ML20062A602
| ML20062A602 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 07/28/1982 |
| From: | Schroeder C COMMONWEALTH EDISON CO. |
| To: | Schwencer A Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19262G716 | List: |
| References | |
| 4450N, NUDOCS 8208040055 | |
| Download: ML20062A602 (9) | |
Text
Os Commonwrith Edison i / On2 First N tion 11 Ptua. Chicago, Illinois v
Addrzss R ply to: Post Ofhca Box 767 x
Chicago. Ilknois 60690 Jul y 28, 1982 Mr.
A. Schwencer, Chie f Licensing Branch #2 Division of Licensing U. S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
LaSalle County Station Units 1 and 2 Environmental Qualification NRC Docket Nos. 50-373 and 50-374 Reference (a):
License NPF-11 dated April 17, 1982 Condition 2.C. (11).
(b):
E. D. Swartz letter to D. G. Eisenhut dated June 24, 1982.
(c):
10 CFR 50.49, Revised June 30, 1982.
(d):
Safety Evaluation Report for LaSalle County Station, Supplement 2, Appendix C.
(e):
C. W. Schroeder letter to A. Schwencer dated June 30, 1982.
Dear Mr. Schwencer:
The purpose of this letter is to summarize the status of environmental qualification requirements for LaSalle County Station and to provide you with a report of corrective actions and additional information.
Background Information Reference (a) states, in part, that:
(a)
No later than J;ne 30, 1982, the licensee shall be in compliance with the provisions o f NUREG 0588, " Interim Staf f Position on Environmental Qualification of Sa fety-Related Electrical Equipment", for safety-related electrical equipment exposed to a harsh enviroment.
(b)
Complete and auditable records must be available and maintained at a central location which describe the
%d 8 environmental qualification methods used for all safety-related electrical equipment in sufficient detail to M)' g/
document the degree of compliance with NUREG-0588.
Such records shall be updated and maintained current as Dah equipment is replaced, dTit further tested, or otherwise further MSl6 qualified to document complete compliance no later than June 30, 1982.
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A. Schwencer July 28, 1982 (c)
The licensee shall complete the corrective actions stipulated in Appendix C to Supplement No. 2 of the Safety 1
Evaluation Report by June 30, 1982.
Reference (b) was provided to summarize Commonwealth Edison Company's position for the completion of the requalification program for safety-related electrical equipment exposed to a harsh environment.
Our position is that we have provided our assessment to justify the interim operation of LaSalle County Station during the first two (2) fuel cycles to accomodate our proposed schedule for final equipment qualification.
A new 10 CFR 50.49 (Reference (c)) was published on June 30, 1982.
This states:
"The June 30, 1982, deadline for completion of environmental qualification of safety-related electric equipment, now contained in the technical specifications or license conditions for all operating nuclear power plants, is hereby suspended pending publication of the final rule on qualification of such equipment."
Status License Condition 2.C. (11). (a):
Commonwealth Edison Company is proceeding with requalification testing and equipment replacement on a schedule for completion within the first two fuel cycles at LaSalle.
License Condition 2.C. (ll). (b):
A central repository exists for HARSH equipment records at Commonwealth Edison's architect-engineer, Sargent & Lundy.
These records are updated as tests are completed or equipment is replaced.
Equipment record coverage has been complete since 1980 when the DDR appraisal was made for HARSH equip-ment.
Two NRC audits, in June and October,1981, focused attention to the method whereby the HARSH equipment binders would be kept l
current.
These HARSH binders are distributed and controlled as an engineering document under Q.A. procedures.
Transfer of these EQ records to the central records file at LaSalle from the central repository is done upon total completion of the qualification for each HARSH line item.
To date, all SQRT qualification records and over 40 percent of the HARSH EQ binders have been transferred to the station.
License Condition 2.C. (11). (c):
Commonwealth Edison Company has prepared a "Ninety Day Report, Revision 1, CQD 002311" dated June,
1982, which addresses the concerns expressed in Reference (d).
Specific status information is provided under the Tabs for each NRC categorical question indicated in SSER #2 Appendix C.
Commonwealth Edison believes this report provides the basis for closure of License Condition 2. c. (11). (c).
Reference (e) stated that this documentation would be provided by July 30, 1982.
This transmittal also fulfills that commitment.
A. Schwencer July 28,1982 Submittal Enclosed for your use are the original and four copies of this letter and five copies of the "Ninety Day Report, Revision 1, CQD 002311," dated June, 1982.
A proprietary report, QUAD-1-82-852 Volumes 1 and 2 is included as Tabs K and L o f this report.
This is included to explain the aenesis and morphology of the LaSalle HARSH equipment list and to record the L5CS " Justification for Interim Operation" through two fuel cycles.
The original and four copies of the affidavit for protection of this report from public disclosure is also provided.
Also enclosed are five copies of a draf t revision to Appendix M of the FSAR.
This information is provided as a status report on the progress of our overall qualification program.
Summary Commonwealth Edison Company is proceeding with the equipment qualification program for safety-related electrical equipment exposed to a harsh environment on a schedule with expected completion of requalification or replacement by the end of the second fuel cyc1rs.
