ML20028G317
| ML20028G317 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 12/30/1982 |
| From: | Felton J NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | Wetterhahn M CONNER & WETTERHAHN |
| Shared Package | |
| ML20027A898 | List: |
| References | |
| FOIA-82-544 NUDOCS 8302080063 | |
| Download: ML20028G317 (1) | |
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UNITED STATES
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NUCLEAR REGULATORY COYMISSION r
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- e December 30, 1982 Docket No. 50-220 Mark J. Wetterhahn, Esquire Conner & Wetterhahn, P.C.
1747 Pennsylvania Avenue, N.W.
IN RESPONSE REFER Washington, DC 20006 TO F01A-82-544
Dear Mr. Wetterhahn:
This is in response to your letter dated November 5,1982, in which-you requested, pursuant to the Fraedom cf Information Act, a copy of the non-proprietary version of "Technica1' Evaluation Report (TER), Review of-Licensees' Resolution of Outstanding Issues from NRC Equipment Environmental Qualification Safety Evaluation Reports, Niagara Mohawk Power Corporation, Nine Mile Point Unit 1", prepared by Franklin Research Center.
In a telephone conversation with Carol Ann Reed, of my staff, on November 29, 1982, you agreed to wait until the Safety Evalual. ion Report (SER) for Ni'ie Mile Point was publisned.
'.nclosed is a copy of the SER and TER.
This completes action on your request.
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J. M. Felton, Director
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Division of Rules and Records
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December 20, 1982 Docket No. 50-220 Mr. G. K. Rhode Senior Vice President Niagara Mohawk Power Corporation 300 Erie Boulevard West Syracuse, NY 13202
Dear Mr. Rhode:
SUBJECT:
SAFETY EVALUATION FOR ENVIRONMENTAL QUALIFICATION OF SAFETY-RELATED ELECTRICAL EQUIPMENT Re:
Nine Mile Point Nuclear Station, Unit No. 1 This letter transmits the Safety Evaluation for the Environmental Qualification of Safety-Related Electrical Equipment at your facility. This evaluation is based on your response to our previous Safety Evaluation Report, dated June 8, 1981, and subsequent submittals dated September 8,1981, February 2, and March 2, 1982.
This Safety Evaluation presents the results of the Environmental Qualification Review for safety-related electrical equipment, exposed to a
_ harsh environment, in accordance with NRC requirements. We request that you provide your plans for qualification or replacement of any of the equipment in NRC categories I.b, II.a and II.b (presented in the Technical Evaluation Report) and the schedule for accomplishing your_ proposed corrective actions to us within ninety (90) days of the receipt of this letter.
As indicated in the conclusion section of the Safety Evaluation, we request that you reaffirm the justification for coatinued operation and within thirty (30) days of receipt of this letter, submit infomation for any items in NRC categories I.b, II.a and II.b (presented in the enclosed Technical Evaluation Report) for which justification for continued operation was not previously submitted to the NRC.
We suggest that the clarification set forth in Item 8 of Generic Letter No. 82-09, " Clarification Questions and Answers on Environ-mental Qualification Requirements," should be considered in your justification for continued operation.
The Technical Evaluation Report contains certain identified infomation which you have previously claimed to be proprietary. We request that you inform us as indicated in the proprietary section of the Safety Evaluation whether any,-'
portions of the identified pages still require proprietary protection.
i At your option, the staff will be available to discuss the findings in the Safety Evaluation as augmented by the Technical Evaluation Report. Questions regarding this letter should be directed through the NRC Project Manager for your plant.
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.The reporting and/or recordkeeping requirements contained in this letter 4
affect fewer than ten respondents; therefore, OMB clearance is not required under P.L.96-511.
Sincerely, Domenic B. Vassallo, Chief Operating Reactors Branch #2 Division of Licensing
Enclosures:
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Safety Evaluation 2.
Technical Evaluation Report cc w/o TER 4
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Mr. G. K. Rh' ode Niagara Mohawk Pcwer Corporation John W. Keib, Esquire Niagara Hohhwk Power Corporation cc:
300 Erie Boulevard West
.T.roy B.., Conner, Jr..Esq.
Syracuse, New York 13202 Conner & Wetterhahn Suite 1050 1747 Pennsylvania Ave., NW i
Washington, D.C.
20006 Di rector, Ronald C. Haynes Technological Development Programs Regional Administrator, Region I State of New York U.S. Nuclear Regulatory Commission Energy Office 631 Park Avenue Swan Street Building King of Prussia, PA 19406 CORE 1 - Second Floor Enpire State. Plaza Albany, New York 12223 Mr. Robert P. Jones, Supervisor Tocen of Scriba R. D. #4 Oswego, New York 13126 Niagara Mohawk Power Corporation ATTN: fir. Thomas Perkins Plant Superint ndent Nine Mile Point Nuclear Station P.O. Box 32 Lycoming, New York 13093 U.S. Environmental Protection Agency Region II Office Regional Radiation Representative 26 Federal Plaza 1
1 Resident Inspector i'^
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION NIAGARA M0 HAWK POWER CORPORATION NINE MILE POINT NUCLEAR STATION, UNIT NO. 1 DOCKET NO. 50-220 ENVIRONMENTAL QUALIFICATION OF SAFETY-RELATED ELECTRIC EQUIPMENT INTRODUCTION General Design Criteria 1 and 4 specify that safety-related electrical equipment in nuclear facilities must be capable of performing its safety-related function under~ environmental conditio,ns associated with all normal, abnormai, and accident plant operatios." Tn order to' ensure compliance with the criteria, the NRC. staff required all licensees of operating reactors to submit a re evaluation of the qualifi, cation of safety-related electrical equipment which may be exposed to a harsh
' environment.
