ML20003A719
| ML20003A719 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 01/30/1981 |
| From: | Sylvia B VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Harold Denton, Youngblood B Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19260G535 | List: |
| References | |
| RTR-NUREG-0588, RTR-NUREG-588 065, IEB-79-01B, IEB-79-1B, NUDOCS 8102050675 | |
| Download: ML20003A719 (4) | |
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A LA Mr. Harold R. Denton, Director Serial No. 065 Office of Nuclear Reactor Regulation N0/RGS:jmj Attn:
Mr. B. Joe Youngblood, Chief Docket No. 50-339 Licensing Branch 1 License No. NPF-7 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Sir:
NUREG-0588 (REVISION 3)
NORTH ANNA POWER STATION UNIT NO. 2 On October 24, 1980, we received Supplement No. 3 to IE Bulletin 79-01B,
" Environmental Qualification of Class 1E Equipment" on Cold Shutdown require-ments and TMI Action Plan equipment. IE Bulletin 79-01B applies to three (3) of our operating plants. Although Supplement No. 3 does not apply directly to North Anna Unit 2 (NUREG-0588) it is our feeling that the two issues raised by Supplement No. 3 should be addressed for North Anna Unit 2-Therefore, we have included for your review Revision 3 to our NUREG-0588 report which includes the subject information.
NRC Request
"(1) Supplement No. 2 (Q.1, Q.5) addressed the minimum cold shutdown require-ments. The staff position on this issue is that the licensee must identify and environmentally qualify the equipment needed.to complete one method (path) of achieving and maintaining a cold shutdown condition.
The equipment of other paths must be reviewed to assure that its failure will not aggravate or contribute to the accident (ref. Q.5 Supp. No. 2).
Due to an inconsistency between Supplement No. 1 and Supplement No. 2, the staff position on this issue was unclear. Therefore, the following will apply:
a.
The qualification information for equipment needed to achieve and maintain a Hot Safe Shutdown condition must be submitted not later than November 1, 1980.
b, The qualification information for equipment required to achieve and maintain a Cold Shutdown condition (ref. Q.1 and Q.5 of Supplement No. 2) must be submitted not later than February 1, 1981."
Response
(1)a.
In Vepco l'etter Serial No. 886 dated October 31, 1980, we submitted the the results of our review of NUREG-0588 Revision l'.
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visoimia nectmic awn Powen connwy to Mr. Harold R. Denton, Director 2
(1)b. In response to your request for a list of equipment required to achieve and maintain a Cold Shutdown condition, we have enclosed the requested information for your review. However, we must take exception to your request to provide the " qualification information" for this equipment.
The implication by statement (1)b that this equipment should meet the criteria established in IE Bulletin 79-01B for the environmental quali-fication of Class 1E electrical equipment is inappropriate. The equip-ment utilized to achieve a Cold Shutdown condition was not designated as Class 1E safety-related equipment in the design basis of the Surry and North Anna Unit 1 FSAR's. Further, North Anna Unit 2 was granted a full power license by the NRC on August 21, 1980, without indication f rom the NRC that the Hot Shutdown Condition was not a safe normal or abnormal mode of operation. We are aware that Supplement No. 3 to the Bulletin was issued on the same day (October 24, 1980) that an Order for Modification of License Concerning Environmental Qualification of Safety-Related Electrical Equipment was issued. The Order provides that all saf ety-related electrical equipment must be qualified to the DOR Guidelines or NUREG-0588 by June 30, 1982, therefore Supplement No. 3 is within the scope of the Order. In your letter of January 19, 1981 on the Cold Shutdown issue, you stated that "This Bulletin requirement was not intended to invoke a change in the licensing basis of the plant".
You indicated that " Regulatory Guide 1.139 contains the implementation plans for the cold shutdown requirements, of which E-Q is a part".
How-ever, Regulatory Guide 1.139 contains a backfit clause for plants docketed before January 1, 1978 by establishing the position that "All applications docket before January 1, 1978, will be reviewed against this guide on a case-by-case basis".
