ML19345E221
| ML19345E221 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 12/16/1980 |
| From: | Cavanaugh W ARKANSAS POWER & LIGHT CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| 1-120-09, 1-120-9, 2-120-20, NUDOCS 8012230482 | |
| Download: ML19345E221 (5) | |
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December 16, 1980 jj as WILLIAM CAVANAUGH 111 Vce Pmsident Generation & Constmetion 1-120-09 2-120-20 Mr. Harold R. Denton, Director Office of Nuclear-Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C.
20555
SUBJECT:
Arkansas Nuclear One - Units 1 & 2 Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6 Environmental Qualification of Class IE Electrical Equipment (File: 1510.6,2-1510.6)
Gentlemen:
On October 24, 1980, the NRC issued Orders for Modification of Licenses on the dockets of Arkansas Nuclear One - Units One and Two (ANO-1 and AN0-2).
These Orders added provisions to.the Technical Specifications of ANO-1 and ANO-2 requiring that "all safety-related" electrical equipment be qualified in accordance with the Division of Operating Reactor's, Guidelines For Evaluating Environmental Qualification of Class 1E Electrical Equipment In Ooerating Reactors (DOR Guidelines) by June 30, 1982.
In addition, the Orders required that documentation of such qualification be assembled at a central location by December 1,1980.
After reviewing these Orders, and other recent bulletins and orders on this issue, we determined that the wording of the Orders was not sufficiently clear to allow us to determine how they might be implemented by the NRC staff or to ascertain the feasibility of complying with the specified deadlines.
In an effort to clarify the intent of these Orders, AP&L representatives met with members of the NRC staff on Wednesday, December 3,1980, at NRC headquarters in Bethesda. The staff attempted to resolve several items of concern at this meeting. Following ~is a summary of those items.
1.
COMPLIANCE WITH DOR GUIDELINES The D0R Guidelines, as the name implies, are a set of guides. for the evaluation of environmental qualification of electrical equipment.
As such, this document is written in general terms and.does not lend 8012 280 h 2-
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Mr. Harold R. Denton, Di rector December 16, 1980 1
itself to implementation as a rigid requirement as the October 24, 1980 Orders iuply.
As noted in Section 1.0 of the Guidelines:
"The objective of the evaluations using these guidelines is to identify class 1E equipment whose documentation does not provide reasonable assurance of environmental qualification. All such equipment identified will then be subjected to a plant application specific evaluation to determine whether it should be requalified or replaced The general guidance nature of the document is confirmed repeatedly by the use of the words "should", "may be", and " generally." To site only a few examples:
SECTION 5.1 Selection of Qualification Method
" Exceptions to these general guidelines must be justified on a case by case basis."
SECTION 5.2(1) Simulated Service Conditions and Test Duration "A shorter. test duration may be acceptable if specific analyses are provided...."
SECTION 5.2(4) Test Specimen Aging "Arrhenius techniques are generally considered acceptable for thermal aging."
The NRC staff noted during our December 3,1980 meeting that the Guidelines are "very flexible." This interpretation is consistent with the portions noted above. Such flexibility is essential for the purpose to which they were originally intended.
- However, the NRC October 24, 1980 Orders establish these Guidelines as very specific Technical Specification requirements.
In this context this " flexibility" constitutes vagueness and causes us great uncertainty as to the staff's implementation.
As would be expected, the application of recently developed standards to operating plants has resulted in an extremelv large number of open items.
Thus the judgement in exerc' the flexibility of the D0R Guidelines will have a tremer impact on the number of components requiring requalific i
or replacement. The staff noted during the meeting ti ieir interpretation of the D0R Guidelines will become clea.,
after Safety Evaluation Reports (SERs) are issued in February of next year.
However, the Orders issued October 24, 1980 are already 4
in effect and our opportunity to request a hearing on the matter i
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O Mr. Harold R. Denton, Di rector December 16, 1980 expired on December 4,1980.
In view of the uncertainty associated with implementation of the Guidelines, AP&L felt compelled to request a hearing, pending clarification of the Orders and review of the SERs to be issued in February. We urge that the staff clarify the intended use of the Guidelines, either by modification of the original Orders or issuance of a clarification letter.
2.
SCOPE OF EQUIPMENT CONSIDERED From our discussions with the NRC staff, it is clear that there is no consensus as to the meaning of the term " safety-related" as used in the October 24, 1980 Orders.
It is our position that these Orders should be restricted to safety-related equipment as defined by the design basis of the facilities. The design basis of both ANO-1 and AN0-2 is that the safe shutdown condition is hot shutdown.
The NRC's position on this is unclear.
