ML20002A141
| ML20002A141 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 10/31/1980 |
| From: | Counsil W CONNECTICUT YANKEE ATOMIC POWER CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20002A142 | List: |
| References | |
| AO1204, NUDOCS 8011040320 | |
| Download: ML20002A141 (8) | |
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Q CONNECTICUT YANKEE ATOMIC POWER COMPANY 1/
BERLIN. CO N N E C TIC U T P O SOR 270 M ARTFORD CONN ECTICUT 06101 tatecuous 203 666 6911 October 31, 1980 Docket No. 50-213 A01204 Mr. Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C.
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References:
(1)
D. G. Eisenhut letter to W. G. Counsil dated September 19, 1980, transmitting the Revised Order for Modification of License.
(2)
D. L. Ziemann letter to W. G. Counsil dated March 6,1980.
(3)
D. L. Ziemann letter to W. G. Counsil dated March 28, 1980.
Gentlemen:
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Haddam Neck Plant Environmental Qualification of Electrical Equipment By Reference (1), the NRC issued an Order and Modification of License, effective immediately, which requires Connecticut Yankee Atomic Power Company (CYAPCO) 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 completek responds to the Staf f's requests specified in References (2) and (3).
The purpose of this submittal is to satisfy the requirements of Reference (1),
in a timely fashion, by providing information regarding the environmental qualification status of safety-related electrical equipment in accordance with the Commission's guidance in this matter. It is recognized that total conformance to all of the applicable environmental qualification requirements is not provided for all safety-related electrical equipment subjected to harsh environments go /
resulting from a Loss-of-Coolant Accident (LOCA), a Main Steam Line Break 5
(MSLB) inside containment, or High Energy Line Breaks (HELB) inside and outside containment. However, there exists no evidence that'the equipment will fail to perform its design function or that public health and safety is compromised.
Where total qualification information is not incorporated into the attached report, justification for continued operation until total conformance can be achieved is provided. Justification for continued operation is founded on j
several considerations, some of which are generic, others unique to specific (D
components. Generic considerations are discussed on the following pages.
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_ - - - _ - - _ _. - O Component-specific justification is provided on equipment sumnary sheets in Appendix 11 of this report. Particular emphasis is directed towards the following bases and assumptions utilized in preparing the attached report.
J (1) Where available, qualification documentation for electrical equipment associated with TM1 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 i
installed is acceptable and is consistent with the re'quirements
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of I&E Bulletin No.79-01B, Supplement 3.
Qualification documenta-i tion is an integral part of post-TMI requirements and will be l
provided in accordance with lessons-learned requirements or other commitments previously made.
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(2) There are instances where safety-related electrical equipment will have performed and completed its safety function within the first several 4
seconds of the start of an accident. Recognition of this fact provides reasonable justification for continued operation until fully qualified replacements can be procured and installed. The NRC requirement for qualification 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 l
NRC on this matter subsequent to the initial publication of NUREG-0588.
Disposition of these comments would provide an appropriate vehicle for resolving the divergent points of view which now exist between the
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NRC Staf f and the industry.
(3) The development of the list of equipment requiring qualification included equipment required to achieve a cold shutdown condition. However, the fundamental objective of the program is to demonstrate that safe shutoown, 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-OlB, which was issued on February 29, 1980, and Supplement 3 which was issued on October 24, 1980. In addition, the ability to achieve a cold shutdown condition using safety-grade equipment was not a design requirement for the Haddam Neck Plant. It is CYAPCO's intention to provide additional information documenting environmental qualification of electrical equipment required for cold shutdown by I
February 1, 1981.
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i (4) In certain cases, justification for continued operation recognizes the existence of safety-related equipment which is redundant 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 och failures would occur simultaneously.
In many instances, the redundant equipment has significant physical separation which would introduce j
additional conservatism into the specification of environmental
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profiles. These conservatisms are in addition to those inherent in j
the profile development in that worst-case J41tial conditions and j
assumptions were utilized for those calcula. ions.
