ML20204F274

Safety Evaluation Re Environ Qualification of safety-related Electric Equipment.Licensee Must Identify All Assumptions Used to Determine Qualification Values.Proprietary Review Guidances Encl

ML20204F274
Person / Time
Site:	Pilgrim
Issue date:	04/13/1983
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20204F270	List: ML20204F265 ML20204F274
References
NUDOCS 8304290239
Download: ML20204F274 (7)

Text

- - - , . - . ~

ENCLOSURE 1

-. UNITED STATES

• g

. [ Ty .,

i NUCLEAR REGULATORY COMMISSION ~

7 W$F[,/ f WASHINGTON. D. C. 20555

\'^.....#%' SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION BOSTON EDISON COMPANY

.. PILGRIM NUCLEAR POWER STATION  !

DOCKET N0. 50-293 i

ENVIRONMENTAL QUALIFICATION OF SAFETY-RELATED ELECTRIC EQUIPMENT INTRODUCTION General

• Design Criteria 1 and 4 specify that safety-related electrical equipment in nuc. lear facilities must be capable of performing its safety-related function under environmental conditions associated with all normal, abnormal, and accident plant operation. In; order to ensure compliance with the criteria, the NRC staff required all licensees of 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) issued to all licensees of operating plants (except those included in the systematic evaluation program (SEP)) IE Bulletin (IEB) 79-01, " Environ-mental Qualification of Class IE Equipment." This Bulletin, together with IE Circular 78-08 (issued on May 31,1978), required the licensees

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

On January 14, 1980, NRC issued IE Bulletin 79-01% which included the 00R guidelines and NUREG-0588 as attachments 4 and 5, respectively. .

h

. e 1

8304290239 830413 .

PDR ADDCK 05000293 P '

~ ' ~ ~

• P ~ -v 7

~

.PDR.

~

. . ~m l

sl Subsequently, on May 23, 1980, Commission Memorandum and Order CLI-80-21 wasissuedandstatedthe00RguidelinesandportionsofNUREG-0588 form the requirements that licensees must meet regarding environmental qualific,ation of safety-related electrical equipment in order to satisfy those aspects of 10 CFR 50, Appendix A, General Design Criterion (GDC) 4.

Supplements to IEB 79-01B were issued, for further clarification and definition of the staff's needs. These. supplements were issued on February 29, September 30, and October 24, 1980.

In addition, the staff issued orders dated August 29, 1980 (amended in

. September 1980) and October 24, 1980 to atl licensees. The August order. .

required that the licensees pro'idev a report, by November 1,1980, docu-menting the qualification of safety-related electrical equipment. The October order # required the establishment of a central file location for the maintenance of all equipment qualification records. The central file was mandated to be established by December 1, 1980. The staff subsequently issued Safety Evaluation Reports (SERs) on enviromental qualification of safety-related electrical equipment to licensees of all operating plants in mid-1981. These SERs directed licensees to "either provide documentation of the missing qualification information which demonstrates that safety-related equipment meets the DOR G,uide-  ;

lines or NUREG-0588 requirements or commit to a corrective action (re qualification, replacement (etc.))." Licensees were required to

- respond to NRC within 90 days of receipt of the SER. In' response T.o 1:

p f

I 4

n

.. _q

. = m m.-m s

e thestaffSERissuedbune3,1981,thelicenseesubmittedadditional infcNation regarding the qualification of safety related electrical '

equipment.

EVALUATION The acceptability of the licensee's equipment e,nvironmental qualification program was resolved for the Division of Engineering by the Franklin Research Center ('FRC) as part of the NRR Technical Assistance Program in support of NRC operating reactdr licensing actions. The consultant's ,

review is documented in the report "13eview of Licensees' Resolutions of Outstanding Issues from NRC Equipment Environmental Qualification Safety - -

Evaluation Reports," which is attached.

Wehavereviewedtheevaluationperformedbyourconsultantcontainedin the enclosed Technical Evaluation Report (TER) 'and concur with its bases and findings.

CONCLUSIONS Based on the staff's review of the enclosed Technical Evaluation Report, the following conclusions are made regarding the qualification of safety-related electrical equipment.

The staff is continuing to review the licensee's environmental qualification program. If any additional qualification deficiencies were identified

' ~

during the course of this review,- the licensee would be requir d to reverify the justification 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 the public health and safety.

The-licensee must provide the. plans

.+-s e s - - mm N g ,-.mm em em-e m e w--w ~ " ~ ***

. . ~ . . , _ m _ . - - -

. c

i#ica-ior, or. ce:ia:smsn Of t. s v. ;ilieig equi: .ent anc -he ' .

. scnecule for accomplisning its prop:se: corrective action in accordance witt, iC CFR 50.49. .

~

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 licenseg are summarized below: .- ,

o Submission of information within thirty.(30) days for items - .

in NRC categories I.b, II.a. II.b and IV for which justification ,,

for continued operation was not previously submitted to NRC or FRC .

o The staff has reviewed the p'ressure and temperature profile -

inside containment (Section 4.3.3.1 of the FRC TER) and finds it acceptable, _

o Resolution of the staff concern regarding the pressure and temperature profile outside containment (Section 4.3.3.2 of the'FRC TER),

o Resolution of the staff concern regarding the radiation dose inside and outside containment (Sedtion 4.3.3.3 of the FRC

'TER). As a result of the staff review, we conclude that the licensee must show that all equipment'inside containment is

" qualified ~toradiationvaluesinexcessof1.8x10kRads gamma (for beta shielded components) or 2 x 108 (beta + gamma) for unshielded components, or that the iadiation values inside the Pilgrim containment are less than the' staff estimates.

