ML19290C083
| ML19290C083 | |
| Person / Time | |
|---|---|
| Issue date: | 07/06/1979 |
| From: | Hanauer S NRC - TMI-2 UNRESOLVED SAFETY ISSUES TASK FORCE |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19290C082 | List: |
| References | |
| REF-GTECI-A-24, REF-GTECI-EL, TASK-A-24, TASK-OR NUDOCS 8001090140 | |
| Download: ML19290C083 (7) | |
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8 3 ([,h NUCLEAR REGULATORY COMMISS;ON WASHINGTON. D. C. 20S55
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MEMORANDUM FOR:
H. R. Denton, Director Office of Nuclear Rer.ctor Regulation FROM:
S. H. Hanauer. Director Unresolved Safety Issues Program RECOMMENDATION FOR FUTURE ACTIVITIES OF TASK A-24
SUBJECT:
(ENVIRONMENTALQUALIFICATION)
Sumary In this memorandum I recommend a major change in the scope and schedule of The review of NSS supplier generic topical reports should be TAP A-24.
broadened to include review of the lead plants referencing these topical This werk needs to be deferred to a schedule consistent with the reports.
review of the lead plants, and should be deleted frcm TAP A-24.
Background
Task Action Plan A-24 was established in early.1977 to review generically industry's implementation of,the qualification criteria defined in IEEE Std IEEE Standard for Qualification of Class IE Equipment for Nuclear 323-1974, Initially, the topical reports from the NSS Power Generating Station _.
suppliers and major balance of plant (B0P) designers were to be evaluated; however, only the NSS suppliers have comitted to provide the generic reports while the B0P designers opted for providing the information on the individual Currently, Westinghouse, Babcock & Wilcox and Combustion SAR applications.
Engineering have submitted their reports and General Electric comitted to submit theirs by the ead of this fiscal year.
The presently approved action plan has the following subtasks:
Request qualification methods, test plans and test procedures from all (1) standard plant nuclear steam supply system suppliers. (i.e., Westinghouse, Babcock & Wilcox, General Electric and Combustion Engineering).
Request qualification methods, test plans and test procedures from all (2) standard balance of plant architect engineers. (i.e., Stone and Webster -
SWESSAR, Fluor Pioneer - B0PSSAR, Gibbs & Hill - GIBBSSAR).
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. JUL 0 f M H. R. Denton Review and evaluate the qualification met. hods, test plans and test (3) procedures for each major equipment type (e.g., sensors, valves, motors and 'ogic modules) and asses., the degree of confomance of the design to IEEE Standard 323-1974 and the Standard Review Plan Sections 3.10 and 3.11.
An audit of. final test results on selected safety-related equipment (4) which were tested in accordance with IEEE Std 323-1974 will be con-This review of the final test ducted when this task is completed.
results will be conducted on a case basis during the OL review, to verify that the design as implemented conforms to the requirenents established in the topical reports in accordance with the standard review plan.
In NUREG 0510, published in January 1979, this plan was modified to include the development of an NRC interim position regarding methods acceptable to 323-1974. Tasks the staff of meeting the recuirements of IEEE Standard (1-4) defined above were also discussed as "further efforts" to follow development of the interim position.
Current Status Initial review of the topical reports as they came in has revealed wide There is evidently wide uncertainty variation in their scope and quality.
of where generic " methods, p.lans, and procedures" stop and " final procedures Rather than attempt to define and enforce a definitive a
and results" begin.
apportionment between topical reports and leed-plant specific information, That is, the we have concluded that the two should be reviewed together.
review of each generic topical report should be accomplished cc.ncurrently with the review of the lead plant that references the report, and with the same reviewers or closely co-ordinated if different reviewers are used.
The advantage of :ombining the topical report and lead plant reviews is economy of effort, since the interface would cause a minimum of extra effort The disadvantage is the delay in reviewing the topical report in this mode.
until the lead plant infomation becomes available.
The task action plan was thus augmented and can be described as having two phases, as follows:
phase 1 This position paper addresses Develop and issue an interim position. selected areas of qualification a which when implemented would be acceptable to the NRC Staff as complying with the requirements of IEEE-323-1974. The estimated completion of Phase 1 is August, 1979.
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7 H. R. Denton JUL 0 01979 Phase 2 r;.
Review NSS supplier generic equipment qualification topical reports in conjunction with the detailed qualification procedures and test data sub-mitted by the lead plant applicants referencing these topical reports (reviewing the lead pla.t application would include the review of BOP designs). The staff's safety evaluations should provide the guidance, if needed, to resolve any issues not identified in the Interim Position of Phase 1.
The estimated completion date for Phase 2 is 1983.
