ML19343B164
| ML19343B164 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 10/31/1980 |
| From: | Cavanaugh W ARKANSAS POWER & LIGHT CO. |
| To: | Seyfrit K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| 1-100-29, 2-100-22, IEB-79-01B, IEB-79-1B, NUDOCS 8012150021 | |
| Download: ML19343B164 (8) | |
Text
s CENTRAL FILFS POR:HQ LPOR TIC NSIC STATE AAKANSAS PCWER & LIGHT COMPANY PCST CF3C2 eCX 551 UTP E ACCX f.AGNSAS 722C3 t501) 371-. 22 October 31, 1980 WiLL!AM CAVANAUGH 111 ves %s Gce sten & Cas:n.c:en
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v Mr. K. V. Seyfrit d),'n'
'Nh 37 Office of Inspection & Enforcement 1E; U. S. Nuclear Regulatory Commission N.
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611 Ryan Pla:a Drive, Suite 1000
^
Arlington, Texas 76011
SUBJECT:
Arkansas Nuclear One - Unit 31 & 2 Docket No. 50-313 and 50-368 IE Sulletin 79-013 - Environmental Qualification of Class IE Electrical Equipment (File: 1510.6 and 2-1510.6)
Gentlemen:
This letter is in response to IE Bulletin 79-013, Environmental Qualifi-cation of Class 1E Electrical Equipment.
This also fulfills the require-ments of the NRC's Revised Orders for Modification of Licenses, dated Septemoer 19, 1980, for ANO-1 and ANO-2.
IE Bulletin 79-01 was originally issued on February 8,1979, and later supplemented by IE Bulletin 79-01A.
AP&L responded to these bulletins by letter dated July 13, 1979.
Although no specific comments were received from the NRC relative to this resoonse, on January 14, 1980, the NRC issued IE Bulletin 79-01B.
This revision alleged that, "in general", utility responses to the original bulletin had been inadecuate.
Further, IE Bulletin 79-01B greatly increased the scoce of the original bulletin.
Scecifically, the bulletin was revised to incluce equioment located outside containment and the effects of high energy line breaks (HEL3s) outside contair.nent.
Further, the revision included " guidelines" to be used for the evaluation of equipment qualification.
In most cases these guidelines are much more stringent than the original design requirements of tne equipment being evaluated.
Due to the magnituce of work necessary to meet the requirements of IE Bulletin 79-018, AP&L, and most other utilities, were unable to meet the. original deadlines (45 and 90 days). AP&L did subnit partial resconses by letters cated February 28, 1980 and Acril 14, 1980.
In addition, after 8012150@ -
Q VEMSEA MICCLE SCUTH U*iUTES SYSTEM
Mr. K. V. Seyfri t October 31, 1980 careful evaluatien of tne work remaining, AP&L cemitted, by letter dated June 23, 1980, to complete our resconse to the bulletin by December 31, 1980.
This schedule represented AP&L's estimation of the shortest practical time ceriod to comolete the remaining work. We wish to make clear that this effort constitutes far more than a simole file search for documentation.
Our efforts in response to this bulletin have required extensive analytical work, including tnermal-hydraulic analysir of numerous postulated HEL3s in the auxiliary buildings and radiation and.'ieliing analysis both inside and outside the reactor buildings.
In additw. extensive field work was requireo to develop comouter models and to identify model numbers and loc-ations of certain comconents. A total of over S500,000 and 5 tecnnical man-years have been expended to date in response to this bulletin.
Althougn every cossible effort was being made to respond to this bulletin in a timely manner, on August 24, 1980, and August 29, 1980, AP&L received, for ANO-1 and ANO-2 respectively, orders mooifying the operating licenses to require comoletion of our casoonte by November 1,1980.
These orders were later modified on September
~4, 1980.
AP&L has accomodated this accelerated schedule.
This wa? accomplished by using certain conservative simplifications in analytical models and analysis and by accomolishing in parallel certain tasks which would have been more efficiently comoleted in series.
Following is a sumary of our response to each action item contained in the bulletin.
ITEM 1:
" Provide a ' master list' of all Engineered Safety Features Systems (Plan
- Protection Systems) required to function under postulated accident con-di tions.
Accident conditions are defined as the LOCA/HEL3 inside contain-ment, and HEL3 outside containment.
For eacn system, within (including cables, EPA's terminal blocks, etc.) the master list, identify each Class 1E electrical equipment item that is recuired to function under accident condi tions.