In addition, the status of certain TMI Action Plan items is unclear. We are presently compiling information on these components (cold shutdown and TMI Action Plan) as required by Supplement No. 3 to IE Bulletin 79-018.
However, we do not necessarily agree that all such equipment need be fully qualified.
Such equipment is certainly not of as high a priority as that addressed in our October 31, 1980 submittal.
Further, an IE Bulletin is not the proper mechanism for attempted modifications of the design basis.
Another item of concern is equipment located in " mild" environments.
Although such equipment was not addressed by IE Bulletin 79-01B, the staff has informed us that this equipment is included in the scope of the October 24, 1980 Orders. The staff has indicated that such equipment will be the subject of future bulletins or supplements and that the effort required to address this equipment will be much less than that for equipment located in harsh environments.
We fear the staff may be underestimating the effort required.
1 Since we have not yet identified this equipment and the NRC has yet to issue the expected bulletins or supplements, we do not feel that such equipment should be considered in the same time frame as that equipment located in harsh environments.
Equipment located in mild environments is not exposed to any unusual stress as a result of an accident, therefore, we do not understand why such equipment should be given such high priority, distracting
'from our efforts to resolve problems with equipment in harsh environments. We request that the staff modify the original Orders to exclude equipment in mild environments.
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Mr. Harold R. Denton, Di rector December 16, 1980 3.
IMPLEMENTATION SCHEDULE In light of the problems discussed above, we are at present unable to define accurately the scope of work required to meet the June 30, 1982 deadline imposed by the October 27, 1980 Orders. We are also puzzled as to the basis for this as the deadline for qualification of equipment.
This deadline was imposed prior to the deadline for response to IE Bulletin 79-01B. We feel that such an arbitrary date is inappropriate.
Prior to enforcing such an arbitrary compliance deadline, the NRC should carefully consider the magnitude of the effort required to comply, the availability of required technical manpower, the availability of test facilities and the availability of qualified replacement parts. We recognize, of course, that the June 30, 1982 deadline was established by the Commission itself, and that it is to the Commission that a request for relief should be addressed.
4.
DOCUMENTATION REQUIREMENTS Our concerns relative to the documentation requirements of the October 24, 1980 Orders were resolved by the distribution of a clarification letter signed by Mr. Darrell Eisenhut dated November 26, 1980. The staff further clarified the requirements by stating, during the December 3,1980 meeting, that separate files are acceptable, one at the utility and one at the appropriate NSSS vendor.
5.
SPARE PARTS The NRC has established its position that spare and replacement parts should be qualified in accordance with IEEE-322-1974 unless there are " sound reasons to the contrary." We cannot agree with or understand the reasons for such a requirement. The NRC stated their position that the D0R Guidelines are acceptable criteria (indeed the only acceptable criteria) for defining compliance with the General Design Criteria.
Further, the NRC has determined that presently installed parts, qualified to the D0R Guidelines, are adequate for continued use.
The NRC position on spare parts, however, leads to the conclusion that installed parts are adequate to assure safe operation until they break, at which time an identical spare is not.
This position may actually be detrimental to safe operation, resulting, in time, in a plant with a haphazard mixture of brands and models within safety systems.
It is not clear to us, for example, how safety is enhanced by replacing one of four like transmitters (each qualified to the D0R Guidelines) with one of a different type' simply because it meets IEEE 323-1974.
The
4 Mr. Harold R. Denton, Director December 16, 1980 resulting system could create engineering and maintenance problems.
The staff should also recognize that the replacement of installed parts with those of different model or type is seldom a simple change out, but may require changes throughout the affected system, reanalysis of safety system setpoints, etc. Therefore, we strongly urge that NRC reconsider its position on this requirement and issue further clarification on this issue.
Such clarification should, as a minimum, establish that system redesign and modification is not the intent of the Comission's Order and that the above concerns, along with parts unavailability, etc., constitute adequate
" sound reasons to the contrary." The clarification should also establish the definition of " spare" and " replacement" parts.
For example, subcomponents of installed parts (i.e., 0-rings, gaskets, resistors, etc.) should be excluded.
Due to our many uncertainties in regard to the October 24, 1980 Orders,
we have requested a hearing on this matter by letter dated December 4,1980.
We hope that these concerns can be resolved prior to such hearings and we consider the December 3 meeting to be a meaningful first step. We stand ready to work with the NRC staff to resolve the difficulties.
Very truly yours,.
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<.ws William Chvanaugh III WC:DRH:1p cc: Mr. K. V. Seyfrit, Director Office of Inspection & Enforcement U. S. Nuclear Regulatory Comm.
Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011