ML19339A614

Forwards Environ Qualification of Safety-Related Electrical Equipment & App 1, Master Listing of Electrical Components by Sys, in Response to NRC 800919 Order for Mod of License & IE Bulletin 79-01B

ML19339A614
Person / Time
Site:	Millstone
Issue date:	10/31/1980
From:	Counsil W NORTHEAST NUCLEAR ENERGY CO.
To:	Eisenhut D Office of Nuclear Reactor Regulation
Shared Package
ML19339A615	List: ML19339A614 ML19339A621 ML19339A623
References
A01204, A1204, IEB-79-01B, IEB-79-1B, NUDOCS 8011040423
Download: ML19339A614 (5)

Text

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NOR1MEAST IF11tJTIES P O Box 270

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• w e m e -i.e.co HARTFORo. CONNECTtCUT 06101 YC.17$(72E

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October 31, 1980 Docket No. 50-336 A01204 Mr. Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C. 20555

References:

(1) D. G. Eisenhut letter to W. C. Counsil dated September 19, 1980, transmitting the Revised Order for Modification of License.

(2) B. H. Grier letter to W. G. Counsil dated January 14, 1980, '

transmitting I&E Bulletin No. 79-OlB.

Gentlemen:

Millstone Nuclear Power Station, Unit No. 2 Environmental Qualification of Electrical Equipment _

By Reference (1), the NRC issued an Order and Modification of License, effective i= mediately, which requires Northeast Nuclear Energy Company (hNEC) to submit information regarding the environmental qualification of safety-related electrical equipment by November 1, 1980. Specifically, the NRC ordered the submittal of information which fully and completely responds to the Staf f's requests specified in Ref erence (2).

The purpose of this submittal is to satisfy the requirements of Ref erence (1),

in a timely fashion, by providing information regarding the environmental quclifi-cation status of safety-related electrical equipment in accordance with the Comission's guidance in this matter. It is recognized that total conf ormance to all of the applicable environmental qualification requirements is not provided for all safety-related electrical equipment subjected to harsh environments resulting from a Loss-of-Coolant Accident (LOCA), a Main Steam Line Break (MSLB) inside containment, er High Energy Line Breaks (HELB) inside and outside contain-ment. However, there exists no evidence that the equipment will fail to perform its design function or that public health and safety is compromised.

Where tote qualification information is not incorporated into the attached report, l justifica':lon for continued operation until total couformance can be achieved is i provided. Justification for continued operation is founded on several considerations, some of which are generic, others unique to specific components. Generic considera-tions are discussed on the following pages. Component-specific justification is  !

provided on equipment sumary sheets in Appendix II of this report. Particular l emphasis is directed towards the following 'oasas and assumptions utilized in preparing the attached report.

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5 (1) Where available, qualification documentation for electrical equipment associated with TMI requirements has been included. The current absence of documentation for equipment not required to mitigate the effects of a design basis event or equipment which is not yet installed is acceptable and is consistent with the requirements of I&E Bulletin No.79-01B, Supplement 3. Qualification documentation is an integral part of post-TMI requirements and will be provided in accordance with lessons-learned requirements or other commitments previously made. ,

(2) There are instances where safety-related electrical equipment will have performed and completed its safety function within the first several seconds of the start of an accident. Reccgnition of this fact provides reasonable justification for continued operation until fully qualified replacements can be procured and installed. The NRC requirement for qualific . tion of equipment for a period of at least one hour beyond its functional requirement is arbitrary and has not been supported from a technical standpoint. Substantive industry comments were forwarded to the NRC on this matter sehsequent to the initial publication of NUREG-0588.

Dispcsition of these comments would provide en appropriate vehicle for resolving the divergent points of view which now exist between the NRC Staff and the industry.

(3) The development of the list of equipment requiring qualification included equipment required to achieve a cold shutdova condition. However, the fundamental objective of the program is to demonstrate that safe shutdown, i.e., hot shutdown, can be successfully achieved. This approach is consistent with NRC requirements as stated in Supplement 1 to I&E Bulletin No.79-01B, which was issued on February 29, 1980, and Supple-ment 3 which was issued on October 24, 1980. In addition, the ability to achieve a cold shutdown condition using safety-grade equipment was noc a design requirement for Milletone Unit No. 2. It is NNECO's intention to provide additional information dccumenting environmental qualification of electrical equipment required for cold shutdcwn by February 1, 1981.

(4) In certain cases, justification for continued operation recognizes the existence of safety-related equipment which is redundent to equipment lacking one or more facets of the requisite qualification. Although redundancy considerations are affected by the absence of full qualifica-tion for both redundant components, it is unlikely that such failures would occur simultaneously. In many instances, the edundant equipment has significant physical separation which would intr Juce additional conservatism into the specification of environmental profiles. These conservatisms are in addition to those irherent in the profile development in that worst-case initial conditions and assumptions were utilized for those calculations.