Based on this ambiguous position, we can only conclude that it is your intent to require that all Cold Shutdown condition and TMI Action Plan equipment be environmentally qualified by June 30, 1982. It appears that the NRC is considering back-fitting this new requirement, but the appropriate regulatory procedures have not been followed. Vepco has not been given opportunity for comment to the Bulletin requirements. To our knowledge the NRC has not developed a value impact assessment. It is our contention that a new requirement of this magnitude should not have been established by Supplements No. 2 and No. 3 of IE Bulletin 79-01B.
NRC Request
"(2)
IEB 79-OlB required a 90 day response which was due in mid-April 1980.
Supplement 1 (Feb. 57-80) informed licensees that equipment which was
" planned" to be installed as a result of lessons learned need not be addressed in that response. Some of this equipment has since been installed. Supplement No. 2 (Q.5, Q.21) identified that the staff posi-tion was that equipment which is installed should be treated in a manner similar to all other safety-related electrical equipment and be addressed in the November 1, 1980 submittal. This position represents no change in staff position regarding the scope of the review. However, since the staff position on this issue was unclear the following will apply:
a.
Qualification information for installed THI Action Plan equipment must be submitted by February 1, 1981.
o W ootw 4 Etreme amp Powsm Courrwr to Mr. Harold R. Denton, Director 3
b.
Qualification information for future TH1 Action Plan equipment (ref.
NUREG-0737, when issued), which requires NRC pre-implementation review, must be submitted with the pre-implementation review data.
Qualification information for TMI Action Plan equipment currently c.
under NRC review should be submitted as soon as possible.
d.
Qualification information for TM1 Action Plan equipment not yet installed which does not require pre-implementation review should be submitted to NRC for review by the implementation date."
Response
(2)a. In Vepco letter Serial No. 958 dated December 1,1980, we submitted the qualification information for installed TM1 Action Plan equipment.
(2)b. Qualification information for future TMI Action Plan equipment is provided for your review in the following supplement to the NUREG-0588 report:
s VIRGINIA ELECTRIC AND POWER COMPAhT NORTH ANNA POWER STATION UNIT 2 NUREG-0588 TMI REVIEW SUPPLEMENT 3 It is our intent to submit qualification information for THI Action Plan equipment which requires NEC pre-implementation review with the pre-imple-mentation review data.
(2)c. In Vepco letter Serial No. 957 dated December 1,1980, we submitted the qualification information for TM1 Action Plan equipment under NRC review.
(2)d. The qualification information for TMI Action Plan equipment that has not yet been installed which does not require pre-implementation re-view will be submitted to the NRC for review by the implementation date.
Revision 3 to the Report contains information which is proprietary to Westing-house. Accordingly we request that this report be withheld from public disclosure.
In order not to delay this submittal of information requested by the Commission, we will comply with the requirements of 10CFR2.790 to provide proprietary and non-proprietary versions together with an affidavit as soon as Westinghouse specifically identifies the proprietary information contained in the report and provides us with an affidavit. We will submit the total required number of copies of the proprietary and non proprietary versions of the report and the required affidavit at that time.
In the meantime, we have provided sufficient copies of the proprietary report for you to initiate your review. Westinghouse has advised us that this procedure has been discussed with Mr. E. Shoemaker of the NRC Executive Legal Department and that he concurs.
Vamourn Ex.acroe t.ca Po43 Courawy to Mr. H3rold R. Dent n, Dircctor 4
A copy of this submittal is being sent to Westinghouse requesting them to specifically identify the proprietary information and to supply the required affidavit. Westinghouse has advised us that they will be able to return the report and affidavit to us within a week of their receipt of the report.
If we can be of assistance in clarifying or interpreting information submitted with this response to the Bulletin, please advise.
Very truly yours,
,.g.
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B. R. ' Sylvia Manager - Nuclear Operations and Maintenance Fnclosures (2) cc:
Mr. Victor Stello, Director (Enclosures-16)
NRC Office of Inspection and Enforcement Division of Reactor Operations Inspection Washington, D.C.
20555 Mr. Zoltan R. Rosztoczy, Branch Chief (Enclosures-2)
NRC Equipment Qualification Branch Division of Engineering Washington, D.C.
20555
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