ML19350F169

Affidavit That Licensees Could Not Meet CLI-80-21 820630 Deadline Due to Lack of Appropriate Regulatory Guidance to Allow Utils to Proceed W/Qualification,Replacement or Reanalysis of Equipment.W/Certificate of Svc

ML19350F169
Person / Time
Site:	Beaver Valley, Millstone, Monticello, Calvert Cliffs, Dresden, Oconee, Mcguire, Indian Point, Catawba, Harris, Saint Lucie, Point Beach, Grand Gulf, Byron, Pilgrim, Arkansas Nuclear, Braidwood, Prairie Island, Columbia, Brunswick, Surry, North Anna, Turkey Point, Robinson, San Onofre, Comanche Peak, Yankee Rowe, Quad Cities, Zion, FitzPatrick, McGuire, LaSalle, 05000496, 05000497, 05000502, 05000471, 05000484, Washington Public Power Supply System, Satsop, Perkins, Cherokee, Green County
Issue date:	06/19/1981
From:	Larson W Arkansas Power & Light Co, Baltimore Gas & Electric Co (BGE), Boston Edison Co, Carolina Power & Light Co, Commonwealth Edison Co, Duke Power Co, Duquesne Light Co, Engineering & Management, Florida Power & Light Co, Mississippi Power & Light Co, Northeast Utilities, Northern States Power Co, Power Authority of the State of New York, Southern California Edison Co, Texas Utilities Electric Co, Virginia Power (Virginia Electric & Power Co), Washington Public Power Supply System, Wisconsin Electric Power Co, Yankee Atomic Electric Co
To:	NRC/OCM
Shared Package
ML19350F156	List: ML19350F155 ML19350F169
References
CLI-80-021, TAC-42493 NUDOCS 8106240317
Download: ML19350F169 (5)

Text

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AttCchment A N~]

UNITED STATES 3F AMERICA NUCLEAR REGULAT',AY COMMISSION BEFORE THE COMMISSION

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In the Matter of

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CLI-80-21, COMMISSION

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MEMORANDUM AND ORDER

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AFFIDAVIT OF W.

WADE LARSON Comes now Affiant, W. Wave Larson, Vice President of Engineering Plannir.g and Management, Inc., after having been duly sworn, and states as follows:

For * past several years, I have c,losely followed and been intimately involved from the perspective of the nuclear industry with the regulation by NRC of the environ-mental qualification of Class IE equipment in nuclear power reactors.

In this regard, I am familiar with the Equipment Evaluation Reports ("EER") on environmental qualification recently issued by the NRC Staff to most holders of NRC l

operating licenses listing equipment with ' potential quali-fication documentation inadequacies.

I have specifically reviewed, in detail, EERs sent to all 14 of the 18 utilities t

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810624"3 / 7

. involved here that are holders of NRC operating licenses. */

I have also reviewed licensee responses prepared by the affected 14 utilities involved here.

In late May and early June 1981, the NRC Staff issued Safety Evaluation Reports ("SERs") on equipment qualifications that, inter alia, listed equipment with potential qualifi-cation documentation inadeguacies.

Shortly thereafter, we reviewed SERs issued and compared them with Ebe EERs as to the scope of the items evaluated and the listing of potential documentation inadequacies.

The results of that comparison showed that the SERs did not significantly reduce the magnitude of the scope of the items evaluated or the listing of potential documentation inadequacies contained in the EERs.

Also, we conducted a survey of the affected NRC licensees involved here to determine their perspective on whether the SERs narrowed the scope of open items contained in the

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Of the 18 utilities involved, the following 14 received EERs:. Arkansas Power & Light Company, Baltimore Gas &

Electric Company, Boston Edison Company, Carolina Power

& Light Company, Commonwealth Edisen Company, Duke Power Company, Florida Power & Light Company', Northeast Utilities, Northern States Power Company, Power Authority of the State of New York, Southern California Edison Company, Virginia Electric & Power Company, Wisconsin Electric Power Company, and Yaakee Atomic Electric Company.

Of the four utilities that did not recieve EERs, the following three are not holders of NRC power reactor Operating Licenses:

Mississippi Fawer & Light Company, Texas Utilities Cenerating Company and Washington Public Power Supply System.

In addition, Duquesne Light Company did not receive an EER.

4 EERs. The result of this survey was that all licensees stated that the SERs did'not significantly narrow the' scope of the open items set forth in the EERs.

On the' basis of the foregoing, I evaluated whether the affected NRC. licensees involved here could comply by June 30, 1982, with the requirements imposed by the Staff 'pur- -

suant to CLI-80-21.

I based my evaluation on my personal knowledge and professional judgment, and upon personal in-

.quiries to several vendors of Class IE equipment to deter-mine availability of qualified equipment.

I concluded that affected NRC licensees involved here could not meet the June 30, 1982, deadline primarily due to (1) the ic1k of appropriate regulatory guidance sufficient to allow licensees

.to proceed with either the qualification, replacement or reanalysis of Class IE equipment found by the Staff to have qualification documentation deficiencies and which may thus require further action, and (2) the unavailability of components with the qualification documentation necessary to satisfy the NRC Staff.

In order to confirm my conclusions, I surveyed the affected NRC licensees involved here to obtain independent judgments f om each on whether each reasonably ar.ticipated that the June 30, 1982, deadline could be n.*t.

All licensees responded that they could not meet the June 30,

L 1982, deadline.

The principal reasons stated for these independent conclusions were (1) lack of timely NRC guidance, and (2) the -unavailability of components with the qualifi-cation documentation necessary to satisfy the NRC Staff.

This situation exists despite the fact that these licen-sees have expended hundreds of man-years and tens of millions of dollars in an effort to meet the schedule and technical requirements imposed by CLI-80-21.

Major expenditures in this regard have included the preparation of extensive qualification analyses and reports, testing of components, replacement of components, and development of related pro-cedures.

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WI Wade lay 3on UNITED STATES OF AMERICA)ss DISTRICT OF COLUMBIA

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Subscribed and sworn to before me this 19th day of June, 1981.

C NS-.9,\\>]

My Comrdaden ":.xp'd O'eoSer K 1933 l

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UNIT?D STATES OF AMERICA

, NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION

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In the Matter of

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CLI-80-21, COMMISSION

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MEMORANDUM AND ORDER

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CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing " Petition For Extension Of Deadline For Compliance With CLI-80-21,"

in the above-captioned matter were se. ved upon the following persons by hand delivery this 22nd day of June 1981:

Chairman Joseph M..Hendrie Mr. Samuel J.

Chilk U.S. Nuclear Regulatory Secretary

-Commission U.S. Nuclear Regulatory Washington, D.C.

20555 Commission Washington, D.C.

20555 Commissioner John F. Ahearne U.S. Nuclear Regulatory Leonard Bickwit, Esq.

Commission General Counsel Washington, D.C.

20555 U.S. Nuclear Regulatory Commission Commissioner Peter A.

Bradford Washington, D.C.

20555 U.S. Nuclear Regulatory Commission Howard K.

Shapar, Esq.

Washington, D.C.

20555 Executive Legal Director U.S. Nuclear Regulatory Commissioner Victor Gilinsky Commission U.S. Nuclear Regulatory Washington, D.C.

20555 Commission Washington, D.C.

20555 Mr. Chase R. Stephens Docketing & Service Section U.S. Nuclear Regulatory Commission Washington, D.C.

20555 t

Nichold S'.

Reynolds Uv i

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