ML20102B384
Text
c
'l f;h k.
November 23, 1983 Note to: Joe Scinto Mary E 'Wagnerf)lv From:
SUBJECT:
SUSQUEHANNA This proposed amendment would change the deadline for environmental qualification of certain equipment at Susquehanna-1.
The proposed deadline would require environmental qualification of this equipment in two years or
'by the end_ of the first refueling outage after the NRC arriving at a position on how to qualify the. equipment, whichever is' later.
Thus, the question arises-as to whether the proposed deadline is consistent with 10 CFR s 50.59(g).
The particular equipment qualifications here relate to an SDV pipe break environment.
It appears that ani.DV pipe break environment is beyond design basis for Susquehanna-1, and thus would not have to be environmentally qualified in accordance with the deadlines in 6 50.49.
Rick Lobel, the staff reviewer, has confirmed to me that an SDV pipe break is not defined as a design-basis event.
As bcst as I can piece together the history of the existing license condition, it arose out of NUREG-0803, " General Safety Evaluation Report Regarding Integrity.of BWR Scram System Piping."
NUREG-0803 in a sense skirted the issue, by not saying that SDV pipe breaks were design basis but saying at the same time that they were of a sufficiently high degree of probability such that some equipment might have to be changed.-
m b',
On July _1,1982 the Staff informed PP&L that equipment essential to shutdown of the plant and mitigation of SDV pipe break should be included in the equipment qualification program.
(See SSER,'Supp. 3,
- p. 4-11). PP&L agreed to do this (Id.; see also PP&L letter to Staff of-September 17,'1981 and PP&L letter to Staff of December 29, 1983
-(1 12)). 'These ' documents are attached.to my note,for your reference. -
This commitment was then. incorporated as a license condition.
The basis for the present deadline probably 'is that the qualification was to be accomplished. as part of PP&L's equipment qualification program.
has submitted a. report to the Staff on the probability of an SDV break
'(which the-Staff has not found adequate in'and of itself to show that the
- equipment does not have to be environmentally qualified) and is doing further study in an attempt to remove this license condition entirely.
Under these circumstances, as long as the Staff maintains that an SDV break is not a design basis accident, an extension of the envi.ronmental qualification date would seem to fall outside the restrictions of 6 50.49(g).
I concur,with noted changes to the package.
a
}
'l
a ADATOS4-166 PDR m
-