ML20076K854

Respecification of Contention I-42 Re Environ Qualification of Electrical Equipment.Certificate of Svc Encl

ML20076K854
Person / Time
Site:	Limerick
Issue date:	07/11/1983
From:	LIMERICK ECOLOGY ACTION, INC.
To:
Shared Package
ML20076K840	List: ML20076K836 ML20076K854
References
NUDOCS 8307180142
Download: ML20076K854 (6)

Text

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i I-42.

The applicant has not shown compliance with the Commission's rule, Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants, Jan. 21, 1983, 48 FR 2729, 10 CFR S 5 0. 4 9. Particularly, it has neither established a program for qualifying all of the electrical equipment covered by 550.49, nor performed an analysis to ensure that the plant can be safely operated pending completion of equipment qualification, as required by S50.49(i). Failure to comply will threaten the health and safety of the public.

BASI'S :

a) The new rule covers qualification of pafety-related electrical. equipment, required by NUREG-0588 (saf e cy-related equipment being Class lE equipment in IEEE Standard 323), and non-safety-related' equipment whose failure under postulated enviror. mental conditions could mislead the operator or otherwise prevent 'satsifactory accomplishment of specified safety functions.

It also covers certain post-accid'ent monitoring equipment.

Applicant's EQ program, designed prior to issuance of the new rule, was designed to qualify safety-related equipment only

@$ (see EQ Report, SS 1 and 2 and Appendix B, for example). Applicant  !

-mm bo og relies upon NUREG-0588 to demonstrate the adequacy of its u.m .

O EQ program.

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oo It is clear from the new EQ rule, however', that it was the

mo gg Commission *'s intention to expand its EQ requirements to cover f'"'" equipment outside of the scope of the Class lE list (see 48 FR

.- 2 7 3 3 , column 1, including footnote 3). In addition, GDC 4 of

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40 CFR Part 50, Appendix A, requires that equipment important to safety be designed to be compatible with postulated environmental conditions.

In light of the broader coverage of 10 CFR 550.49 and the confusion and/or disagreement that has arisen between NRC staff membeis and between NRC staff and the regulated community concerning the definitions of safety classifications (see affidavit of Jmmes H. Conran, pp. 28-33, previously submitted), applicant should promptly develop a list of the equipment at Limerick that is "important to safety" (and not just safety-related) and that will be tested in its environmental qualification program (such a list is required by 10 CFR 550.49 (d)) . Failure to promptly develop this list and to reach agreement as to what additional equipment must be qualified in order to comply with the new 550.49 and GDC 4 will seriously impair applicant's progress in qualifying all necessary equipir.ent.

Without the documentation that the applicant has included all necessary non-safety-related but important-to-safety

_. equipment in its EQ program, and without the analysis required by 550.4'9(i), applicant cannot assure that post-accident failure of non-safety-related. equipment will not degrade any safety function or mislead the operator pending completion of qualification.

l Examples of sy. stems or equipment that should be reviewed l

) for inclusion in the applicant's EQ program include those for feedwater control, emergency lighting and communications systems,

' th;+tlant process computer system, and computer sof tware.

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b) Consideration of those systems that are required to mitigate the consequences of a LOCA or HELB, in order to determine the list of systems and equipment to be qualified, is inadequate (see EQ Report, p. 2-1.) It is important to consider not only the interaction of failed equipment with other equipment caused by accident initiators such as LOCA and HELB, but to conduct a human interaction review to determine which equipment failures' caused by adverse environmental conditions can mislead the operator and therefore degrade safety functions. As an example, the applicant's response to O 281.11 of the FSAR states:

Non-safety-related valves that are part of the PASS [ post-accident sampling systeml are not included in the Limerick equipment qualification program. However,. those valves that are not accessible for repair after an accident do not contain materials that, if degraded, would prevent the PASS from performing its sampling function.

LEA contends, however, that it is important to determine whether failura of such valves would mislead the operator into misjudging the level of radionuclide releases occurring, and therefore to cause miscategorization of an accident for emergency planning purposes. Applicant's EQ Report contains no documentation

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that such human interaction problems have been addressed.

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c) The applicant's EQ Report is inadequate, in that:

1) EQRRs (Equipment Qualification Review Records) are .provided for only one type of equipment --

Limitorque valve motor operators (see Appendix E).

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2) Where qualified life of a piece of equipment does not equal the,40 year plant life, no action is identified to correct the deficiency (see EQRRs, pp. 8, 32-35).

3) The Beport excludes some safety-related equipment without explanation or justification. For instance, in its qualification of equipment related to the standby liquid control system, squib valves and the related key lock switch in the control room are excluded.

LEA reserves the right to review the October, 1983 amendments to the EQ Report and to submit a,dditional contentions as necessary.

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CERTIFICATE OF SERVICE -

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I hereby certify that Limerick Ecology Action's foregoing s respecification of contention I-42 has been served, U.S. mail, first-class postage prepaid, upon the following on July 11, 1983:

Lawrence-Brenner, Chairman Atomic Safety and Licensing Board Administrative Judge Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, DC 20555 Washington, DC 20555 Atomic Safety and Licensing Dr. Richard F. Cole Appeal Panel Administrative Judge U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Washington, DC 20555 Commission Washington, DC 20555 Docketing and Service section Office of the Secretary -

Dr. Peter A. Morris U.S. Nuclear Regulatory Commission Administrative Judge Washington, DC 20555 U.S. Nuclear Regalatory Commission Thomas Y. Au, Esq.

Washington, DC 20555 ~ Commonwealth of PA Department of Environmental.Rescurces Ann P. Hodgdon, Esq. 505 Executive House Office of the Executive P.O. Box 2257

'Harrisburg, PA 17120

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- Legal Director s U.S. Nuclear Regulatory Commission David Wersan, Esq.

Washington,'DC 20555 Assistant Consumer Advocate.

Office of the Consumer Advocate Troy B. . Conner, Jr., Esq. 1425 Strawberry Square -

Conner and Wetterhahn Harrisburg, PA 17120-1747 Pennsylvania Ave., NW *

. Washington, DC 20006' Director .

PA Emergency Management Agency Phila.-Electric Company Basement, Transportation and

' ATTN: Edward'G. Bauer, Jr.. Safety Building VP.and General Counsel Harrisburg, PA 17120 2301 Market St.

Phila., PA 19101 ,

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Thcmas Gerusky, Director Spence W. Perry, Esq.

Bureau of Radiation Protection Associate General Counsel Department of Environmental FEMA Resources Room 840 Fulton Bank Building, 5th fl. 500 C St., SW Third and Locust Sts. Washington, DC 20472 Harrisburg, PA 17120 Martha W. Bush, Esq.

• Deputy City Solicitor -

City of Philadelphia Municipal Services Building 15th and JFK Blvd.

Phila., PA 19107 Robert Anthony 103 Vernon Lane, Box 186 Moylan, RA 19065 Donald Bronstein, Esq.

1425 Walnut St., 3rd fl.

Phila., PA 19102 Marvin Lewis 6504 3radford Terrace Phila., PA 19149 Jacqueline I. Ruttenberg Keystone Alliance 3700 Chestnut St.

Phila., PA 19104 .

4 Frank Romano 61 Forest Ave. . .

Ambler, PA 19002 Joseph H. White III B. w 1 b ,

Robert.Sugerman, Esq'.

Sugarman and Denworth Suite 510, North American Building 121 S. Broad St.

Phila., PA 19107

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