ML20136F546

Forwards SER for Final Resolution of Environ Qualification of Electric Equipment Important to Safety.Program & Proposed Resolution of Each Environ Qualification Deficiency Acceptable

ML20136F546
Person / Time
Site:	Maine Yankee
Issue date:	11/26/1984
From:	Knight J Office of Nuclear Reactor Regulation
To:	Lainas G Office of Nuclear Reactor Regulation
Shared Package
ML20136E859	List: DD-85-17, Notice of Issuance of Director'S Decision DD-85-17 Under 10CFR2.206 Re Alleged Equipment Qualification Deficiencies at Facility.Concerns Identified in State of Me 840626 Comments Adequately Addressed ML20136F546
References
TAC-42490, NUDOCS 8412050155
Download: ML20136F546 (10)

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NOV 2 6 1984 Docket'No. 309 MEMORANDUM FOR: Gus C. Lainas, Assistant Director for Operating Reactors Division of Licensing FROM: James P. Knight, Assistant Director, Components & Structures Engineering Division of Engineering

SUBJECT:

SAFETY EVALUATION REPORT FOR FINAL RESOLUTION OF ENVIRON-MENTAL QUALIFICATION OF ELECTRIC EQUIPMENT IMPORTANT TO SAFETY - MAINE YANKEE, TAC 42490 Plant Name: Maine Yankee Docket No.: 50-309 '

Licensing Stage: OR Responsible Branch: Operating Reactors Branch No. 3 Responsible Project Manager: K. Heitner

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The enclosed Safety Evaluation Report (SER) was prepared by DE:C&SE, Equipment Qualification Branch. This SER addresses the environmental cualification of electric equipment important to safety for Maine Yankee for compliance with the requirenents of 10 CFR 50.49, the licensee's proposed resolutions for the deficiencies identified in the SER dated April 8, 1983, and the Tebruary 23, 1983 Franklin Research Center (FRC) Technical Evaluation Report (TER) enclosed with it, and justification for continued operation.

On April 4, 1984, a meeting was held with the Maine Yankee Atomic Power Company to discuss their proposed method cf resolution for each of the environmental qualification deficiencies identified. Discussions also included Maine Yankee's general methodology for compliance with 10 CFR 50.49,

" Environmental Qualification of Electric Eouipment Important to Safety for Nuclear Power Plants," which became effective February 22, 1983, and justification for continued operation (JCO) for'those equipment items for which environmental qualification is not yet completed. The licensee provided a submittal, by letter dated May 31, 1984 addressing the above subjects and documenting the discussions held at the meeting.

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NOV 2 6 1984 Gus C. Lainas Based on discussions during the meeting and the results of our review of the licensee's May 31, 1984 submittal, we have concluded that Maine Yankee's Equipment Qualification Program is in compliance with the requirements of 10 CFR 50.49, that the proposed resolution for each of the environmental qualification deficiencies identified for Maine Yankee is acceptable, and that continued operation of Maine Yankee will not present undue risk to the public health and safety.

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James P. Knight, Assistant Director Components & Structures Engineering Division of Engir.eering

Enclosure:

As stated cc: R. Vollmer

• D. Eisenhut J. M. Taylor J. P. Knight J. Miller K. Heitner R. Karsch W. Sheilds N. B. Le A. Blough, Region I A. Finkel, Region I C. Anderson, Region I T. Martin, Region I R. LaGrange P. Shemanski l

SAFETY EVALUATION REPORT OFFICE OF NUCLEAR REACTOR REGULATION EQUIPMENT QUALIFICATION P'tANCH MAINE-YANKEE DOCKET NO. 50-309 ENVIRONMENTAL OUALIFICATION OF ELECTRIC EQUIPMENT IMPORTANT TO SAFETY INTRODUCTION Equipment which is used to perform a necessary safety function must be demonstrated to be capable of. maintaining functional operability under all service conditions postulated to occur during its installed life for the time it is required to operate. This requirement, which is embodied in General Design Criteria 1 and 4 of Appendix A and Sections III, XI, and XVII of Appendix B to 10 CFR 50, is applicable to equipment located inside as well as outside containment. More detailed requirements and guidance relating to the methods and procedures for demonstrating this capability for electrical equipnent have been set forth in 10 CFR 50.49, "Environnental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants," NUREG-0588,

" Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment" (which supplements IEEE standard 323 and various NRC Regulatory Guides and industry standards), and " Guidelines for Evaluating

-Environmental Qualification of Class IE Electrical Equipment in Operating Reactors" (DOR Guidelines).

BACKGROUND On February 8, 1979, the NRC Office of Inspection and Enforcement (IE) issued to all licensees of operating c' ants (except those included in the systematic evaluation program (SEP)) IE .letin (IEB) 79-01, " Environmental Qualification of Class IE Equipment." This Bulletin, together with IE Circular 78-08 (issued on May 31, 1978), required the licensees to perform reviews to assess the adecuacy of their environmental qualification programs.

