ML20041D753
| ML20041D753 | |
| Person / Time | |
|---|---|
| Issue date: | 02/04/1982 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| TASK-PII, TASK-SE SECY-82-051, SECY-82-51, NUDOCS 8203090112 | |
| Download: ML20041D753 (11) | |
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February 4,1982 SECY-82-51 (Information)
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For:
The Commission L*
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From:
William J. Dircks 6
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Executive Director for Operations
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Subject:
STAFF REQUIREMENTS - SECY-81-6038 - PROPOSED RUL
" ENVIRONMENTAL QUALIFICATION OF ELECTRIC EQUIPMENT FOR NUCLEAR POWER PLANTS"
Purpose:
To respond to the January 8,1982 memorandum from S. Chilk requesting the staff to provide specific information to the Commission.
Discussion: The following information is provided in the order requested:
a.
Response to the Commission's request for a list of those power plants which have, and which have not, provided adequate justification for continued operation.
In 1981, the staff prepared and provided to each licensee of an operating nuclear reactor a safety evaluation report I
identifying equipment whose qualification program did not provide sufficient assurance that the equipment is capable I
of performing its design function in harsh environments and providing the staff's position relating to any identi-fied deficiencies.
The staff requested under the pro-visions of 10 CFR 50.54(f), that the licensee review the deficiencies enumerated and the ramification thereof to determine whether safe operation of the facility would be impacted in consideration of the deficiencies. After a preliminary review of the SER and due consideration of the deficiencies each licensee provided a ten-day response indicating that continued safe operation would not be adversely affected. As a part of the licensee's detailed
Contact:
W. Johnston, NRR l
X27331 1
i The Commission review of the SER they were to resolve identified deficiencies by providing within 90 days of receipt of the SER (1) documentation of missing qualification information which demonstrates that such equipment meets the D0R guidelines or NUREG-0588, or (2) commit to a corrective action (requalification, replacement, relo-cation, etc.) consistent with the requirements to establish qualification by June 30, 1982.
The SER also established the requirement that if option (2) was to be used that the licensee must provide justifi-cation for operation until such corrective action is compl ete. All licensees (72)providedtherequjred 90 day responses and all adopted option 2.
The staff has completed an initial review of these sub-mittals to determine if the licensee's submittal is responsive to deficiencies identified in the SER and the adequacy of the justificatior for continued operation during the interim period ne essary to complete the documentation and to implement corrective actions.
One component of tne staff evaluation was provided by the Franklin Research Center.
The review criteria used by FRC (Appendix A) was approved by the staff.
Another component of the evaluation was provided by the project manager for each facility. The project manager assessed the FRC review to ensure that all pertinent docu-ments had been reviewed and that the conclusion reached by FRC was consistent and acceptable.
In addition, the PM reviewed and audited the licensee's submittal to establish the adequacy of the justification. The decision of the project manager was reviewed by the cognizant DL Branch Chief. We have determined on the basis of our evaluation that 54 operating reactors (listed in Appendix B) can be categorized as having provided adequate justification for continued operation.
We have also determined that some submittals, while pro-viding general statements regarding continued safe operation, must be either supplemented with additional justification addressing the deficiencies identified in the SER or reviewed in greater detail to identify the justification.
On the basis of our evaluation thus far, we have categorized 18 operating reactors (listed in Appendix C) as requiring either supplements to their submitted justification or further staff review.
Th3 Comission For those plants listed in Appendix C, additional action on the part of the licensee and staff is required.
Meetings will be held with each licensee to identify the necessary action required by the licensee to (1) supplement the justification for continued operation provided in his submittals thus far, or (2) to convince the staff that adequate justification is already contained in his submittal.
This upgrading action is to be completed by February 28, 1982.
Following the upgrading effort, licensees for which a positive finding cannot be made for the adequacy of the justification for continued operation would be issued an Order to Show Cause to establish a basis for continued operation.
b.