Pages 1 and 2 of Enclosure 2 are standard formats to be used for the ' master list' with typical infornation included.
Electrical equipment items, wnich are components of systems listed in Accendix A of Enclosure a, which are assumed to operated in the FSAR safety analysis and are relied on to mitigate design casis events are considered witnin the sccoe of this Sulletin, regardless whetner or not they were classified as part of the engineered safety features wnen the plant was originally licensed to ocerate.
The necessity for further upgrading of nonsafety-related clant systems will be decendent on the outccme of the licensees and the NRC reviews subsequent to TMI/2."
RESPONSE
The systems and components lists are included in Section 3 of the attached reports. A discussion of how these lists were developed is also included.
Mr. K. V. Seyfrit October 31, 1980 It should be noted that only those ccmoonents which could be exposed to a harsh environment are included.
ITEM 2:
"For each class 1E electrical equipment item identified in Item 1, provice written evidence of its environmental qualification to support the cacability of the item to function under postulated accident conditions.
For those class 1E electrical equipment items not having adequate qualifi-cation data available, identify your plans for determining qualifications of these items and your schedule for ccmoleting this action.
Provide this in the format of Enclosure 3."
RESPONSE
Equipment qualification data sheets are provided in Appendix A to the attached reporta.
In some cases action is presently underway to obtain missing data and is so indicated in the data sheets. Our clans for resolving other instances of incomplete documentation will be discussed in our response to item four (4).
ITEM 3:
"For equipment identified in Items 1 and 2, provide service condition pro-files (i.e., temperature, pressure, etc., as a function of time).
Thi s data should be provided for design basis accident conditions and qualifi-
.catien tests performed.
This data may be orovided in profile or tabular form."
RESPONSE
The request service conditions are provided as Section 4 of the attached report, along with a description of how these conditions were developed.
In some cases the service conditions are based on analysis desc ' bed in the facilities' FSARs.
In many cases, however, new analyses have been performed in order to provide the required service conditions.
Due to the time con-straints on our response simplifying, but conservative assumotions have been made in some cases.
If our future reviews indicate that this conservation is excessive, certain calculations may be modified at a later date.
Another significant conservatism exists in the analysis of HEL3s outside containment. When a harsh environment could exist in a comoartment cue to more than one postulated HEL3, the most severe service condition is specified. All ccmoonents in a compartment were then evaluated against the service condition regardless of whether the component is neeced to mi tigate the limiting-HEL3.
This approach may be refined during the-evaluation of certain open items.
Mr. K. V. Seyfrit October 31, 1980 ITEM 1:
" Evaluate the qualification of your Class IE electrical equipment against the guidelines provided in Enclosure 4, ' Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment', provides suoplemental infonnation to be used with these guide-lines.
For the equioment identified as having ' outstanding items' by, provide a detailed ' Equipment Qualification Plan'.
Include in this plan specific actions which will be taken to determine equicment qualification and the schedule for completing the actions."
RESPONSL:
The equipment qualification data sheets in Accendix A of the attacned i
reports indicate where open items presently exist.
Selow is a discussion of our plans and a schecule for resolving tnese open items.
" Aging" is indicated as an open item on most data sheets.
This is exotcted since the evaluation of aging was not a requirement at the time the eq;ipment was crocurec. AP&L will, however, address this item for equicment recaired to function in a harsh environment.
Action to be taken includes:
1.
Identification of materials of construction of each component.
2.
Evaluation of materials of construction to identify materials known to be susceptible to thermal aging.
3.
Based on available data, m e.ted life will be determined for each compe, 4.
Development of a periodic regi ca.
t program for certain components (or subcomocaents) identified as having an expected life less than the design life of the facilities.
AP&L plans to complete these actions by September 30 of 1981.
It should be noted that the resolution of this item is deoendent upon adeouate response from eouipment vendors and comoleteness of tneir records.
The above date is based on our current estimates of the time required.
Other open items include lack of documentation or inadequate documentation.
In no case have we concluded at this time that presently installeo equicment is not capable of being qualified.
AP&L clans to take one or more of the following actions to resolve these ocen items as appropriate.
Mr. K. V. Seyfrit October 31, 1980 1.
Continue efforts to locate missing documentation - In many cases we feel tnat, altnougn cocumentationwis not available in our files, documentation may exist from other sources.
The utility industry has funded the development of a Equipment Qualification Data Bank.
While this was not completed in time to be useful in our response to date, this system is now in the early stages of becoming operational and should be of great help in locating test reports from other utilities.
