ML19290C076
| ML19290C076 | |
| Person / Time | |
|---|---|
| Issue date: | 08/13/1979 |
| From: | Varga S Office of Nuclear Reactor Regulation |
| To: | Hanauer S NRC - TMI-2 UNRESOLVED SAFETY ISSUES TASK FORCE |
| Shared Package | |
| ML19290C074 | List: |
| References | |
| REF-GTECI-A-24, REF-GTECI-EL, TASK-A-24, TASK-OR NUDOCS 8001090125 | |
| Download: ML19290C076 (3) | |
Text
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'o, UNITED STATES g
I NUCLEAR REGULATORY COMMISSION g
E WASHINGTON, D. C. 20555 5
AUG 131979 dEMORANDUMFOR:
S. H. Hanauer, Director, Unresolved Safety Issues Program FROM:
S. A. Varga, Acting Assistant Director for Light Water Reactors, Division of Project Management
SUBJECT:
RECOMMENDATIONS FOR FUTURE ACTIVITIES RELATED TO GENERIC TASK A-24, ENVIRONMENTAL QUALIFICATION OF CLASS IE ELECTRICAL EQUIPMENT We have reviewed your memorandum to H. R. Denton on the subject of Recomendations for Future Activities of Task A-24 (Environmental Qualification) dated July 6, 1979.
Your memorandum can be organized around the following three subjects, on which we would like to comment:
1.
The early issuance of an Interim Position Paper, i.e., about August 1, 1979.
2.
A change in scope of TAP A-24 to terminate this task action plan on issuing the Interim Position.
3.
A selection of one of three options for future activities founded on availability of DSS staff resources.
We are encouraged to learn of the issuance of the Interim Position Paper as early as August 1979. We consider this a major step in the resolution of the generic concerns relating to equipment qualification since it will provide guidance and describe methods of qualification in selected areas which when implemented would be acceptable to the NRC staff as complying with the requirements of IEEE 323-1974. We note also your conclusion that, "The staff's safety evaluations should provide the guidance, if needed, to resolve any issues not identified in the Interim Position Paper." Therefore, we understand that a team could be assigned to review the implementation on individual plants of the acceptance criteria and methods of qualification given in the Interim Position Paper.
From a licensing project management point of view we also endorse your proposed termination of Task A-24 on the issuance of the Interim Position Pa;,er as you have proposed in the " Change in Scope of Task A-24."
The early establishment of suitable acceptance criteria against which a specific plant can be evaluated, and the termination of that " Unresolved Safety Issue" as a generic concern, will eliminate the problems associated with statements in a safety evaluation that a certain issue is resolved for this plant while it remains an " Unresolved Safety Issue."
Our difficulty with your memorandum falls to the third subject, i.e., the options you have presented.
You recommend Option 2, proposing to terminate TAP A-24 1730 193 8001000 12.5
n AUG 1 3 1979 S. H. Hanauer (which we agree should be done), and performing the remaining effort on a schedule determined by the OL review schedule. You state, "All options would get the actual work done in time to license the lead plants." Given the past history and present difficulties of this issue, we have serious doubts that postponing this effort in the case of Options 2 or 3 will permit us to license these four lead plants without delaying their fuel load dates.
May we suggest the following Option 4 to resolve your lack of resources and continue the review.
1.
Issue the Interim Position Paper as soon as possible.
2.
Terminate TAP A-24 on the issuance of the Interim Position.
3.
Assign responsioility for the implementation of the Interim Position to a team of project managers with responsibility for technical sufficiency retained in your organization and monitored through the participation of A. Suzkiewicz on the team.
Our reasons for recommending Option 4, in lieu of your Option 2, are the following:
1.
We believe that the potential for schedule impact in this matter is very great (See items 2 and 8, below). Therefore we consider it imperative that the ORNL review team be kept intact, and proceed to work on the implementation of the Interim Position. We believe that utilizing knowledgeable project managers to assist in implementing the Interim Position will lessen the impact on your internal manpower resources.
2.
The choice of Option 2 or 3 remains viable only so long as we find that the applicant did a " perfect job". Since this is a new program, it is doubtful that we and the applicant will agree completely. Therefore, it is likely with the schedule constraints that will exist, we will be limited to a partial resolution now with final resolution deferred to post-licensing or to later reviews.
3.
Transferring this review effort to a separate group for implementation will confirm that we no longer consider equipment qualification as an " Unresolved That is to say, the act of transfer is evidence that we Safety Issue".
believe the Interim Position gives adequate guidance to the industry and the reviewers to get on with the work in a manner which will resolve our concerns on this safety issue.
4.
It has been our experience that when we defer a task for high priority work, we still do not have the resources at the scheduled resumption date.
Instead, we nave a new unexpected task that also has higher priority.
In short, deferment seldom resolves any concern.
1730 194
AUG 131979 S. H. Hanauer 3_
5.
It is our understanding that the ORNL reviewers have unique qualifications relative to equipment qualification, and if we divert them to other workWe wa may be unable to use their services on this matter at a later date.
strongly recomend that the ORNL assignments to this effort be continued, and you continue to explore other resources for additional personnel for
" higher" priority work.
Transfer of this implementation effort to DPM will not alter the completion 6.
of this task in accordance with the " Change in Scope of Work of Task A-24."
7.
Your memorandum appears to omit the review of the balance-of-plant equipment which must be qualified. Thus, we consider the implementation of the Interim Position a larger task effort than your memorandum implies.
Finally, we believe that if we take a recess in our review of the equipment 8.
qualification reports on Comanche Peak we are going to cause a delay in the fuel load date. The applicant is projecting a fuel load date of March 1, 1981. We are basing our review schedule on a PDD in the sumer of 1981.
In order to provide time for the hearing we conclude the LPM must receive the SER input by July 1980. This is a difficult, first of a kind review.
We must recognize it will not go smoothly and efficiently, especially with the review team located in a separate and distant office.
We will be available to meet with you and discuss this matter further at your convenience. May we suggest that a meeting be scheduled approximately one week after your Interim Position Paper is issued.
'9&'
, Steven A. Varga,,A in ssistant Director for Light Wate actors Division of Project Management cc:
H. Denton E. Case D. Vassallo R. Her A. Suzkiewicz S. Burwell 1730 195