(5) The mention of electrical equipment in emergency operating procedures does not, of itself, necessitate qualification of such components in 1
accordance with all applicable NRC requirements. The emergency operating l
procedures were not developed by considering safety-related components to the exclusion of all others. Although safety-related equipment is 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 l
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 O
the Appendix of System Component Evaluation Work Sheets (SCEWS) and the l
associated justifications 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 l
rather than pure borated water. A preliminary engineering evaluation q
suggests that this difference is not significant, and is, therefore,
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not considered to be grounds for disqualification at this time. The fact that the containment spray system is not an automatically initiated engineered safety feature and is not credited in any accident analysis further supports the reasonableness of this position.
(7) Although the qualification requirements address a design life of 40 years, it is emphasized that the equipment currently in service is typically only 10 - 15 years old, and in some cases, is much newer. This provides additional assurance of its ability to function as required.
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(8) Although many components were installed prior to the qualification requirements 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 requirement for fully qualified equipment by June 30, L982.
(9) In all instances where 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 safety is compromised.
Consideration of a historical summary of this issue provides additional in-sight into understanding the difficulties encountered by CYAPCO in addressing this concern to the satisfaction of the Staff with optimum utilization of limited resources. Issuance of new criteria during the latter stages of this segment of the qualification program has impeded its resolution.
The environmental qualification of electrical equipment was examined several years ago during the initial phase of the Systematic Evaluation Program (SEP).
A CYAPCO summary of these efforts is detailed in the D. C. Switzer letter to V. Stello, Jr., dated March 6, 1978. In that document, CYAPC0 addressed the issue of environmental qualification of electrical equipment both inside and outside containment. Regarding equipment outside containment, the NRC Staff, in its SER dated July 14, 1977, concluded that the " proposed systems of f"')
barriers, restraints, and encapsulation sleeves provide an acceptable basis (s /
for satisfying the applicable requirements of NRC General Design Criterion No. 4... ". Based in part on this Staf f position, CYAPCO concluded that the ability of electrical equipment located outside containment to withstand the limiting environmental condition had been assessed previously by CYAPCO and the NRC Staff and found to be acceptable.
Regarding equipment inside containment, CYAPCO addressed both the MSLB and the LOCA (the latter being the limiting case) and concluded that necessary electrical equipment inside containment would perform its safety function under the postulated limiting environmental conditions for the events analyzed.
The Staff's conclusions regarding their review of the environmental qualification issue for SEP plants was published in NUREG-0458, Short-Term Safety Assessment on the Environmental Qualification of Safety-Related Electrical Equipment of SEP Operating Reactors, dated May,1978. The significant conclusions were delineated as follows-l
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No significant safety deficiencies requiring Lamediate remedial actions were identified in the assessment of the eleven SEP plants.
2.
The results of the Staff's safety assessment of the eleven SEP plants has not changed the Staff's basis and conclusions in NUREG-0413.
3.
The changing and upgrading of older plants is a continual process.
While this process is not part of a comprehensive program, it has provided and continues to provide additional assurance that safety-related equipment will perform its function when required."
Item 3 above is of particular relevance as it acknowledges that the older operating nuclear plants do not necessarily fully conform to design criteria, such as those associated with environmental qualification, which were not in existence at the time these facilities were designed and constructed. Furthermore, the Staff stated that no deficiencies requiring immediate remedial action were identified.
The adequacy of the initial review of environmentai qualification, at least for an interim period, was again strongly inferred by statements published by the NRC in I&E Bulletin No. 79-01.
The February 8, 1979 letter f rom B. H. Grier to W. G. Counsil specifically exempted the SEP plants from this Bulletin, and stated:
"This Bulletin is also being sent for information to the 11 SEP plants... No action or written response is required..."
Os CYAPCO followed this guidance and did not initiate a reevaluation at that t ime,
even though it was apparent that the scope and level of detail associated with the Bulletin review exceeded the review conducted in response to the V. Stello, Jr., letter to D. C. Switzer dated December 23, 1977. Such differences were judged to be consistent with the philosophy promulgated by the NRC Staff at tha t time, in that specific acceptance criteria and groundrules unique to the SEP plants would be developed and utilized.