BACKGROUND On February 8, 1979, the NRC Office of Inspection and Enforcement (IE) issued to all lic'ensees of operating plants (except those included in the systematic evaluation program (SEP)) IE Bulletin (IEB) 79-01, " Environ-mental Qualification of Class IE Equipment." This Bulletin, together with IE Circular 78-08 (issued on May 31,1978), required the licensees to perform reviews to assess the adequacy of their environmental qualifica-tion programs.
f On January 14, 1980, NRC issued IE Bulletin 79-01B which includtd the 00R guidelines and NUREG-0588 as attachments 4 and 5, respectively.
) Y Subsequently, on May 23, 1980, Commission Memorandum and Order CLI-80-21 t
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S was issued and stated the DDR guidelines and portions of NUREG-0588 fom 0) the requirements that licensees must meet regarding environmental
qualification of safety-related electrical equipment in order to satisfy those aspects of 10 CFR 50, Appendix A, General Design Criterion (GDC) 4.
Supplements to IEB 79-01B were issued for further clarification and definition of the staff's needs.
These su;_plements were issued on February 29, September 30, and October 24, 1980.
In addition, the staff issued orders dated August 29, 1980 (amended in September 1980) and October 24, 1980 to all licensees.
The ugust order required that the licensees provide a report, by November 1,.1980, docu-menting the qualification of safety-related electrical equipment. The
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October order required the establishment of a central file location for the maintenance of all equipment qualification records.. The central file was mandated to be established by December 1, 1980.
The staff subscquently issued Safety Evalu'ation Reports (SERs) on'enviromental qualification of safety-related electrical equipment to licensees of all operating plants in mid-1981.
These SERs directed licensees to "either provide documentation of the missing qualification information which demonstrates that safety-related equipment meets the D0R Guide'-
lines or NUREG-0588 requirements or connit to a corrective action (re qualification, replacement (etc.))."
Licensees were required to respond to NRC within 90 days of receipt of the SER.
In response to the staff SER issued June 8, 1981, the licensee submitted additional information regarding the qualification of safety-related electrical equipment.
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' - EVALUATION The acceptability of the licensee's equipment environmental qualification program was reviewed for the Division of Engineering by the Franklin Research Center (FRC) as part of the NRR Technical Assistance Program in support of NRC operating reactor licensing actions.
The consultant's review is documented in the report " Review of Licensees Resolutions of Outstanding Issues from NRC Equipment Environmental Qualificatidn Safety Evaluation Reports," which is attached.
We have reviewed the evaluation performed by our consul' tant contained in tr the enclosed Technical Evaluation Report (TER) and concur with its bases and findings.
Our review has also revealed certain discrepancies in the TER which are being corrected by this Safety Evaluation as follows:
o Delete the third paragraph on page 1-9 of the TER.
o Delete the second paragraph on page 1-10 of the TER.
The staff has also reviewed the licensee's justification for continued operation regarding each item of safety related electrical equipment identified by the licensee as not being capable of meeting environmental,
qualification requirements for the service conditions intended.
CONCLUSIONS Based on the staff's review of the er. closed Technical Evaluation Report and the licensee's justification for continued ope' ration, the following conclusions are made regarding the nuali'. ation of safety-related elec-l trical equipment.
Continued operation until completion of the licensee's environmental qualification program has been determined to not present undue rist h to the public health and safety.
Furthermore, the staff is contiiuing
' to review the licensee's environmental qualification program.
If any additional qualification deficiencies were identified during the course of this reviev, the licensee would be required to re-verify the justification for continued operation. The staff will review this information to ensure that continued operation until completion of the licensee's environmental qualification
- program will not present undue risk to the public health and safety.
The major qualification deficiencies that have been identified in the enclosed FRC TER (Tables 4-1, 4-2, 4-3, and 4-4) must be resolved by the licensee.
Items requiring special attention by the licensee are summarized below:
o Submission of information within thirty (30) days for any of the items in NRC categories I.a. II.a and II.b for which ' justification for continued operation was not previously submitted to NRC or FRC, Resolution of the concern regarding completeness of.the o
safety-related equipment list i.e., identification of safety-related systems and display instrumentation (See Section 4.3.1
't of the FRC TER).
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The_ licensee must provide the plans for qualification or rep'sacement of the unqualified equipment and the schedule for accomplishing its proposed i
correction' action.
PROPRIETARY REVIEW Enclosed in the FRC Technical Evaluation Report (TER) are certain identi-fied pages on which the information is claimed to be proprietary.
During the preparation of.the enclosed TER, FRC used test reports and other documents-supplied by the licensee that included material claimed to be proprietary by their owners and originators.
NRC is now preparing to publicly release the FRC TER and it is incumbent on the agency to seek review of all claimed proprietary material.
As such, the licensee is requested to review the enclosed TER with their owner or originator and notify NRR, within seven (7) days of receipt of this Safety Evaluation whether any portions of the identified pages still require proprietary protection.
If so, the licensee must clearly identify this information and the specific rationale and justification for the protection from public disclosure, detailed in a written response within twenty (20) days of receipt of the Safety Evaluation.
The level of specificity necessary for such continued protection should be consistent with the criteria enumerated in 10 CFR '2_.790(b) of the Commission's regulations.
Principal Contributors:
P. Shemanski Date:
DEC 2 01982 v-t
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