Work on Phase 2 began in April of this yeer with efforts being concentrated on qualification information provided on the Comanche Peak Docket (the lead Westinghouseplant). The review of other lead plant information was to be initiated when the FSARs are submitted for docketing. To assist the staff with the Phase 2 review, a Technical Assistance program was initiated on with Dak Ridge National Lab (ORNL). At present two full time March 20, 1979 and one part time engineer at ORNL are dedicated to assist PSB and ICSB in the performance of Phase 2 tasks.
Future Work Table I, attached, lists the lead plants and their fuel load dates. As a result of the TMI-2 event, the priorities assigned to the review of these lead plants have been redcced and the NRR manpower has been reassigned to other, higher priority tasks. Therefore, scheduling our effort on A-24 hps been reassessed. The options available are:
1.
Continue the effort on A-24 by pursuing Phase 2 with ORNL now, to o
the extent feasible, starting with topicel reports and Comancte Peak and continuing on other lead plants as the FSAR information becomes available.
Terminate TAP A-24 after completion of Phase 1 and perform the work 2.
originally designated as Phase 2 later, on a schedule determined by the OL reviev schedule of the lead plants.
3.
Leave Phase 2 in TAP A-24, but defer its schedule just as in Option 2.
All options would get the actual work done in time to license the lead plants.
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7 H. R. Denton J U !. r r 1 m
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There are several reasons in favor of continuing now with Phase 2, as stated in Option 1.
Applicants' required to conform to IEEE-323-1974 are now doing the planning and, in some cases, the actual testing to qualify their equipment.
If some of the qualification programs underway should turn out later to be inadequate, staff guidance provided to t! e licant now could alleviate the need for costly retesting later. Also,
-app considerable staff effort was required to initiate the ORNL technical assistance program and it is now beginning to gather momentum.
Continua-tion of A-24 Phase 2 (Option 1) would require the expenditure of signifi-cant manpower over the next several years. At least three manyears of effort, in-house, prcvided by senior level reviewers, would be required over the next calender year. That manpower could be made available only by postponing work on higher priority casework.
The adoption of Option 2 would allow the work formerly in A-24, Phase 2 to be performed later, on schedules consistent with the OL reviews of the lead plants (Table 1) at a time when more NRC manpower would be available.
It would also halt this work at ORNL and divert the available effort there and in-house. to higher priority work.
I believe that this is appropriate, but recognize the r.eed to hold together the OF.NL team on environmental qualification, if possible. Perhaps these people at ORNL could be assigned environmental qualification reviews on higher-priority casework.
Option 3, which would have the same effective result as Option 2 has the disadvantage of appearing to, defer work on an Unresolv.ed Safety Issue for several years. The deferral is real, but the public health and safety a
does not depend on. the detailed resolution of this issue until the lead plants are licensed to operate.
Conclusion For the reasons given above, I recomend implementing Option 2.
Enclosure 2 gives a proposed brief writeup to explain what we are doing.
S. H. Hanauer Director Unresolved Safety Issues Program
Enclosure:
1.
Table - Lead Plants for Environmental Qualifi-1B0 m cation to IEEE-323-1974 2.
Cha_nge in Scope of Task A-24 cc: See next page t
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JUL 0 61979 H. Denton.
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R. Mattson F. Schroeder D. Eisenhut D. Vassallo G. Lainas M. Aycock R. Satterfield F. Rosa T. Dunning D. Tondi A. Szukiewicz
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ENCLOSURE 1-JUL 0 61979 Table 1 Lead Plants for Erivjronmental Qualification to IEEE-323-1974 Projected Fuel load Date_
Supplier Lead Plant Westinghouse Comanche Peak MarcF 1981 September 1982 (based on a Babcock & Wilcox WUPPS 1 FSAR submittal by Dec.1979)
October 1982 (based on a General Electric Perry FSAR submittal by March 1980)
December 1982 (based on a Combustion Engineering Palo Verde 1 FSAR submittal by December 1979) 1730 208 l
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ENCLOSURE 2 JUL 0 f 1979 Change in Scope of Task A-24 Environmental Quali.fication of Safety Related Electrical Equipment l
A revised plan of werk on environmental qualification of sa'ety-related electrical equipment is as follows:
1.
Develop and issue an interim position. This position paper addresses selected areas of qualification and provides guidance and describes methods which when implemented would be acceptable to the NRC Staff as The estimated com-complying with the requirements of IEEE-323-1974.
pletion of Phase 1 is August, 1979.
Terminate Task A-24 at the completion of the item 1.
2.
Broaden the review of the HSS suppliers generic equipmer.t qualification 3.
topical reports to include assessing the implemented design associated on each of NSS suppliers lead plants.
Continue to review the HSS topical reports with the lead plant design on 4.
a schedule determined by the OL review schedule of the lead plant.
This change in scope and schedule does not effect the health and safety of the Detailed resolution of this issue will be provided in the safety public.
evaluation reports of the lead plants when they are licensed to operate.
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