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2 On January 14, 1980, NRC issued IEB 79-01B which included the DOR Guidelines and NUREG-0588 as attachments 4 and 5, respectively. Subsequently, on May 23, 1980, Commission Memorandum and Order CLI-80-21 was issued and stated that the D0R Guidelines and portions of NUREG-0588 form the requirements that licensees must meet regarding environmental qualification 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 all licensees. The August order required that the licensees provide a report, by November 1, 1980, documenting 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 staf.f subsequently issued a Safety Evaluation Report (SER) on environmental qualification of safety-related electrical equipment to the licensee on September 2, 1981. This SER directed the licensee to "either provide documentation of the missing oualification information which demonstrates that safety-related equipment meets the D0R Guidelines or NUREG-0588 requirements or commit to a corrective action (requalification, replacement (etc.))." The licensee was required to respond to NRC within 90 days of receipt of the SER. In response to the staff SER issued in 1981, the licensee submitted additional information regarding the qualification of safety-related electrical equipment. This information was evaluated for the staff by the Franklin Research Center (FRC) in order to: 1) identify all cases where the licensee's response did not reaolve the significant qualification issues, 2) evaluate the licensee's qualification documentation in accordance with established criteria to determine which equipment had adequate docunentation and which did not, and 3) evaluate the licensee's cualification documentation for safety-related electrical equipment located in harsh environments required for Tl1I Lessons learned Implementation. A Technical Evaluation Report (TER) was issued by FRC on February 23, 1983. A Safety Evaluation Report was subsequently issued to the Maine Yankee Atomic Power Company on April 8, 1983, with the FRC TER as an attachment.

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3 A final rule on environmental qualification of electric eouipment important to safety for nuclear power plants became effective on February 22, 1983. This rule, Secticn 50.49 of 10 CFR 50, specifies the requirements of electrical equipment important to safety located in a harsh environment. In accordance with this rule, equipment for Maine Yankae may be qualified to the criteria specified in either the DOR Guidelines or NUREG-0588, except for replacement equipment. Replacement equipment installed subsequent to February 22, 1983 must be qualified in accordance with the provisions of 10 CFR 50.49, using the guidance of Regulatory Guide 1.89, unless there are sound reasons to the contrary.

A meeting was held with each licensee of plants for which a TER had been prepared for the staff by FRC in crder to discuss all remaining open issues regarding environmental qualification, including acceptability of the environmentalconditionsforequipmentqualificationpurposes,ifthisissue had not yet been resolved. On April 4, 1984 a meeting was held to discuss Maine Yankee's proposed method to resolve the environmental qualification deficiencies identified in the April 8, 1983 SER and February 23, 1983 FRC TER. Discussions also included Maine Yankee's general methedology for compliance with 10 CFR 50.49, and justification for contirued operation for those equipment items for which environmental qualification is not yet l completed. The minutes of the meeting and proposed method of resolution for l

each of the environmental qualification deficiencies are documented in a May l 31, 1984 submittal from the licensee.

EVALUATION l

The evaluation of the acceptability of the licensee's electrical equipment environmental qualification program is based on the results of an audit review performed by the staff: (1) the licensee's proposed resolutions of the environmental qualification deficiencies identified in the April 8, 1983 SER and February 23, 1983 FRC TER; (2) compliance with the requirements of 10 CFR 50.49; and (3) justification for continued operation (JCO) for those equipment itams for which the environmental qualification is not yet completed.

4 Proposed Resolutions of Identified Deficiencies The proposed resolutions for the equipment environmental qualification deficiencies, identified in the April 8, 1983 SER, and the FRC TER enclosed with it, are described in the licensee's May 31, 1984 submittal. During the April 4, 1984 meeting with the licensee, the staff discussed the proposed resolution of each deficiency for each equipment item identified in the FRC TER and found the licensee's approach for resolving the identified environmental qualification deficiencies acceptable. The majority of-deficiencies identified were documentation, similarity, aging, qualified life and replacement schedule. _All open items identified in the SER dated April 8, 1983 were also discussed and the resolution of these items has been found acceptable by the staff.

The approach described by the licensee for addressing and resolving the L identified deficiencies includes replacing equipment, performing additional analyses, utilizing additional qualification documentation beyond that

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reviewed by FRC, obtaining add'itional qualification documentation and determining that some equipment is outside the scope of 10 CFR 50.49, and therefore not required to be environmentally qualified, e.g., located in a mild environment. We discussed the proposed resolutions in detail on an item ,

by item basis with the licensee during the April 4, 1984 meeting. Replacing or exenpting equipment, for an acceptable reason, are clearly acceptable i nethods for resolving environmental qualification deficiencies. The more lengthy discussions with the licensee concerned the use of additional analyses or documentation. Although we did not review the additional' analyses or documentation, we discussed how analysis was being used to resolve deficiencies identified in the FRC TER, and the content of the additional documentation in order to determine the acceptability of these methods. The l

licensee's equipment environmental qualification files will be audited by the j staff during follow-up inspections to be performed by Region 1, with assistance form IE Headquarters and NRR staff as necessary. Since a significant amount of documentation has already been reviewed by the staff and Franklin Research Center, the primary objective of thi file audit will be to verify that they contain the appropriate analyses and other necessary

5 documentation to support the licensce's conclusion that the equipment is qualified. The inspections will verify that the licensee's program for surveillance and maintenance of environmental qualified equipment is adequate I to assure that this equipment is maintained in the as analyzed or tested condition. The nethod used for tracking periodic replacement parts, and implementation of the licensee's commitments and actions, e.g., regarding replacement of equipment, will also be verified.