Records are maintained and updated on an on-going basis at a central repository and are transferred to the LaSalle County Station Central File upon completion.
The corrective actions stipulated in Appendix C to Supplement No. 2 of the SER have been completed and are documented in the enclosed "Ninety Day Report."
To the best of my knowledge and belief the statements contained herein and in the enclosures are true and correct.
In some respects these statements are not based on my personal knowledge but upon information furnished by other Commonwealth Edison and contractor employees.
Such information has been reviewed in accordance with Company practice and I believe it to be reliable.
If there are any questions in this matter, please contact this office.
Very truly yours, Chdh 7]x/v1.
C. W. Schroeder Nuclear Licensing Administrator 1m l
l Enclosures l
cc:
NRC Resident Inspector - LSCS 1/0 l
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AFFIDAVIT I,
Thomas E. Watts, being duly sworn, depose and state the following:
1.
I am the LaSalle Project Engineer for Commonwealth Edison Company and have been delegated the function of reviewing the information described in paragraph 2 which is sought to be withheld and have been authorized to apply for its withholding.
2.
The information sought to be withheld consists o f:
Ta b K,
"LaSalle County Station Assessment to Justify Interim Operation," Volume I ( QU AD 81 -85 2), and Tab L, "LaSalle County Station Assessment to Justify Interim Operation," Volume II ( QUAD 81-85 2 ) Appendix F.
Both of these Proprietary Tabs are part of the Edison Company 's 90-Day Report EQ-LS-SER " Environmental Qualification o f Class IE Equipment" for LaSalle County Station, dated May 1982.
The S&L CQD Number is 00234.
3.
The designated material is characterized as proprietary and trade secrets as set forth in Section 757 of the American Law Institute Restatement of Torts, which provides:
" A trade secret may consist of any formula, pattern, device or compilation of information which is used in one's business and which gives him an opportunity to obtain and advantage over competitors who do not know or use it....
A substantial element o f secrecy must exist, so that except by the use of improper means, there would be dif ficulty in acquiring information....
Some factors to be considered in determining whether given information is one's trade secret are:
(1) the extent to which the information is known outside of his business; (2) the extent to which it is known by employees and others involved in his business; (3) the extent of measures taken by him to guard the secrecy of the information; (4) the value of the information to him and to his competitors; (5) the amount of effort or money expended by him in developing the information; (6) the ease or difficulty with which the information could be properly acquired or duplicated by others."
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. 4.
The designated material consists of a comprehensive BWR-5 systems safety analysis built upon the systems operational analysis contained in Appendix D to the LaSalle FSAR.
This comprehensive safety analysis utilizes a systems diagram of the BWR-type plant which incorporates all supporting equipment and services, all major safety components including a representation of redundancy and the logic dependency of plant reactions to initiating events.
This systems diagram references system conditions, safety objectives, and enroute events along process paths, isolation paths, and electrical signal or control paths.
The fulfillment of the six safety objectives from any transient or accident is systematically represented in this systems diagram.
This practical tool enables the repetitive consideration of each transient or accident event with accompanying malfunctions in the safety equipment or in the supporting equipment.
Sequential or coincident initiating events can be considered such that a hierarchy of event severity is developed.
By this technique, it was confirmed that the NRC's designated accidents for HARSH environments actually created severe (HARSH) conditions inside the plant and that other events did not contribute to HARSH environments.
With this practical tool unique pathways for successfully accomplishing each of the six essential safety functions were determined-a principle success path and an alternate success path.
The systematic compilation of each event leading to equipment exposure to a H ARSH environment was then traceable to these success paths.
Compilation of exposed equipment and redundant equipment which could perform the safety function from a non-exposed plant location became a routine appraisal step in evaluating the effects of each HARSH event and in evaluating means by which the event could be mitigated.
The listing of l
components requiring qualification to HARSH l
environmental conditions ensued based upon the fact that they were exposed to such conditions when required to mitigate the HARSH event (ie. support one of the six safety functions).
These essential safety components then represented the event-set of safety equipment to be qualified.
By adding all the events together, the event i
sets added into a basic set of safety equipment needing l
to be qualified to the HARSH conditions.
Where certain pieces of equipment were common to more than one HARSH event, the most severe environmental condition was assigned for the qualification condition for that equipment.
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. The proprietary information is the systemic output of equipment needed to ful fill the six safety functions together with the reasons why other equipment is not necessary along all alternate pathways.
Also o f significance is the hierarchy of safety equipment needs and supporting equipment needs.
These differ tremendously from the original list of Class IE electrical equipment in the plant that was initially claimed to be essential hence necessary to be qualified to a conglomerate of superimposed accidents as if all accidents occurred simultaneously and all safety functions were required immediately thereafter.
This BWR system safety analysis technique decreased the equipment list from over 600 items from the early non-structured appraisal to roughly 130 items from this comprehensive analysis.
The designated material also consists o f Component Application Statements (Tab L) that discuss the function of the component; its description, location, and potential environment; the impact o f component f ailure as a result of the initiating events which cause the HARSH environment; and any required operator action needed to achieve the six safety functions.