Response to the Comission's request to describe under what circumstances licensees are obligated to report to the NRC when equipment fails a qualification test.
A licensee would only be obligated to report equipment qualification test failures to the NRC if those tests represented installed equipment in his licensed facility and such failures ~would res61t fFsafety system inopera-bility against the requirements of the Technical
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Specifications. The licensee's normal safety assessment procedures should govern this situation.
As implied by the Comission's question, there are no reporting requirements per se for equipment that fails qualification tests. We do not consider such requirements necessary since such information would not require further action unless the tests represented installed equipment.
It is presumed that a licensee would not knowingly attempt to install equipment in a facility that has failed a test and, therefore, could not be considered qualified.
- Further, when equipment fails a test, that equipment is usually modified or redesigned until it does pass the qualification tests.
Part 21 is only applicable to equipment defined as basic components that have been " dedicated" or " delivered" to a purchaser for use in a nuclear facility and that have a defect that could cause a substantial safety hazard. All of these conditions must exist to be reportable (see Part 21.3(a) and (d) and NUREG-0302, Rev.1).
Equipment under test or equipment represented by a test would generally not be purchased or dedicated by a buyer until those tests were successfully completed.
c.
Response to the Comission's request for an information paper on the capability of power reactors to achieve cold shutdown and the specific equipment required.
An information paper being prepared to address this item is scheduled for completion by Marcn 1,1982.
The Commission.
d.
Response to Commission's request to provide information on enforcement actions NRC should take if equipment is not properly qualified for any reason.
A response to this request was made on January 22, 1982 as SECY-82-31.
e.
Response to Commission's request for a staff proposed plan for equipment qualification, including seismic qualification of equipment in operating plants and the utilization of the resolution of USI A-46.
This plan is being submitted as a separate SECY paper; Willi n'J. Dircks Executive Director for Operations
Enclosures:
1.
Appendix A--review criteria 2.
Appendix B--list of plants having provided adequate justification 3.
Appendix C--list of plants requiring further justifi-cation or staff review DISTRIBUTION Commissioners Commission Staff Offices ACRS Secretariat O
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ENCLOSURE 1 l
APPENDIX A CRITERIA USED FOR THE REVIEW Justification for Interim Operation Criteria FRC will provide independent technical assessments of Licensee-submitted justification for interim operation. Where the Licensee's justification is based upon engineering judgment, FRC will provide an independent technical judgment as an additional input from which the NRC can take appropriate action.
In general, justification for interim operations can be categorized as follows:
1.
Redundant equipment is available to substitute for the unqualified equipment.
2.
Another system is capable of providing the required function of the system with unqualified equipment.
3.
The unqualified equipment will have performed its safety function prior to failure.
4.
The plant can be safely shut down in the absence of the unqualified equi pment.
Redundant Equipment:
Backup equipment must be:
1.
Comparable (i.e., characteristics) 2.
Qualified for environment of the accident 3.
Not susceptible to disabling single active failure Backup System:
- Replacement system must perform the essential function of the equipment that has failed.
There must be no loss in reliability (safety class, seismic, etc.).
i The essential function must be performed in spite of possible single l
active failure.
There must be no unacceptable consequences resulting from use of the backup system (e.g., causes unacceptable release of radioactivity to the surrounding environment, etc.).
Function Is Performed Prior to Failure:
Qualification of equipment to remain functional for specified period of time must be based on objective evidence (e.g., testing) or on reasonable engineering judgment.
- Basis for the specific operating time requirement must be substantiated.
Failure of equipment must not mislead the operator or cause adverse impact on other safety-related equipment, components, or power supplies.
Plant Can Be Safely Shut Down:
(Evaluation will include a combination of the above categories.)
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1 ENCLOSURE 2
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APPENDIX B Docket No.
Utili ty Plant 50-348, 364 Alabama Power Company Joseph M. Farley Units 1 and 2 50-261 Carolina Power & Light Co.