We recognize that this search cannot continue indefinitely, therefore, if missing documentation has not been located by September 30, 1981, we will assume that such document-ation does not exist and take other actions to assume adequate equipment qualification.
2.
Qual;fication by Analysis or Judgment - In some cases the differences between the service concitions and test condi-tions are small or the service conditions are not severe.
In such cases adequate qualification may be demonstrated by analysis (including refinement of service conditions) or judgment.
3.
Justification that Qualification is not needed - In some cases it may be possible to provice an alternate method of accomolishing the required function and qualification may not be required.
4 Ecuioment Requalificatioq - If required certain componer.ts will ce sucaectea to type testing to establish adequate documentation of qualification.
5.
Equicment Reolacement or Modification - In some cases equip-ment may ce reciaced or mocifiec.
Such action may be taken when qualification cannot be established or when such action is more economical than establishing qualification by type testing, analysis, etc.
AP&L is currently evaluating each comoonent to detemine which of the above actions will be taken. We will complete this initial review by February 1,1981.
This review will result in a specific action plan for each comconent.
ITEM 5:
" Identify the maximum expected flood level inside the primary containment resulting from costulated accidents.
Specify this flood level by elevation such as the 520 foot evaluation.
Provide this infomation in the format of."
Mr. K. 't. Seyfri t October 31, 1980
RESPONSE
This information was creviously provided by letter dated June 23, 1980 and is repeated below.
ANO 344'-11" ANO 343'-6" ITEM 6:
" Submit a " Licensee Event Recort" (LER) for any Class IE electrical equipment item whicn has been determined as not being capable of meeting environmental cualification requirements for service intended.
Send the LER to the aporoo-riate NRC Regional Office witnin 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of identification.
If plant coera-tion is to continue folicwing identiff ration, provide justification for sucn operation in the LER.
Provice a cetailed written report witnin la days of identification to the appropriate NRC Regional Office.
Those items wnicn were creviously reported to the NRC as not beirg qualified oer IE3-79-01 do not require an LER."
RESPONSE
To date we have discovered no sucn comoonents. However, during our contin-uing review, as described above, we will comoly with this item should we conclude that any ccmponent is not capable of meeting environmental qualification requirements.
In addition to those actions outlined in our-resconses to specific actior, items, AP&L will take further action to assure continued qualification of replacement parts. As stated in our letter of October 9, 1980, AP&L does not feel it is reasonable to require that replacement and scare parts be qualified to IEEE-323-1974 We do, however, recognize the need to assure adequate environmental cualification for such parts.
Therefore we are establishing procedures to assure that spare replacement parts reviewed against the 00R guidelines, as required for presently installed j
carts.
We will have these crocedures in effect by February 1,1981.
l As specified in my letter to you cated October 9,1980, we will crovice recuested infomation relative to eqv Oment recuired to acneive cold shutdcwn and TM1 equipment by January 1,1981.
This will fulfill the requirements of Suoplement No. 3 to this bulletin.
In summary, the attached reports and referenced documents fully respond to IE Bulletin 79-013. We recogni:e that a large number of items remain to ce resolved. We feel, newever, that these open items are the result of cnanging recuirements rather than actual deficiencies in safety related
Mr. K. V. Seyfri t Octocer 31, 1980 equipment.
Further, we feel the acticns outlined aeove will provide even greater assurance that this e4uipment will function in an adverse environ-ment in the unlikely event that it is required.
Very truly yours,.
[J
,;$/L .,a V M
J William Civpa6gh III WC:0RH:lo cc:
U. S. Nuclear Regulatory Ccmmission Office of Inspection & Enforcement Divisien of Reactor Coerations Inspections Washington, D.C.
20555 l
STATE OF ARKANSAS
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SS COUNTY OF PULASKI
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i William Cavasc;;h III, being duly sworn, states that he is Vice President, Generation & Construction, for Arkansas Power & Light Company; that he is authori:ed on the part of said Company to sign and file with the Nuclear Regulatory Comission this Supplementary Infomation; that he has reviewed or caused to have reviewed all of the statements contained in such infomation, and that all such statements made and matters set forth therein are true and correct to the best of his knowledge, informa-tion and belief.
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William Ca apaugh III SUBSCRIBED AND SWORN TO before me, a Notary Public in and for the County and State above named, this 31 day of oc w or
- 1980, 1240x LLL /L
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Uf l Notary Puolic /
My Comission Expires:
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