Thes e Component Applications Statements present an appraisal of safety as referenced to the safety components and their supporting equipments.
In order to represent the effects of failure of the component and its supporting equipment it was necessary to consider failure mechanisms outlined in IEEE 382.
This process is exemplified in Section 4.7 o f Tab K for two systems.
Both in-system failure effects and possible effects on other systems were considered and reported in the component applications statements.
The component applications statements provide a conclusion at component level of what a complete Failure Model and Ef fects Analysis (FMEA) would show.
Likewise, it was I
concluded that the component applications statements corroborate the results of the systems safety analysis.
The results o f thin tri-level appreisal indicate the safety advantage of a physically separated (compartmentalized) plant that has electrical separation o f redundant safety divisions.
5.
The summary results of both the systems safety analysis and the component applications statements provide a comprehensive basis for the evaluation of what equipment is needed and for how long to prevent or mitigate accident / transient ef fects at LaSalle.
The conclusion l
. is not unexpected, though it contradicts the original premise that most plant equipment must be qualified to survive a HARSH environemnt.
These results are unique to the industry in that they are the first results with such a comprehensive basis.
The technique for their derivation and the systematic method used to assure comprehensive coverage are not new but the systems logic diagram as a compilation tool is new and its utility in structuring the problem and ordering the results is a unique contribution that sets this effort apart from all prior systems appraisals down to component level of detail.
A monetary advantage accrues from the use of this evaluation tool because conclusions therefrom justify which safety equipment must be qualified and which need not be qualified to the HARSH environmental parameters.
6.
With environmental test plans cost vg $17,000 to $45,000 depending upon the complexity of tnv equipment to be tested and with actual execution o f HARSH tests costing
$25,000 to over $200,000, it is indeed economical to justify fewer tests because fewer equipments are needed to mitigate the HARSH accident during or af ter exposure to a H ARSH environment.
The savings on 100 equipment items amounts to somewhere between $4,200,000 and
$24,500,000.
Even the lower estimate of savings is well worth the investment for a thorough and complete system safety evaluation.
The combination of systems conclusions and the detailed definition of potential HARSH environments for each HARSH accident constitutes the basis for justifiable expenditure of testing funds for a much reduced scope of equipment.
7.
Unfortunately, no other utility pursued this comprehensive system safety evaluation, nor was any utility ready to share the development of the system logic on a schedule compatible with LaSalle; therefore, these assessments by Quadrex Corporation (both Vol. I and Vol. II) represent non-recoverable investments unless protected.
Other utilities need only copy from the public record should they so choose to forgo a replicate expense in defining the basis for their Environmental Qualification program.
Competitor AE's or Consultants could easily convert these two study volumes to other plant specific situations with a minimum of effort, thus capitalizing on the ex Corporation (Edison's consultants) pertise of Quadrex and Edison's investment ($105,000 direct cost) without any monetary consideration if these volumes are not withheld from the public reading rooms under a proprietary provision.
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.- 8.
The Commonwealth Edison Company engineering group assigned to LaSalle Project reviewed and approved the proprietary treatment of this information because that engineering group is most acquainted with the technical and cost details associated with this subject.
They also understand the sensitivity of this analytical technique in relation to industry knowledge and utilization.
The approval for external release of this information is exercised by the LaSalle Project Manager, the LaSalle Project Engineering Manager, or the Manager of the Station Nuclear Engineering Department.
Disclosure of this information is not delegated to the Architect Engineer nor to contractors nor to vendors, suppliers, consultants, and licensees.
9.
This appraisal information, to the best of my knowledge and belief, was partially documented to the NRC previously in preliminary format without Volume II as an attachment to a letter from CECO's Mr. L.O. DelGeorge to NRC's Mr. A. Schwencer on October 1, 1981.
It is not available from public sources and its disclosure to other parties shall be conditioned to proprietary agreements which provide maintenance of the information in confidence.
10.' Public disclosure of this information sought to be withheld is likely to erode and destroy one competitive advantage of the Commonwealth Edison Company, its consultant and its Architect Engineer and deprive or reduce the availability for partial recovery of costs from other utilities who have been awaiting release of this inf ormation to justify a less costly systems appraisals for plants under construction.
Cross-referencing the LaSalle docket to justify the use of conclusions and justification therein cannot be allowed without commercial consideration which benefits Commonwealth Edison for partial costs of this systems safety appraisal and component applications statements.
l l
. Thomas E. Watts, being duly sworn, deposes and says that he has read the foregoing affidavit and the matters stated therein are true and correct to the best of his knowledge, information and belief.
E5ecuted at Chicago, Illinois, this Jfel, day of
( L }11/
1982.
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JArasui & 20E Thoma s E. Watts Commonwealth Edison Company STATE OF ILLINDIS)
SS:
COUNTY OF COOK)
SUBSCRIBED and SWORN to before me this Afdday of Osl>)
1982.
d*
A.J Notary Public ih & For Said County & State l
l 15 81 L*
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