H. B. Robinson Unit 2 50-237, 249 Commonwealth Edison Company Dresden Units 1 and 2 50-254, 265 Commonwealth Edison Company Quad Cities Units 1 and 2 50-295, 304 Commonweath Edison Company Zion Units 1 and 2 50-213 Connecticut Yankee Atomic Power Haddam Neck 50-247 Consolidated Edison Company, Inc.
Indian Point Unit 2 50-409 Dairyland Power Cooperative Lacrosse 50-369 Duke Power Company McGuire Unit 1 50-334 Duquesne Light Company Beaver Valley Unit 1 50-302 Florida Power Corporation Crystal River Unit 3 50-335 Florida Power & Light Co.
St. Lucie Unit 1 50-250, 251 Florida Power & Light Co.
Turkey Point Units 3 and 4 50-321, 366 Georgia Power Company E. I. Hatch Units 1 and 2 50-315, 316 Indiana & Michigan Electric Co.
D. C. Cook Units 1 and 2 50-331 Iowa Electric Light & Power Co.
Quane Arnold 50-219 Jersey Central Power & Light Co.
Oyster Creek 50-289 Metropolitan Edison Company Three Mile Island Unit 1 50-298 Nebraska Public Power District Cooper 50-220 Niagara Mohawk Power Corporation Nine Mile Point Unit 1 50-245, 336 Northeast Nuclear Energy Co.
Millstone Units 1 and 2 50-263 Northern States Power Company Monticello 50-282, 306 Northern States Power Company Prairie Island Units 1 and 2 50-285 Omaha Public Power District Ft. Calhoun 50-344 Portland General Electric Co.
Trojan 50-333 Power Authority of the State of FitzPatrick New York 50-286 Power Authority of the State of Indian Point Unit 3 New York 50-272, 311 Public Service Electric & Gas Co.
Salem Units 1 and 2 50-267 Public Service Co. cf Colorado Ft. St. Vrain 50-244 Rochester Gas & Electric Co.
R. E. Ginna 50-312 Sacramento Municipal Utility Rancho Seco District 50-259, 260, 296 Tennessee Valley Authority Browns Ferry Units 1, 2 and 3 l
50-327, 328 Tennessee Valley Authority Sequoyah Units 1 and 2 50-346 The Toledo Edison Co.
Davis-Besse Unit 1 50-338, 339 Virginia Electric & Power Co.
North Anna Units 1 and 2 l
50-280, 281 Virginia Electric & Power Co.
Surry Units 1 and 2 50-266. 301 Wisconsin Electric Power Co.
Pt. Beach Units 1 and 2 50-29 Yankee Atomic Electric Co.
Yankee Rowe I
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ENCLOSURE 3 1
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APPENDIX C 50-313, 368 Arkansas Power & Light Co.
Arkansas Units i and 2 50-317, 318 Baltimore Gas & Electric Co.
Calvert Cliffs Units 1 and 2 50-293 Boston Edison Company Pilgrim Unit 1 50-325, 324 Carolina Power & Light Company Brunswick Units 1 and 2 50-155 Consumers Power Company Big Rock Point 50-255 Consumers Power Company Palisades 50-269, 270, 287 Duke Power Company Oconee Units 1, 2 and 3 50-309 Maine Yankee Atomic Power Co.
Maine Yankee 50-27/, 278 Philadelphia Electric Co.
Peach Bottom Units 1 and 2 50-206 Southern California Edison Co.
San Onofre Unit 1 50-271 Vermont Yankee Nuclear Power Vermont Yankee Corp.
50-305 Wisconsin Public Service Corp.
Kewaunee e
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NUCLEAR REGULATORY COMMISSION i
WASHINGTON, D. C. 20665 l'
OFFICE OF THE t
SECRETARY NOTE TO: Mike Collins FROM:
Tom Combs Attached are copies of correspondence to be entered in the DCS and placed in the PDR.
An advance copy has already been sent to the PDR.
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