CYAPCO representatives, along with representatives from the other SEP plants, were requested to and did attend a meeting with the Staff in Bethesda to discuss this matter on February 21, 1980. Reference was made during the meeting to a February 15, 1980 letter which had not been received by CYAPCO by the meeting date.
During the meeting, the SEP Owners' Group stated its objection to the inference that the SEP utilities had not been reaponsive. It was noted that the absence of Staff comments or questions in response to the December 23, 1977 letter, along with directives provided in the 79-01 Bulletin series, provided evidence that the Staff had satisfactorily resolved this issue.
1 O in renen e te Staff ree irement. cvirco enen ems rxed un n eemerene 1 e qualification effort to assemble the requested information, support the audit 1
activities of the Staff and its consultants, and to support the Staff 's schedule.
Section A of the attached report discusses the numerous and significant changes in NRC requirements which have occurred during the past nine months. It is unfortunate that such changes have continued to occur even during the final stages of preparation of this submittal. The issuance of Supplement 3 to I&E Bulletin No. 79-OlB 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 i
qualification documentation would constitute indisputable conformance with Reference (1).
One example of the difficulties encountered with changing criteria concerns the calculations for radiation service conditions. Staff requirements regarding the 4
4 calculations for radiation qualification requirements differ as a function of the guidance document being utilized. By letter dated April 11, 1980, CYAPCO identified this conflict in radiation qualification requirements between Item 2.1.6b of the j
lessons-learned documentation and Enclosure 1 to the February 15, 1980 letter,
" Guidelines for Evaluating Environmental Qualification of Class lE Electrical Equipment in Operating Reactors". In the April 11 letter, CYAPC0 advised the Staff that it had resolved this conflict by deciding to utilize the February 15 guidance. The basis for this decision was founded on the premise that this 1
I guidance was developed exclusively for the SEP plants, thereby superseding l
generically issued guidance.
By letter dated September 30, 1980, the Office of Inspection and Enforcement issued Supplement 2 to I&E Bulletin No. 79-OlB. The response to Question 18 indicated that the Staff had concluded that CYAPCO's decision of April 11 was incorrect. The Staff must recognize that such changes in groundrules could not be accommodated so far into the program. The radiation source terms calculated by CYAPCO are already extremely conservative and serve as an appropriate i
I basis for this facet of the qualification program. The fact that this is the i
first Supplement to the 79-01 Bulletin series forwarded to CYAPCO as applicable to the Haddam Neck Plant is further justification for not complying with the provisions of the response to Question 18 at this time.
CYAPCO 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 environmental will, I
in fact, do so.
The absence of full and complete compliance to the Staff requirements is judged to be acceptable, as in these instances, justification is provided for continued operation. Where appropriate, commitments have been made to complete a i
replacement program as soon as practicable before June 30, 1982, assuming procure-ment delays do not prohibit replacement by this date.
In the May 23, 1980 Menorandum and Order, the Commission stated that:
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e believe that current Consnission requirements in.
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environment qualification areas and those actions 7 order today provide reasonable assurance that the public healh and safety is being adequately protected during the time ner.essary for corrective action."
Very substantial progress towards total equipment qualification documentation has j
been made by CYAPCO since the date of issuance of this Order, which further I
supports the reasonableness and appropriateness of the Commission's determination that public health and safety is being adequately protected.
In summary, in accordance with Cotmission requirements, it is cYAPCO'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 Electrical Equipment - Haddam Neck Plant", as clarified and supplemented by the above information, CYAPCO concludes that a full and complete response to Reference (1) is hereby provided.
Very truly yours, CONNECTICUT YANKEE ATOMIC POWER C ANY O
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W. G. Counsil Senior Vice President Attachment l
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COUNTY OF HRTFORD Then personally appeared before me W. C. Counsil, whc being duly sworn, did state that he is Senior Vice President 7f Connecticut Yankee Atomic Power 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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