The licensee states the Maine Yankee EQ Master List contains the safety-related electrical equipment defined in Paragraph (b)(1) of 10 CFR 50.49. The list is limited to equipment required to remain functional in the harsh environment to electrical equipment required for safe shutdown or accident mitigation. The Master List was prepared from reviews of the Maine Yankee Final Safety Analysis Report (FSAR), Technical Specifications, emergency operating procedures, and applicable piping, instrumentation, and electrical drawings. Maine Yankee also included flooding outside containment in the list of design basis events which could result in a potentially harsh environment. Therefore, all design basis events at Maine Yankee were considered within the scope of Paragraph (b)(1) of 10 CFR 50.49.

The licensee's approach for identifying equipment within the scope of paragraph (b)(1) is in accordance with the requirements of that paranraph, and therefore acceptable.

The method used by the licensee for identification of electrical equipment within the scope of paragraph (b)(2) of 10 CFR 50.49, nonsafety-related electric equipment whose failure under postulated environmental conditions could prevent satisfactory acccmplishment of safety functions, is summarized below:

1. The elementary wiring diagrams of the Master List equipment were reviewed to identify any non-safety related devices with a direct electrical con-nection into the control or pcwer circuitry of that equipment (e.g.,

automatic trips or interlocks). Any equipment identified during this review was evaluated to determine if its failure, due to postulated harsh environmental conditions, could prevent the reouired operation of the associated safety-related equipment.

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(. 2. The operation of the safety-related systems and equipment were reviewed to

( identify any non-safety-related auxiliary equipment with electrical com-ponents which are necessary for the required operation of the safety-t related equipment (e.g., cooling water or lubricating equipment). This involvedthejeviewofplantdrawinos,technicalmanuals,andsystems l~ descriptions in the FSAR.

3. Non-Safety-related electrical circuits indirectly associated with the l l electrical equipment identified in the Master List by common power supply l were considered by a review of the original Maine Yankee electrical design including the use of properly coordinated protective relays, circuit j breakers, and fuses for electrical fault protection.

l The licensee states that no additional equipment at Maine Yankee was I

identified during the above review that was not previously included in the Master List.

We find the methodology being-Used by the licensee is acceptable since it provides reasonable assurance that equipment within the scope of.paraoraph (b)(2) of 10 CFR 50.49 has been identified.

With regard to paragraph (b)(3) of 10 CFR 50.49, the licensee states that its Regulatory Guide 1.97 equipment was addressed during Maine Yankee's study of NUREG-0737, Supplement 1. A schedule for completion of the NUREG-0737, Supplement 1 activities has been submitted to NRC. Upon completion of those activities, Maine Yankee will add Regulatory Guide 1.97, Cateoory 1 and 2 items to the Master List.

We find the licensee's approach to identifyirg equipment within the scope of paragraph (b)(3) of 10 CFR 50.49 acceptable since it is in accordance with the requirements of that paragraph, Justification for Continued Operation Itainee Yankee stated equipment replacements will be completed during its current refueling outage therefore, JC0's are not required.

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CONCLUSIONS Based on the above evaluation, we conclude the following with regard to the qualification of electric equipment important to safety within the scope of 10 CFR 50.49. .

Maine Yankee's electrical equipment environmental qualification program complies with the requirements of 10 CFR 50.49.

The proposed resolutions for each of the environmental qualification deficiencies identified in the April 8, 1983 SER and FRC TER are acceptable.

• Continued operation will not present undu,e risk to the public health

! and safety.

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. 8 SALP INPUT FOR MAINE YANKEE 8

l 1. Management Involvement in Assuring Quality Overall r'ating for this attribute is category 1. The licensee exhibited consistent evidence of prior planning and assignment of priorities including well stated controlled and explicit procedures for control of equipment oualification activities.

2. Approach to Resolution of Technical Issues Overall rating for this attribute is category 1. The licensee demon-strated a clear understanding of issues and provided technically sound and thorough approaches to the resolution of equipment qualification deficiencies in almost all cases.

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3. Responsiveness to NRC Int'tiatives Overall rating for this attribute is category 1. The licensee was responsive and provided a schedule that was tinely regarding the resolution of equipment qualification deficiencies.

4. Enforcement History - N/A

5. Reportino end Analysis of Reportable Events - N/A

6. Staffing - N/A Training - N/A

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