ML20028G339

Safety Evaluation of Environ Qualification of safety-related Electrical Equipment.Continued Operation Will Not Present Undue Risk to Public Health & Safety

ML20028G339
Person / Time
Site:	Arkansas Nuclear
Issue date:	01/26/1983
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20028G335	List: ML20028G334 ML20028G339
References
NUDOCS 8302080438
Download: ML20028G339 (6)

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4y SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION it I

l ARKA*lSAS POWER AND LIGHT C0!1PANY l

ARKANSAS NUCLEAR ONE, UNIT NO. 1 i

j DOCKET !!O. E0-313 4

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ENVIRONMENTAL QUALIFICATION OF SAFETY-RELATED ELECTRIC EQUIPMENT INTRODUCTION r

General Design Criteria 1 and 4 specify that safety-related electrical i4 equipment in nuclear facilities must be capable of performing its safety-related function under environmental conditions associated with all ll normal, abnormal, and accident plant operation.

In order to ensure compliance with the criteria, the NRC staff required all licensees of 1

operating, reactors to submit a re-evaluation of the qualification 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) l j.

issued to all licensees of operating plants (except those included in the systematic evaluation program (SEP)) IE Bulletin (IEB) 79-01, " Environ-i

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._ mental Qualification of Class IE Equipment." This Bulletin, together with IE Circular 78-08 (issued on May 31, 1978),. required the licensees j

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to perform reviews to assess the adequacy of their environmental qualifica-tion programs.

i On January 14, 1980, NRC issued IE Bulletin 79-018 which included the

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00R guidelines and NUREG-0588 as attachments 4 and 5, respectively.

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Subsequently, on May 23, 1980, Commission Memorandum and Order CLI-80-21 b

ji was issued and stated the 00R guidelines and portions of NUREG-0588 form p

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'l the requirements that licensees must meet regarding environmental d.

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J qualification of safety-related electrical equipment in order to satisfy lj tnose aspects of 10 CFR 50, Appendix A, General Design Criterion (GDC) 4.

Q Supplements to IEB 79-018 were issued for further clarification and iiq definition of the staff's needs. These supplements were issued on h~

February 29, September 30, and October 24, 1980.

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In addition, the staff issued orders dated August 29, 1980 (amended in September 1980) and October 24, 1980 to all lic.ensees. The August order iij required that the licensees provide a report, by Nownber 1,1980, docu-U menting the qualification of safety-related electrical equipment. The d

ll October order required the establishment of a central file location for

-iy the maintenance of all equipment qualification. records. The. central i

file was mandated to be~ established by December 1, 1980. The staff subsequently issued Safety Evaluation Reports (SERs) on enviromental o

l qualification of safety-related e)ectrical equipment to licensees of 1

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all operating pl, ants in mid-1981. These SERs directed licensees to l-

"either provide documentation of the missing qualification s.aformation which demonstrates that safety-related equipment meets the DOR Guide-lines or NUREG-0588 requirements or commit to a corrective action (re qualification, replacement (etc.))." Licenseas were required to

tii respond to NRC within 90 days of receipt of the SER.

In response to

O the staff SER issued June 16, 1981, the licensee submitted additional jj i-information regarding the qualification of safety-related electrical equipment.

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EVALUATION

[1 The acceptability of the licensee's equipment environmental qualification I!

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program was resolved for the Division of Engineering by the Franklin

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!.I Research Center (FRC) as part of the NRR Technical Assistance Program

t r -;upport of NRC operating reactor licensing actions. The consultant's I

review i.t documented in the report " Review of Licensees' Resolutions of

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Outstanding Issues from NRC Equipment Environmental Qualification Safety

'd Evaluation Reports," which is attached.

1 We have reviewed the evaluation performed by our consultant contained in the enclosed Technical Evaluation Report (TER)'and concur with its bases I

j and findings.

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The staff has alu reviewed the licensee's justification for continued 1

, [f operation regarding each item of safety-related electrical equipment l,

identified by the licensee.as not being :apable of meeting environmental

'I lh qualification requir*ments for the service conditions intended.

Il; CONCLUSIONS "1

4 Based on the staff's review of the enclosed Technical Evaluation Report and the licerjsee's justification for continued operation, the folle.[ing i4 i

conclusions are made regarding the qualification of safety-related elec-I trical equipment.

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l Contined operation until completion of the licensee's environmental I i

!g qualification program has been determined to not present undue risk i$

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to the public health and safety. Furthermore, the staff is continuing to review the licensee's environmental qualification program.

If any 2

additional qualification deficiencies were identified during the course of this review, the licensee would be required to reverify the justifi-

{j cation 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 r!jj the public health and safety.

In this regard, it is requested that 1

the licensee do the following:

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 ifcensee are

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'i summarized below:-

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Submission of information within thirty (30) days for items

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in NRC categories 18, 2A and 2B for which justification for 5]

continued operation was not previously submitted to NRC or FRCy l}

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o Resolution of deficiencies associated with Equipment Items 4i!'

28, 29, 32, 33, 34, 35, 36, 40, 109 and 110 which have i,,

been assigned to NRC Category II.B (Equipment Not Qualified),

o Resolution of the concerns identified in Section 4.3.1 of j

the FRC TER regarding the completeness of the safety-related equipment list,

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Resolution of the concern identified in Section 4.3.2 of the FRC TER regarding the Containment Spray System, t.

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o Resolution of the concern identified in Section 4.3.3.1 of i

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The FRC TER regarding environmental service conditions. The i:

i staff hss reviewed this concern and concludes that the con-tainment temperature / pressure profiles for the worst case LOCA given in Figures'14-61 and 14-62 of the FSAR, are acceptable for use in equipment qualification.

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o Resolution of the staff concern (Section 4.3.3.3 of the i

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j FRC TER) regarding the treatment of beta radation doses.

I The staff position on beta radiation is' that only eval-l uations of equipment or cables which are placed in or surrounded by shielding could take ' credit for beta 4

dose reduction. Any equipment.or exposed cables j

should be qualified to the calculat.ed maximum beta l.

+ gamma dose inside containment.

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l The licensee must provide the plans for qualification or replacement of i

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l the unqualified equipment and the schedule for accomplishing its proposed correction action in accordance with 10 CFR,50.49.

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PROPRIETARY REVIEW Enclosed in the FRC Technical Evaluation Report (TER) are certain identi-fied pages on which the information is claimed to be proprietary.

h During the preparation of the enclosed TER, FRC used test reports and

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other documents supplied by the licensee that included material claimed j

l' to be proprietary by their owners and originators. NRC is now preparing 9

to publicly release the FRC TER and it is incumbent on the agency to

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seek review of all claimed proprietary material. As such, the licensee U

i is requested to review the enclosed TER with their owner or originator e

r-i and notify NRR within seven (7) days of receipt of this SER whether i

j any portions of the identified pages still require proprietary j

protection.

If so, the licensee must clearly identify this infor-mation and the specific rationale and justification for the protection

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t from public disclosure, detailed in a written response within twenty l

t q (20). days of receipt of this SER. The level of specificity necessary i

1lj for such continued protection should be consistent with the criteria

.t ll enumerated in 10 CFR 2.790(b) of the Commission's regulations.

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