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(5) The mention of electrical equipment in emergency operating procedures does not, of 'itself, necessitate qualification of such components in l accordance with all applicable NRC requirements. The emergency operating  !

i procedures were not developed by considering saf ety-related components to the exclusion of all others. Although saf ety-related equipment was given priority, other systems and components are justifiably involved.

A realistic evaluation of plant incidents would result in situations and hostile environments significantly different from those assumed for the purposes of conducting the environmental qualification program. The absence of full qualification for certain components which fall into this category is not, by itself, sufficient grounds to classify the equipment inoperable or to remove these components from being utilized in the procedures.

Specific applications of this philosophy are identified in the Appendix of System Component Evaluation Work Shet ts (SCEWS) and the associated justifica-tions for continued operation where applicable.

(6) The section of qualification test reports addressing chemical spray is normally based upon an assumption of there being a buffered spray solution rather than pure borated water. A preliminary engineering evaluation suggests that this difference is not significant, and is, therefore, not considered to be grounds for disqualification at this time. It is noted that the containment spray system is redundant to the containment air recirculation system regarding design basis containment heat removal demands. Even without the containment spray system, operation of three of the four available CAR fans is sufficient for containment heat removal.

(?) Although the qualification requirements address a design life of 40 years, it is emphasized that the equipment currently in service is typically only 8 - 12 years old, and in some cases, is much newer. This provides additional assurance of its ability to function as required.

(8) Although many components were installed prior to the qualification require-ments for aging, the effects will be identified by a materials susceptibility analysis. The results of the review will be included in the considerations for equipment replacement on a case-by-case basis, recognizing the require-ment for fully qualified equipment by June 30, 1982.

(9) In all instances whare the qualification documentation is less than complete, there exists no evidence that the equipment will fail to perform its design function, or that public health and saf ety is compromised.

Consideration of a histori al summary of this issue provides additionci insight into understanding the dif ficulties encountered by NNECO in addressing this -

concern to the satisf action of the Staff with optimum utilization of Aimiced resources. Issuance of new criteria during the latter stages of this segment of the qualification program has Lapeded its resolution.

Since the issuance of I&E Bulletin No. 79-01, NNECO has devoted significant resources to the resolution of this issue. However, upon the issuance of I&E Bulletin No. 79-OlB, NNECO embarked upon a comprehensive qualification ef fort to assemble the requested information, support the audit activities of the Staff, and to support the Staf f 's schedule. Section A of the attached report elaborates on the numerous and significant changes in NRC requirements which have occurred during the past 18 months. It is unfortunate that such changes continue to occur even during the final stages of preparation of this document. The issuance of Supplement 3 to I&E Bulletin No.79-013 on October 24, 1980 is supportive of this position. The myriad of Staff guidance documents on this subject and the significant technical judgments which must be exercised render it extremely difficult to ascertain what level of qualification documentation would constitute indisputable conformance with Reference (1). NNECO has endeavored to comply with its interpretation of the intent of the Staff requirements. Specifically, the purpose of the attached report is to assure that all equipment which is required to function in a harsh environment will, in fact, do so. The absence of full and complete compliance to the Staff requirements is judged to be acceptabla, as in these instances, justifi-cation is provided for continued operation. Where appropriate, commitments have been made to complete a replacement program as soon as practicable before June 30, 1982, assuming procurement delays do not prohibit replacement by this date.

In the May 23, 1980 Memorandum and Order, the Commission stated that:

"We believa that current Commission requirements in . ..

environment qualification areas and those actions we order today provide reasonable assurance that the public health and safety is being adequately protected during the time necessary for corrective action."

Very substantial progress towards total equipment qualification documentation has been made by NNECO since the date of issuance of this Order, which further supports the reasonableness and appropriateness of the Commission's determination that public health and safety is being adequately protected.

In summary, in accordance with Commission requirements, it is NNECO's intention to have all necessary electrical equipment fully qualified by June 30, 1982.

In many instances where a replacement strategy has been identified, the replacement process is intended to be completed as much before this deadline as possible.

Based upon the information in the attached report entitled " Environmental Qualification of Elect rical Equipment - Millstone Unit No. 2", as clarified and supplemented by the above informatics, NNECO concludes that a full and complete response to Reference (1) is hereby provided. l

\

Very truly yours, )

NORTHEAST NUCI. EAR i.NERGY COMPANY W. G. Counsil Senior Vice President Attachments l

J STATE OF CONNECTICUT )

) ss. Berlin - 31; Il PO COUNTY OF RARTFORD )

Then personally appeared before me W. G. Counsil, who being duly sworn, did state that he is Senior Vice President of Northeast Nuclear Energy Company, a Licensee herein, that he is authorized to execute and file the foregoing information in the name and on behalf of the Licensees herein and that the statements contained in said information are true and correct to the best of his knowledge and belief.

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Notary Public My Commialon Expkss March 31.1931 1

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