- . If the licensee elects to demonstrate that a smaller radiation. .

e y

6

• g e

. m. . em- we , ~ ,. . mw n.- -.- .-- - e,- av .m e 9 -

n-

~

~.. u. :.  : J hM 5

4 k

service condition is appropriate, all assumptions used in the do's'e evaluation and a sample calculation for the dose at the containment centerline from all sources must be provided.

l' Further, the licensee has not provided the radiation environ- .

j .

ment for equipment located outside containment as identified j in the June 1,1981 SER. The licensee must provide either a 4

j reference for this information or identify all the assumptions j used in determining the qualification values and a sample calcu-lation for one piece of equipment.

'! PROPRIETARY REVIEW ,,

i Enclosed in the FRC Technical Evaluation Report (TER) are certain identi-i i

fied pages on which the information is claimed to be procrietary.

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

.i other documents supplied by the licensee that included material claimed k

i to be proprietary. NRC is now preparing to publicly release the FRC

! TER and it is incumbent on the agency to seek review of all claimed

proprietary material. As such, the licensee is requested to review I the enclosed TER and notify NRR whether any portions of the identified

~

, , pages still require proprietary protection. If so,.the licensee must ,'

clearly identify this information and the specific, rationale an.1 justi-fication for the protection from public disclosure, detailed in a written

. . - g response. The level of specificity necessary for such continued protection

^

should be' consistent with the criteria enumerated in 10 CFR 2.790(b) of

. . i'

- the Commission's regulations.

Principal Contributor: P. Shemanski, ., ,

Date: April 13,1983 v w , , ,

- ~

' . . - . - . . . - ~ . - -. .--.n.2&5

~

j PRPRIETARY REVIE'n' GUI DELINES It is the pMicy of the Nuclear Regulatory Commission that the records of, the agency are avaiTable for inspection and copying in the NRC ou blic Encument Room, except for matters that'are exempt from public. disclosure l pursuant to the nine exemptions of the Freedom of Information Act.

(See 10 C.F.R. 2.790) i Recently, the NRC has had'its contractor Franklin Research Center (FRC),

l prepare Technical Evaluation Reports. for all 10 CFR Part 50 licensees. -

i These reports evaluate and comment upon the references cited by the I licensee as evidence of qualification in accordance with the docanentatib6 reference instruct! ions' established tiy IE Bulletin 79-018.

i In. a typical evaluation, FRC generates a report of approximately 750 pages.

} Any page which mentions or comments upon a licensee's referenced' material j

i that was marked or claimed to be proprietary is marked at the top of the page with the legend " Proprietary Infomation". FRC has used this marking i

in a liberal manner and has not fully investigated the licensee's claim to i

detemine whether portions of pro,prietary reports that they reproduced or '" ~

' m'entioned were in fact " proprietary".- A report t.ypically contains 15 to 25 pages that are marked " Proprietary Infomation", Usually, no more than i

i A licensee proprietary references are so discussed. In order td make any of the reports available to the public FRC has produced two versions of l each: those containing proprietary information and those having the pro-

!, prietary' information removed.

The NRC now seeks the assistance of licensees in reviewing the proprietary versions of the FRC reports to determine i

whether still more information can be made available to the public.

i For this reason, each licensee has been sent the Staff Equipment Q'ualification SEP and 2 copy of the proprietary version of the FRC Technical Evaluation

! Report. It is believed that the licen:;ee can review the few pages containing proprietary information in a relatively short period of time. The licensee is to send the third party owner of the reference report, which has been ciaimed to be proprietary, a copy of those pages from the FRC report that relates to its test report. The third party owner can quickly revi.ew these pages and determine whether the information claimed to be proprietary must still be so . categorized. All reviewers should be aware of the NRC's polic ji Quali.y, as specified fication ' testing in willSECY-81-119, not be treatedthat as sumary databyonthe proprietary Equipment NRC. If the review identifies no data that requires protection, the NRC should'be notified and that portien of the report will be placed.in the Public D:cu-ent Roo n. If. ha efer, the licensee identifies to' the NRC portions

' that are still clai ed to rapire proprietary protection, their compliance

... , ::4 ma:6 with tr.E ripire.:.ar.ts for withholcing. unde ~r 10 C.F.R. 2.790.

This can be accomplished in two ways: (1) If the reference proprietary r; port has previously been submitted to the NRC pursuant to 10 C.F.R. 2.790 i-

, and the NRC, has made a detemination that portions are proprietary, then I

, . ~ i s-p yv 5 r--T -

w w v -

e, 1

~

1 4  !

~~

n:se sar,e portions can oe. protected again simply by notifying the NRC that this r:ater il.1 it covered in the NRC's acceptance letter of a given date.

If the reference' proprietary report has not previously been submitted to the NRC p;rs J ant to 10 C.F.R. 2.790, then the licensee and the proprietary owner must at this time make such an application and request for withholding from . .

public disclosure.

The NRC recognizes that this proprietary review places an administrative burden Upon its licensees and any third party owners. However, it is the-policy of the NRC to. make .all non.-pr.oprietary information public, and the only way to protect the owner of proprietary'information is to insure 1

that the Franklin reports have been appropriately scrutinized, i

The NRC will grant extensions of time for'these reviews if necessary, on a case-by-case basis. If you have any fu'r ther questions regarding this review, please contact either Edward Shomaker, DELD, at 492-8653 or.

. , Neal Abrams, patent Counsel, at 492-8662. -

s 2

,t 4

e e e.-

V e .

s s

3 f