posi-.
tiori was that equipment which is.installed should be treated in a manner similar to all other safety-related electrical equipment and be addressed in, the November: 1, 1980* submitta*l. This position, represents no change in staff position regarding the* scope of the review. However, since the staff position on this issue was unclear the following will. apply::
- a. Qualification information for, installed 'l'MI Action P~n equipment
- must be submitted by February 1, 1981.
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VIBOINIA ELECTRIC AND PO'WEB COMPANY TO Mr. James P. O'Reilly, Director
- b. Qualification information for future '!MI Action Plan equipment (ref.
NUREG-0737, when issued), which.requires NRC pre-implementation review, must be submitted with the pre-implementation review data.
- c. Qualification information for TM! Action Plan equipment currently under NRC review should be submitted as soon as possible.
- d. Qualification information for TMI Action Plan equipment not yet installed which does not require pre-implementation review should be submitted to NRC for review by the implementation date."
Response
(2)a.. In Vepco letter Serial No. 957 dated December 1, 1980, we submitted the qualification information for installed TMI Action_Plan equipment.
(2)b. Qualification information for* future TMI_Action Plan equipment is provided, for your review in the followii:m supplements to the IE Bulletin 79-0lB reports:
VIRGINIA ELECTRIC AND POWER COMPANY' SURRY POWER STATION UNIT 1 IE BULLETIN 79~01B REVISION 3 TMI REVIEW SUPPLEMENT. 3 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION
_UNIT 2 IE BULLETIN 79-0lB REVISION 3 TMI REVIEW SUPPLEMENT 3 VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNIT 1 IE BULLETIN 79-0lB REVISION*3 TMI REVIEW SUPPLEMENT 3 3
It is our intent to submit qualification information for 'l'MI Action Plan eqµipment which.requires NRC pre-implementation review with the pre-imple-mentation review data. * *
(2)c. In Vepco letter Serial No. 957 dated December 1, 1980, we submitted the qualification information for TMI Action Plan equipment under NRC review.
(2)d.
The qualification information for 'l'MI Action Plan equipment that has n~t yet been installed which does not require pre-implementation re-view will be submitted to the NRC for review by the implementation date.
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e V1ao1Nu. Eu:cr*1c AND Powza CoxPANY TO Mr. James P. O'Reilly, Director Revision 3 to the Report. contains information which is proprietary to Westing-house*.
Accordingly we request that. this report. be withheld from public disclosure.
In order not to delay this: submittal of information requested by the Commission, we will comply with the requirements of 10CFR2.790 to provide proprietary and non-proprietary *versions" together with an affidavit as soon*
as Westinghouse specifically*. identifies* the proprietary information contai~ed in the report and provides us with an affidavit *.
- We will submit the total required number of copies of: the proprietary and non-proprietary yersions of 4
the report and. the required affidavit at that time.
- In the meantime,. we have provided sufficient copies of the proprietary report for you to initiate your review... Westinghouse. has advised: us-that this procedure has been discussed with Mr. E. Shoemaker. of the NRC Executive Legal. Department and that he concurs.
A.copy of this: submittal is, being sent. to Westinghouse requesting them to*
specifically identify the proprietary information and to supply the required*
affidavit. Westinghouse has, advised us that* they will be able to return the report and affidavit to us within a week of t_heir receipt of the report
- If we can be of assistance-in clarifying or* interpreting information submitted with this response' to the: Bulletin~; please advise.
Very truly yours,
/l
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B. R. Sylvia Manager - Nuclear Operations and Maintenance Enclosures (6) cc:
Mr. Victor Stello, Director. (Enclosures-48)
NRC Office of rnspection and Enforcement
- Division of Reactor Operations Inspection
- Washington, D.C.. 20555*
Mr. Zoltan R. Rosztoczy,, Branch Chief (Enclosures-6)
NRC Equipment Qualification Branch Division of Engineering.
Washington,, D.C..
20555: