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Category:CORRESPONDENCE-LETTERS
MONTHYEARML18017A9241999-10-15015 October 1999 Provides Supplemental Info Re 981223 Lar,Placing Plant Spent Fuel Pools 'C' & 'D' in Service.Info Provided Does Not Change Util Initial Determination That Proposed License Amend Represents No Significant Hazards Consideration ML18017A9141999-10-12012 October 1999 Forwards Addl Info Re Second 10-year ISI Program Plan Relief Requests,As Requested During 990923 Telcon ML18017A9131999-10-0606 October 1999 Provides Notification That Three SROs Licensed at Shnpp Have Been Reassigned from Position for Which Util Previously Certified Need for SRO License.Name,Docket Number & License Number for Subject Sros,Encl.Encl Withheld ML18017A8911999-09-30030 September 1999 Submits Comment on Encl 2 to 990617 Memo Titled Summary of Meeting with Nuclear Energy Inst. Encl 2 Was Titled Draft Technical Study of Spent Fuel Pool Accidents for Decommissioning Plants. Rept Which Provides Info Encl Also ML20216G3501999-09-29029 September 1999 Confirms Conversations Re NRC Staff Voluntary Response to Orange County Discovery Requests.Staff Will Voluntarily Answer Discovery Requests & Will Not Waive Any Objection or Privilege Under NRC Regulations.Related Correspondence ML20212M1081999-09-29029 September 1999 Confirms Intent to Meet with Utils on 991025 in Atlanta,Ga to Discuss Pilot Plants,Shearon Harris & Sequoyah Any Observations & Lessons Learned & Recommendations Re Implementation of Pilot Program ML20212J0741999-09-29029 September 1999 Refers to Proposed License Amend for Harris NPP Which Would Allow Licensee to Activate Two of Plant Spent Fuel Pools.Serves Copy of Orange County Second Set of Document Requests to NRC Staff,Dtd 990929.Related Correspondence ML18017A8941999-09-29029 September 1999 Forwards Response to NRC 990414 RAI Re GL 95-07, Pressure- Locking & Thermal-Binding of SR Power-Operated Gate Valves. ML18017A8881999-09-27027 September 1999 Submits Info Re Estimated Effect of Changes or Errors in ECCS Evaluation Models or in Application of Models,Per 10CFR50.46(a)(3)(ii) ML18017A8861999-09-21021 September 1999 Forwards Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Examinations. ML18017A8821999-09-14014 September 1999 Provides Notification That RO Licensed on Harris Plant No Longer Meets Requirements of 10CFR50.21,effective 990826. Name,Docket Number & License Number for Individual Provided in Encl.Encl Withheld,Per 10CFR2.790(a)(6) ML18017A8651999-09-0808 September 1999 Requests Relief from Section XI,IWA-5242(a) Requirement for HNP Class 2 Bolted Connections in Borated Sys.Compliance with Requirement Would Result in Unusual Difficulty Without Compensating Increase in Level of Quality & Safety ML18017A8581999-09-0303 September 1999 Provides Response to NRC 990805 RAI Re Amend Request to Increase Fuel Storage Capacity ML18017A8551999-09-0101 September 1999 Forwards Marked Up Copy of Approved FSAR Section 17.3 with Applicable Duplicated TS Requirements,As Committed to in 990602 Application for Rev to TS ML18017A8541999-08-20020 August 1999 Submits Closure Info for Rev 1,Suppl 1 to GL 92-01, Reactor Vessel Structural Integrity. Identified Discrepancies from Review of NRC Rvid Provided HNP-99-134, Forwards Rev 11 to Physical Security & Safeguards Contingency Plan,Iaw 10CFR50.54(p)(2) & 10CFR50.4(b)(4). Description of Changes Is Provided as Encl 2 to Ltr.Rev Withheld,Per 10CFR73.211999-08-18018 August 1999 Forwards Rev 11 to Physical Security & Safeguards Contingency Plan,Iaw 10CFR50.54(p)(2) & 10CFR50.4(b)(4). Description of Changes Is Provided as Encl 2 to Ltr.Rev Withheld,Per 10CFR73.21 ML18017A8351999-08-10010 August 1999 Corrects Statement Made in 980923 Ltr,By Clarifying That Operation of Inner & Outer Pal Doors Can Be Operated by Control Panels Located Inside & Outside Containment ML18016B0531999-08-0606 August 1999 Forwards Exercise Scenario with Controller Info & Simulation Data for Harris Nuclear Plant Emergency Preparedness Exercise Scheduled for 990921.Without Encl ML18016B0461999-08-0404 August 1999 Forwards LER 99-006-01 Describing Condition Which Resulted in Exceeding TS Requirements for CIVs & TS 4.0.4 for Generic Requirements for Surveillance Testing.Rev Includes Results of Investigation Into Failure to Recognize TS Requirements ML18016B0391999-07-30030 July 1999 Forwards Rev 35 to PLP-201, Emergency Plan. Rev Replaces All Pages of Previous Rev with Exception of EAL Flow Path, Side 1 & 2 & Annex H,Operations Map & Aperature Card. Changes Made by Rev,Listed ML18016B0421999-07-30030 July 1999 Informs That in Ltr Dtd 950330 CP&L Committed to Complete Assessment of Severe Accident Mgt Capabilities & Make Any Identified Enhancements by 981231.Actions Were Completed in July 1998 ML18016B0221999-07-26026 July 1999 Informs That CP&L Proposes to Provide Response to NRC 990414 RAI Re GL 95-07, Pressure-Locking & Thermal-Binding of SR Power-Operated Gate Valves, by 990930 ML18016B0171999-07-16016 July 1999 Forwards Corrected Pages to Annual Radioactive Effluent Release Rept, for 1998 for HNP ML18016B0051999-07-0101 July 1999 Informs of Scheduled Emergency Preparedness Exercise for Shnpp on 990921,per Requirements of 10CFR50,App E.List of 26 Objectives Selected for Evaluation During Exercise,Encl. Without Encl ML20212H7741999-06-23023 June 1999 Responds to Re Petition Filed by Orange County Board of Commissioners Re Proposed Expansion of Sf Storage Capacity at Shearon Harris Npp.Public Meeting Will Be Held at Later Date.With Certificate of Svc.Served on 990624 ML18016A9871999-06-14014 June 1999 Forwards Response to NRC 990429 RAI Re License Amend Request to Place Spent Fuel Pools C & D in Service,Dtd 981223.Info Does Not Change Initial Determination That Proposed License Amend Represents No Significant Hazards Consideration ML18016A9831999-06-10010 June 1999 Submits Notification That Reactor Operator Licensed at HNP Has Terminated Employment with Cp&L.Reactor Operator Info Encl.Effective 990528,individuals License Is No Longer Required & CP&L Requests That License Be Terminated ML20212H7521999-06-0404 June 1999 Encourages NRC to Schedule Open Public Forum Which Would Allow Local Citizens to Express Concerns Re Proposed Expansion of high-level Radwaste Storage Capacity at Shearon Harris Npp.With Certificate of Svc.Served on 990624 ML18016A9721999-05-28028 May 1999 Responds to 990309 RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs. ML18016B0011999-05-26026 May 1999 Forwards Ltr Received from Hj Jaffe Expressing Concern Re Cpl Proposal to NRC on Dec of 1998 to Make Harris Nuclear Plant Largest Storage Area for High Level Nuclear Waste in Nation ML18016A9631999-05-25025 May 1999 Forwards Periodic Update to FSAR for Hnp.Amend 49 Is Current Through 981128 (End of RFO 8).Some Changes & Analysis Completed After 981128 Have Also Been Included in Amend ML20206R2511999-05-19019 May 1999 Responds to Addressed to Chairman Jackson Requesting That NRC Grant Standing to Orange County Board of Commissioners in Shearon Harris Proceeding Currently Before Board.With Certificate of Svc.Served on 990519 ML20206Q5281999-05-17017 May 1999 Responds to 990304 Request for Two Rail Routes to Be Used for Transport of Spent Fuel from Brunswick Steam Electric Plant,Southport,Nc & Hb Robinson Steam Electric Plant, Hartsville,Sc to Shearon Harris Npp,Near New Hill,Sc ML18016A9511999-05-13013 May 1999 Submits Info Re Estimated Effect of Change to ECCS Evaluation Model,As Required by 10CFR50.46 ML18016A9601999-05-11011 May 1999 Forwards Resolution Adopted by Carrboro Board of Aldermen at 990504 Meeting.Resolution Expresses Town Concern Re Util Plans to Double high-level Nuclear Waste Storage at Shnpp ML18016A9481999-05-0606 May 1999 Forwards NRC Form 396, Certification of Medical Examination by Facility Licensee, for Senior Reactor Operator Licensed to Operate Hnp.Individuals Info Is Proprietary & Is Being Withheld from Public Disclosure,Per 10CFR2.790(a)(6) ML20206R2611999-05-0505 May 1999 Requests That NRC Grant Standing to Intervention Sought by Orange County Board of Commissioners Re Proposal by CP&L to Expand Storage of Hlrw at Shnpp.With Certificate of Svc. Served on 990519 ML18016A9451999-05-0404 May 1999 Provides Proprietary Notification That One SRO Has Been Reassigned from Position for Which Util Certified Need for SRO License & Another SRO Has Terminated Employment with Util.Proprietary Info Withheld,Per 10CFR2.790(a)(6) ML18016A9441999-05-0404 May 1999 Notifies NRC of Util Completion of Actions Re GL 96-01, Testing of Safety-Related Logic Circuits at Plant ML18016A9351999-04-30030 April 1999 Forwards Info Requested in 990324 RAI as Suppl to 981223 Application for Amend to License NPF-63 for Alternative Plan for Spent Fuel Pool Cooling & Cleanup Sys Piping ML18016A9311999-04-30030 April 1999 Forwards Annual Radioactive Effluent Release Rept for Jan- Dec 1998 & Rev 11 to ODCM for Shnpp HNP-99-068, Forwards Rev 0 to Physical Security & Safeguards Contingency Plan. Description of Changes Provided.Encl Withheld1999-04-28028 April 1999 Forwards Rev 0 to Physical Security & Safeguards Contingency Plan. Description of Changes Provided.Encl Withheld ML18016A9211999-04-27027 April 1999 Provides Rev 2 to ISI Relief Request 2RG-008, ISI of Class 1,2 & 3 Snubbers (Code Category F-A) Per Plant TS in Lieu of ASME Code Section XI, in Response to 990408 Telcon with NRC ML18016A9221999-04-27027 April 1999 Forwards Proprietary Notification That SRO Licensed on Shnpp Has Terminated Employment with Cp&L,Per 10CFR50.74(b). Proprietary Info Withheld,Per 10CFR2.790(a)(6) ML18016A9161999-04-22022 April 1999 Forwards Proprietary NRC Form 396, Certification of Medical Exam by Facility Licensee, for SRO Licensed to Operate Hnp. License for Individual Should Be Amended IAW Change Noted on Form.Proprietary Encl Withheld,Per 10CFR2.790(a)(6) ML18016A9201999-04-20020 April 1999 Informs of HNP Personnel Changes to Facilitate Proper Distribution of Correspondence.Records Should Be Updated to Reflect Noted Change ML20205M0431999-04-13013 April 1999 Eighth Partial Response to FOIA Request for Records.App Q & R Records Encl & Being Made Available in PDR ML18016A9121999-04-12012 April 1999 Forwards Diskette Containing Data Re Annual Exposure Rept for Individual Monitoring for Personnel Shnpp,Per 10CFR20.2206(b).Without Encl ML18016A9021999-04-12012 April 1999 Forwards Rev 34 to PLP-201, Shearon Harris NPP Emergency Plan, Replacing All Pages of Previous Rev with Exception of EAL Flow Path,Side 1 & 2 & Annex H Operations Map & Aperture Card.Changes,Listed.Rev Summary,Encl IR 05000400/19982011999-04-12012 April 1999 Discusses Safeguards Insp Rept 50-400/98-201 (Operational Safeguards Response Evaluation) on 980908-11.No Violations Noted.Licensee Performance During Evaluation Indicated Excellent Overall Contingency Response Capability 1999-09-08
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML18017A9241999-10-15015 October 1999 Provides Supplemental Info Re 981223 Lar,Placing Plant Spent Fuel Pools 'C' & 'D' in Service.Info Provided Does Not Change Util Initial Determination That Proposed License Amend Represents No Significant Hazards Consideration ML18017A9141999-10-12012 October 1999 Forwards Addl Info Re Second 10-year ISI Program Plan Relief Requests,As Requested During 990923 Telcon ML18017A9131999-10-0606 October 1999 Provides Notification That Three SROs Licensed at Shnpp Have Been Reassigned from Position for Which Util Previously Certified Need for SRO License.Name,Docket Number & License Number for Subject Sros,Encl.Encl Withheld ML18017A8911999-09-30030 September 1999 Submits Comment on Encl 2 to 990617 Memo Titled Summary of Meeting with Nuclear Energy Inst. Encl 2 Was Titled Draft Technical Study of Spent Fuel Pool Accidents for Decommissioning Plants. Rept Which Provides Info Encl Also ML20212J0741999-09-29029 September 1999 Refers to Proposed License Amend for Harris NPP Which Would Allow Licensee to Activate Two of Plant Spent Fuel Pools.Serves Copy of Orange County Second Set of Document Requests to NRC Staff,Dtd 990929.Related Correspondence ML18017A8941999-09-29029 September 1999 Forwards Response to NRC 990414 RAI Re GL 95-07, Pressure- Locking & Thermal-Binding of SR Power-Operated Gate Valves. ML18017A8881999-09-27027 September 1999 Submits Info Re Estimated Effect of Changes or Errors in ECCS Evaluation Models or in Application of Models,Per 10CFR50.46(a)(3)(ii) ML18017A8861999-09-21021 September 1999 Forwards Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Examinations. ML18017A8821999-09-14014 September 1999 Provides Notification That RO Licensed on Harris Plant No Longer Meets Requirements of 10CFR50.21,effective 990826. Name,Docket Number & License Number for Individual Provided in Encl.Encl Withheld,Per 10CFR2.790(a)(6) ML18017A8651999-09-0808 September 1999 Requests Relief from Section XI,IWA-5242(a) Requirement for HNP Class 2 Bolted Connections in Borated Sys.Compliance with Requirement Would Result in Unusual Difficulty Without Compensating Increase in Level of Quality & Safety ML18017A8581999-09-0303 September 1999 Provides Response to NRC 990805 RAI Re Amend Request to Increase Fuel Storage Capacity ML18017A8551999-09-0101 September 1999 Forwards Marked Up Copy of Approved FSAR Section 17.3 with Applicable Duplicated TS Requirements,As Committed to in 990602 Application for Rev to TS ML18017A8541999-08-20020 August 1999 Submits Closure Info for Rev 1,Suppl 1 to GL 92-01, Reactor Vessel Structural Integrity. Identified Discrepancies from Review of NRC Rvid Provided HNP-99-134, Forwards Rev 11 to Physical Security & Safeguards Contingency Plan,Iaw 10CFR50.54(p)(2) & 10CFR50.4(b)(4). Description of Changes Is Provided as Encl 2 to Ltr.Rev Withheld,Per 10CFR73.211999-08-18018 August 1999 Forwards Rev 11 to Physical Security & Safeguards Contingency Plan,Iaw 10CFR50.54(p)(2) & 10CFR50.4(b)(4). Description of Changes Is Provided as Encl 2 to Ltr.Rev Withheld,Per 10CFR73.21 ML18017A8351999-08-10010 August 1999 Corrects Statement Made in 980923 Ltr,By Clarifying That Operation of Inner & Outer Pal Doors Can Be Operated by Control Panels Located Inside & Outside Containment ML18016B0531999-08-0606 August 1999 Forwards Exercise Scenario with Controller Info & Simulation Data for Harris Nuclear Plant Emergency Preparedness Exercise Scheduled for 990921.Without Encl ML18016B0461999-08-0404 August 1999 Forwards LER 99-006-01 Describing Condition Which Resulted in Exceeding TS Requirements for CIVs & TS 4.0.4 for Generic Requirements for Surveillance Testing.Rev Includes Results of Investigation Into Failure to Recognize TS Requirements ML18016B0421999-07-30030 July 1999 Informs That in Ltr Dtd 950330 CP&L Committed to Complete Assessment of Severe Accident Mgt Capabilities & Make Any Identified Enhancements by 981231.Actions Were Completed in July 1998 ML18016B0391999-07-30030 July 1999 Forwards Rev 35 to PLP-201, Emergency Plan. Rev Replaces All Pages of Previous Rev with Exception of EAL Flow Path, Side 1 & 2 & Annex H,Operations Map & Aperature Card. Changes Made by Rev,Listed ML18016B0221999-07-26026 July 1999 Informs That CP&L Proposes to Provide Response to NRC 990414 RAI Re GL 95-07, Pressure-Locking & Thermal-Binding of SR Power-Operated Gate Valves, by 990930 ML18016B0171999-07-16016 July 1999 Forwards Corrected Pages to Annual Radioactive Effluent Release Rept, for 1998 for HNP ML18016B0051999-07-0101 July 1999 Informs of Scheduled Emergency Preparedness Exercise for Shnpp on 990921,per Requirements of 10CFR50,App E.List of 26 Objectives Selected for Evaluation During Exercise,Encl. Without Encl ML18016A9871999-06-14014 June 1999 Forwards Response to NRC 990429 RAI Re License Amend Request to Place Spent Fuel Pools C & D in Service,Dtd 981223.Info Does Not Change Initial Determination That Proposed License Amend Represents No Significant Hazards Consideration ML18016A9831999-06-10010 June 1999 Submits Notification That Reactor Operator Licensed at HNP Has Terminated Employment with Cp&L.Reactor Operator Info Encl.Effective 990528,individuals License Is No Longer Required & CP&L Requests That License Be Terminated ML20212H7521999-06-0404 June 1999 Encourages NRC to Schedule Open Public Forum Which Would Allow Local Citizens to Express Concerns Re Proposed Expansion of high-level Radwaste Storage Capacity at Shearon Harris Npp.With Certificate of Svc.Served on 990624 ML18016A9721999-05-28028 May 1999 Responds to 990309 RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs. ML18016B0011999-05-26026 May 1999 Forwards Ltr Received from Hj Jaffe Expressing Concern Re Cpl Proposal to NRC on Dec of 1998 to Make Harris Nuclear Plant Largest Storage Area for High Level Nuclear Waste in Nation ML18016A9631999-05-25025 May 1999 Forwards Periodic Update to FSAR for Hnp.Amend 49 Is Current Through 981128 (End of RFO 8).Some Changes & Analysis Completed After 981128 Have Also Been Included in Amend ML18016A9511999-05-13013 May 1999 Submits Info Re Estimated Effect of Change to ECCS Evaluation Model,As Required by 10CFR50.46 ML18016A9481999-05-0606 May 1999 Forwards NRC Form 396, Certification of Medical Examination by Facility Licensee, for Senior Reactor Operator Licensed to Operate Hnp.Individuals Info Is Proprietary & Is Being Withheld from Public Disclosure,Per 10CFR2.790(a)(6) ML20206R2611999-05-0505 May 1999 Requests That NRC Grant Standing to Intervention Sought by Orange County Board of Commissioners Re Proposal by CP&L to Expand Storage of Hlrw at Shnpp.With Certificate of Svc. Served on 990519 ML18016A9451999-05-0404 May 1999 Provides Proprietary Notification That One SRO Has Been Reassigned from Position for Which Util Certified Need for SRO License & Another SRO Has Terminated Employment with Util.Proprietary Info Withheld,Per 10CFR2.790(a)(6) ML18016A9441999-05-0404 May 1999 Notifies NRC of Util Completion of Actions Re GL 96-01, Testing of Safety-Related Logic Circuits at Plant ML18016A9351999-04-30030 April 1999 Forwards Info Requested in 990324 RAI as Suppl to 981223 Application for Amend to License NPF-63 for Alternative Plan for Spent Fuel Pool Cooling & Cleanup Sys Piping ML18016A9311999-04-30030 April 1999 Forwards Annual Radioactive Effluent Release Rept for Jan- Dec 1998 & Rev 11 to ODCM for Shnpp HNP-99-068, Forwards Rev 0 to Physical Security & Safeguards Contingency Plan. Description of Changes Provided.Encl Withheld1999-04-28028 April 1999 Forwards Rev 0 to Physical Security & Safeguards Contingency Plan. Description of Changes Provided.Encl Withheld ML18016A9221999-04-27027 April 1999 Forwards Proprietary Notification That SRO Licensed on Shnpp Has Terminated Employment with Cp&L,Per 10CFR50.74(b). Proprietary Info Withheld,Per 10CFR2.790(a)(6) ML18016A9211999-04-27027 April 1999 Provides Rev 2 to ISI Relief Request 2RG-008, ISI of Class 1,2 & 3 Snubbers (Code Category F-A) Per Plant TS in Lieu of ASME Code Section XI, in Response to 990408 Telcon with NRC ML18016A9161999-04-22022 April 1999 Forwards Proprietary NRC Form 396, Certification of Medical Exam by Facility Licensee, for SRO Licensed to Operate Hnp. License for Individual Should Be Amended IAW Change Noted on Form.Proprietary Encl Withheld,Per 10CFR2.790(a)(6) ML18016A9201999-04-20020 April 1999 Informs of HNP Personnel Changes to Facilitate Proper Distribution of Correspondence.Records Should Be Updated to Reflect Noted Change ML18016A9121999-04-12012 April 1999 Forwards Diskette Containing Data Re Annual Exposure Rept for Individual Monitoring for Personnel Shnpp,Per 10CFR20.2206(b).Without Encl ML18016A9021999-04-12012 April 1999 Forwards Rev 34 to PLP-201, Shearon Harris NPP Emergency Plan, Replacing All Pages of Previous Rev with Exception of EAL Flow Path,Side 1 & 2 & Annex H Operations Map & Aperture Card.Changes,Listed.Rev Summary,Encl ML18016A8911999-04-0505 April 1999 Forwards non-proprietary App 4A,pages 20-25 & Proprietary Page 4-6 to re-issued Rev 3 of Holtec International Licensing Rept HI-971760.Pages Were Inadvertently Omitted from Reissued Rept.Proprietary Page 4-6 Withheld ML18016A8891999-04-0101 April 1999 Forwards Rev 99-1 to Plant EALs for NRC Review & Approval, Per 10CFR50,App E.Encl Provides Comparison of Currently Approved EALs & Proposed Rev 99-01.Approval of EALs Prior to June 1999,requested.With Four Oversize Drawings ML18016A8811999-03-31031 March 1999 Responds to NRC 990301 Ltr Re Violations Noted in Insp Rept 50-400/98-11.Corrective Actions:Post Trip/Safeguards Actuation Rept for 981023,RT Was Corrected,Required Reviews Completed & Approval Obtained on 990219 ML18016A8671999-03-19019 March 1999 Submits Response to RAI Re Spent Fuel Pool Water Level & Revised Fuel Handling Accident Analyses,Per 990317 Telcon with NRC ML18016A8631999-03-19019 March 1999 Forwards Shnpp Operator Training Simulator,Simulator Certification Quadrennial Rept, IAW 10CFR55.45(b)(5)(ii). NRC Form 474 & Required Info Re Simulator Performance Test Results & Schedules Also Encl ML18016A8691999-03-18018 March 1999 Forwards Resolution Adopted by Lee County,North Carolina Board of Commissioners Re Proposed Expansion of high-level Radioactive Waste Storage Facilities at Carolina Power & Light Shearon Harris Nuclear Power Plant ML18016A8511999-03-15015 March 1999 Forwards Proprietary & non-proprietary Version of Rev 3 to HI-971760, Licensing Rept for Expanding Storage Capacity in Harris SFPs 'C' & 'D'. Repts Are Reissued to Reflect Reduction in Proprietary Info.Proprietary Info Withheld ML18016A8601999-03-15015 March 1999 Informs NRC of Mod to Commitment for Hnp,Re Comprehensive Review of Implementation of TS Sr.Upon Completion of Listed Reviews,Surveillance Procedure Review Project Will Be Considered Complete 1999-09-08
[Table view] Category:UTILITY TO NRC
MONTHYEARML20059L0911990-09-12012 September 1990 Confirms That Fee Electronically Transferred to Dept of Treasury for Payment of NRC Review Fees ML18009A6581990-09-11011 September 1990 Submits Addl Info Re Use of Hafnium Control Rods at Facility.All Rods Will Be Removed During Spring 1991 Outage ML20059H4181990-09-0606 September 1990 Responds to NRC Re Violations Noted in Insp Rept 50-400/90-13.Corrective Action:Changes to EST-717 in Area of Power Normalization Under Study for Past Several Months ML17348B4941990-08-30030 August 1990 Forwards Semiannual 10CFR26 fitness-for-duty Program Data for 900103-0630.Mgt Decision Made to Utilize Alcohol Breath Instruments as Screening Devices for Unscheduled Work Call Outs in Determining fitness-for-duty ML20059D3511990-08-30030 August 1990 Forwards Decommissioning Financial Assurance Certification Rept Submitted by North Carolina Eastern Municipal Power Agency ML18009A6261990-08-10010 August 1990 Informs That Action Committed to in Response to Generic Ltr 88-14, Instrument Air Supply Sys, Completed ML18009A6241990-08-0303 August 1990 Forwards Addl Info Re Operator Action Times Assumed in Steam Generator Tube Rupture Analyses for Plant,Per 900712 Telcon ML18009A6081990-07-31031 July 1990 Forwards Plan for Shearon Harris Nuclear Power Plant Emergency Exercise - 900919, Per NRC Request.W/O Encl ML20055J4171990-07-30030 July 1990 Forwards Rev 5 to Security Plan.Rev Withheld (Ref 10CFR73.21) ML20055F9431990-07-12012 July 1990 Advises That Stated Amount Electronically Transferred to Us Dept of Treasury,Nrc on 900711 for Payment of Operator License Exam Fees for Listed Insp Invoices ML18009A5991990-07-0606 July 1990 Comments on Electrical Distribution Sys Functional Insp Rept 50-400/90-200 on 900212-0316.Seismic Qualification Package Subsequently Upgraded to Include Qualification Info Based on Receipt of Part 21 from Transamerica Delaval ML18009A5851990-06-28028 June 1990 Advises That Emergency Preparedness Exercise Scheduled on 900919.Exercise Will Consist of Simulated Accident at Plant Site & Will Involve Planned Response Actions.Objectives to Be Fulfilled Encl ML18009A5621990-05-30030 May 1990 Responds to NRC 900504 Ltr Re Violations Noted in Insp Rept 50-400/90-06.Corrective Actions:Procedures OST-1008 & OST-1108 Revised to Delete Stroke Testing of Valve 1ST-359 on Quarterly Basis ML18009A5141990-05-0303 May 1990 Forwards Eddy Current Exam CP&L Shearon Harris Nuclear Power Plant Steam Generators A,B & C, Providing Results of Inservice Insps Performed During Plant Second Refueling Outage in Oct 1989 ML18009A4941990-04-26026 April 1990 Forwards Radiological Environ Operating Rept,1989, Radiological Environ Operating Rept,Vol II,Jan-June 1989, Sample Analyses Data & Radiological Environ Operating Rept,Vol III,Jul-Dec 1989,Sample Analyses Data. ML18009A5031990-04-25025 April 1990 Submits Suppl 2 to Relief Request R2-001 Re Plant 10-yr Inservice Insp Plan,Per 880129 Request ML18009A4911990-04-24024 April 1990 Forwards Addl Info Re Proposed Wakesouth Regional Airport to Be Located Near Facility,Per 900411 Request.Info Previously Provided to NRC During 900320 & 23 Telcons ML18009A4841990-04-24024 April 1990 Forwards Corrected Bases marked-up Page to 900226 Tech Spec Change Request Re Surveillance Intervals ML18009A4251990-03-30030 March 1990 Submits Supplemental Response to Station Blackout Rule Based on Guidelines Provided in NUMARC 87-00, Guidelines & Technical Bases for NUMARC Initiatives.... No Changes to Previous Calculations Necessary & One Deviation Noted ML18009A4231990-03-29029 March 1990 Suppls Response to NRC 900216 Ltr Re Violations Noted in Insp Rept 50-400/89-23.Corrective Actions:Surveys Performed to Determined Extent & Level of Contamination & Personnel Involved Decontaminated ML18009A4111990-03-23023 March 1990 Responds to NRC 900227 Ltr Re Violations Noted in Insp Rept 50-400/90-02.Corrective Actions:Personnel Involved W/ Quadrant Power Tilt Ratio Calculations & Operability Determination Counseled ML18009A4121990-03-23023 March 1990 Forwards Rev 17 to PLP-201, Emergency Plan & Fission Product Barrier Analysis.Rev to Emergency Plan Incorporates Comments Received During Recent Licensed Operator Requalification Training in Emergency Plan Procedures ML18009A4151990-03-22022 March 1990 Responds to NRC SALP Rept for Jul 1988 - Nov 1989.Contrary to Statement in Rept Significant Amount of Refresher Training Was Conducted During SALP Assessment Period Including Termination & Splicing & Motor & Bus Relays ML18009A4081990-03-19019 March 1990 Responds to NRC 900226 Ltr Re Violations Noted in Insp Rept 50-400/90-01.Corrective Actions:All Calibr Required by Tech Specs for Power Range Nuclear Instrumentation Satisfactorily Completed ML18022A7891990-03-0909 March 1990 Forwards Vols 1 & 2 of Inservice Insp Summary 1st Interval 1st Period,2nd Refueling Outage Completed 891222. ML18022A7881990-03-0606 March 1990 Confirms Understanding of Status of NRC Activities Re Proposed Wakesouth Regional Airport Located Near Plant Site. Pending Issues Should Be Resolved by 900331 to Enable Util to Complete Negotiations W/Airport Authority ML18022A7851990-03-0202 March 1990 Responds to NRC 900131 Ltr Re Violations Noted in Insp Rept 50-400/89-34.Corrective Actions:Valve SI-332 Closed & Gravity Drain Path Isolated & Shift Foreman Required to Review MMM-012 Re Priority/Emergency Maint Work Control ML18022A7721990-02-26026 February 1990 Forwards Application for Amend to License NPF-63,revising Tech Spec Surveillance 4.0.2 to Permit Surveillances to Be Extended Up to 25% of Specified Interval & Removing 3.25 Limitation from Spec,Per Generic Ltr 89-14 ML20011F3821990-02-26026 February 1990 Confirms Amount Electronically Transferred to Us Dept of Treasury,Nrc on 900223 for Payment of NRC Review Fees of 10CFR50 Applications & 10CFR55 Svcs Per 10CFR170,for Period of 890101-0617 for Listed Invoices ML18022A7701990-02-14014 February 1990 Notifies of Issuance of Renewal of NPDES Permit for Plant. Permit Encl ML18009A3831990-02-0909 February 1990 Responds to 900112 Ltr Re Violation Noted in Insp Rept 50-400/89-35.Corrective Actions:Valves ICS-775 & ICS-776 Added to Inservice Insp Program for Back Seat & Full Flow Testing & ICS-525 Revised to Satisfy Tech Spec Requirements ML18009A3751990-02-0101 February 1990 Forwards Retyped Tech Spec Pages Re 890630 Application for Amend to License NPF-63 Concerning RCS Pressure Temp Limits ML18009A3701990-02-0101 February 1990 Informs That Planned Corrective Actions Re Violations Noted in Insp Rept 50-400/89-28 Will Not Be Completed Until 900301 IR 05000400/19890281990-02-0101 February 1990 Informs That Planned Corrective Actions Re Violations Noted in Insp Rept 50-400/89-28 Will Not Be Completed Until 900301 ML18009A3631990-01-26026 January 1990 Responds to NRC Bulletin 88-008, Thermal Stratification in Piping Connected to Rcs. Design Differences That Either Minimize Potential of Occurrence or Enhance Possibility of Detection Should Scenario Be Created at Plant Determined ML18009A3531990-01-25025 January 1990 Forwards Reactor Containment Bldg Integrated Leak Rate Test Conducted in Oct 1989.Util Believes That Packing Leaks Discovered Are Isolated Failures & That Repair Should Prevent Recurrence ML18009A3501990-01-22022 January 1990 Forwards Revised Tech Spec Table 3.7-6, Area Temp Monitoring, Per 891218 Tech Spec Amend Request ML18022A7591990-01-17017 January 1990 Submits Results of Aircraft Hazards Study Associated W/ Proposed Wakesouth Regional Airport & Facility ML20005G5731990-01-16016 January 1990 Forwards Response to Insp Rept 50-400/89-32.Encl Withheld (Ref 10CFR73.21) ML18009A3351990-01-0505 January 1990 Forwards Rev 16 to Vol 1,Part 2 of Plant Operating Manual PLP-201, Emergency Plan. Revised NUREG-0654 Comparison W/ Plant Emergency Action Level Flow Path Also Encl for Review ML18009A3171989-12-21021 December 1989 Responds to NRC 891108 Ltr Re Violations Noted in Insp Rept 50-400/89-21.Corrective Actions:Incident Reviewed by Both Plant & Nuclear Engineering Dept Personnel to Avoid Future Miscommunication ML18009A3181989-12-15015 December 1989 Forwards Retyped Amend Bar Pages to Tech Spec Table 3.3-3 Re Auxiliary Feedwater Manual Initiation,Per 891026 Application for Amend to License NPF-63 ML18009A3011989-12-15015 December 1989 Forwards Proprietary WCAP-12403 & Nonproprietary WCAP-12404, LOFTTR2 Analysis for Steam Generator Tube Rupture W/Revised Operator Action Times for Shearon Harris Nuclear Power Plant. WCAP-12403 Withheld (Ref 10CFR2.790(b)(4)) ML18022A7371989-12-13013 December 1989 Forwards Change 3 to Rev 2 to State of Nc Emergency Response Plan in Support of Shearon Harris Nuclear Power Plant, Incorporating Administrative Enhancements. W/One Oversize Encl ML18009A2971989-12-0808 December 1989 Responds to NRC 891108 Ltr Re Violations Noted in Insp Rept 50-400/89-23.Corrective Action:Min of Four Decontamination Personnel Will Be Assigned 24 H Per Day During Fuel/Cask Handling to Maintain Cleanliness in Fuel Handling Bldg ML18009A2841989-11-30030 November 1989 Forwards Rev 0 to Core Operating Limits Rept in Support of Cycle 3 Operations ML18005B1531989-11-27027 November 1989 Forwards Retyped Amend Bar Pages to 890630 Request for Rev to License NPF-63 Re RCS pressure-temp Limits ML18022A7311989-11-27027 November 1989 Forwards Response to Generic Ltr 89-21, Request for Info Re Status of Implementation of USI Requirements. ML18005B1511989-11-17017 November 1989 Forwards 15-day Special Rept Identifying Number of Steam Generator Tubes Plugged During Current Inservice Insp Period ML18005B1501989-11-13013 November 1989 Suppls 890403 Response to NRC Bulletin 88-010, Nonconforming Molded-Case Circuit Breakers. Addl Nontraceable Molded Case Circuit Breakers (MCCB) & MCCBs Traceable to Refurbishers Noted During Records Review 1990-09-06
[Table view] |
Text
- SYEGULATORY INFORMATION DISTRIBUTION BY~TEN (RIBS)
'ACCESSION NBR:8406040066 DOC ~ DATE: 84/05/29 NOTARIZED: NO
,FACIL:50-000 Shearon Harris Nuclear Power PlantF Unit 1~ Carolina 05000400 AUTH ~ NAME, . AUTHOR AFF ILIATION ZIMMERMAN~S,R, Carolina Power & Light Co ~
NOTES'OCKET RECIP ~ NAME RECIPIENT AFFILIATION DENTONaH ~ RE Office of Nuclear Reactor Regulationr Director
SUBJECT:
Forwards addi info re equipment qualification programiper 840321 requests Summary of radiation considerations for=,
equipment qualification in mild/harsh environs also CODE: A048S COPIES RECEIVED:LTR J "ENCL - SIZE; encl'ISTRIBUTION TITLE: OR/L'icensing Submittal: Equipment Qualification RECIPIENT COPIES REC IP IENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL NRR LB3 BC 12 1 0 BUCKLEYtB 01 1 1 INTERNALB ELD/HDS1 12 1 1 GC 13 1 IE FILE 09 1 1 NRR KARSCHrR 1 1 NRR/DE/EQB ,07 2 2 NRR/DL DIR 14 1 1 NR ORAB 06 1 1 NRR/DS I/AE8 1 1 F 00 1 1 RGN2 1 1=
EXTERNAL; ACRS 15 8 8 LPDR 03 1 1 NRC PDR 02 1 NSIC 05 1 1 NTIS 31 1 1 TOTAL NUMBER OF COPIES REQUIRED: LTTR 25 ENCL 2<I
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CMK Carolina Power 8 Light Company SERIAL: NLS-84-201 MAY 39 1984
.Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NO. 50-400 EQUIPMENT QUALIFICATION
Dear Mr. Denton:
Carolina Power & Light Company (CP&L) hereby submits one (l) original and forty (40) copies of additional information on the equipment qualification program for the Shearon Harris Nuclear Power Plant. This information is submitted in response to the equipment qualification issues discussed at the meeting held on March 21, 1984 between the Nuclear Regulatory Commission Staff and CP&L.
e Should you,have any questions with regard to this issue, please contact Mr. Pedro Salas at (919) 836-8015.
Yours very truly, S ~ mmerman Manager Nuclear Licensing Section PS/lcv (9957PSA)
Attachments: I) Additional Information II) Radiation Considerations for Equipment Qualification in Mild/Harsh Environments Mr. Goutam Bagchi (NRC-NRR/EQ) Mr. G. F. Maxwell (NRC-SHNPP)
Hr. B. C. Buckley (NRC-NRR/LB) Mr. J. P. O'Reilly (NRC-RII)
Hr. G. O. Bright (ASLB) Mr. Travis Payne (KUDZU)
Dr. J. H. Carpenter (ASLB) Mr. Daniel F. Read (CHANGE/ELP)
Hr. Wells Eddleman Mr. John D. Runkle Mr. J. L. Kelley (ASLB) Mr. J. N. Singh (EG&G)
Mr. Clarke Kido (EG&G) Dr. Richard D. Wilson Hr. Bob Legrange (NRC-NRR/EQ) Wake County Public Library Dr. Phyllis Lotchin Chapel Hill Public Library Hr. Armand Masciantonio (NRC-NRR/EQ) 411 Fayettevilte Street o P. O. Box 1551 ~ Raleigh, N. C. 27602 pa<
8406040066 840529 PDR ADOCK 05000400 A PDR
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ATTACHMENT I SHEARON HARRIS NUCLEAR POWER PLANT EQUIPMENT QUALIFICATION PROGRAM ADDITIONAL INFORMATION I. Valves Included in the Pum . and Valve 0 erabilit Review Issue: The Nuclear Regulatory Commission (NRC) Staff has requested that valves two inches and under be included in the pump and valve operability review.
Response: Carolina Power & Light Company (CP&L) will include valves two inches and under in the pump and valve operability review.
II. Documentation of E ui ment Reviewed Under the Mechanical E ui ment alification Pro ram Issue: The NRC Staff has requested that packages be prepared for all equipment reviewed under the mechanical equipment qualification program.
Response: Consistent with the preparation of packages for the Catawba audits, Carolina Power & Light Company will prepare packages for the equipment that the NRC selects for the audit. Carolina Power & Light Company feels packages are not necessary for all equipment since all documentation generated by this effort will be kept readily retrievable and available for audit. Quality Assurance (QA) records will be maintained in the QA vault on-site. Drawings used will be available from the document control system on-site. The system used to generate data on particular components or types of materials (e.g., activation energies, thermal degradation curves, etc.) will be maintained at the Architect/Engineer's (Ebasco) office through December, 1984 when the effort will be concluded and at the CP&L offices following that date.
III. Definition of Harsh Environment Issue: The NRC Staff has requested that an environment be considered harsh if the total integrated dose (TID) encompassing forty years installation during normal'plant operation and one year post-accident 4
installation, is greater than 10 rads.
Response: Carolina Power & Light Company's position on TID threshold for the definition of harsh environment is presented in Attachment II.
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IV. Acce tance of Vendor Su lied Re orts Issue: The NRC Staff has requested a description of CP&L's review and approval of vendor supplied reports.
Response: Carolina Power & Light Company has contracted its Architect Engineer (Ebasco) and its Nuclear Steam Supply System vendor (Westinghouse) to review, on its behalf, the reports supplied to them.
CP&L has reviewed and accepted the Ebasco and Westinghouse gA programs and has reviewed and accepted selected vendor supplied reports.
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ATTACHMENT II SHEARON HARRIS NUCLEAR POWER PLANT RADIATION CONSIDERATIONS FOR E UIPMENT QUALIFICATION IN MILD/HARSH ENVIRONMENTS CONTENTS Introduction Definition of Mild Environment Selection of Equipment Covered by 10 CFR 50.49 Determination of a "Radiation-Harsh" Environment Conservatism in the Radiation Environmental Conditions Conservatism of the Harris EQ Program II-1 (9957PSA/cf r)
I. Introduction On March 21, 1984, representatives of the Shearon Harris Nuclear Power Plant (SHNPP) Equipment Qualification Team met with representatives of the Nuclear Regulatory Commission (NRC) Equipment Qualification Branch.
The purpose of the meeting was to present and discuss Carolina Power &
Light Company's (CP&L's) Equipment Qualification Program for Shearon Harris Unit 1. During this. discussion, the NRC requested clarification on our methodology for determining and defining "mild environment" with respect to radiation dose. This report has been prepared to address CP&L's approach to this matter for SHNPP.
CP&L has used Section B, Regulatory Guide 1.89 (Revision 1, Draft) as a basis for equipment qualification radiation considerations. It reads as follows:
"The following are examples of considerations to be taken into account when determining the environment for which the equipment is to be qualified: (1) equipment outside containment would generally see a less severe environment than equipment inside containment; (2) equipment whose location is shielded from a radiation source would generally receive a smaller radiation dose than equipment at the same distance from the source, but exposed to its direct radiation; Electrical equipment to be qualified in a nuclear radiation environment should be exposed to radiation that simulates the conservatively calculated integrated dose (normal and accident) that the equipment should withstand prior to completion of its intended safety function."
CP&L's rigorous approach to radiation qualification, based on case-by-case qualification tests and analysis supported by tests or previous qualification information, assures the adequacy of equipment. This approach assesses the severity of radiation environments at locations where other environmental parameters are clearly mild. The same approach is applied 'to threshold values for solid state components. The methodology complies with NUREG-0588, including specific consideration of radiation effects in all plant areas, and does not generally exclude from consideration equipment exposed to a low radiation dose (i.e., below the sometimes considered negligible).
CP&L's approach to harsh environment radiation test consideration for SHNPP is consistent with an NRC staff response to public comments(*) on Proposed Regulatory Guide 1.89, Revision 1 wherein it was stated,
. The present position permits exemption of materials and equipment
Reference:
"Analysis of Public Comments" (response to Comment Nos. 74-83),
enclosure to Draft Revision 1 of Regulatory Guide 1.89, transmitted to J. C. Saldarini, Ebasco Services Incorporated, by USNRC letter dated November 14, 1983, from S. K. Aggarwal, EE Branch, Division of Engineering Technology, Office of Nuclear Regulatory Research.
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from qualification testing at any (dose) level if previous operating experience or previous qualification information can be provided which shows operability of the materials or equipment for the planned radiation environment."
Based on the conservatism applied in the derivation of the specified radiation parameters, a conservative program for selecting qualification methods and implementing these methods in the overall environmental qualification program as discussed herein, it is concluded that the SHNPP qualification methods established with respect to radiation considerations in environments considered to be mild provide an acceptable method for complying with NRC regulations with regard to accommodating the effects of environmental conditions.
II. Definition of Mild Environment The recent environmental qualification rule, 10 CFR 50.49 (hereafter called the EQ Rule), defines a mild environment as follows:
. an environment that would at no time be "si nificantl more severe" than the environment that would occur during normal power plant operation, including anticipated operational occurrences."
The definition does not require blanket exclusion from mild environment consideration all accident conditions that numerically exceed non-accident conditions. Rather it allows for considerations based on how and under what conditions the definition is applied.
CP&L has reviewed the available guidance pertaining to application of this definition, including material prepared before and after issuance of the EQ Rule (e.g., NRC presentations and workshops, IEEE and EPRI-NSAC documents). CP&L representatives have attended several recent seminars (e.g., EPRI-NSAC 1983 Seminars) and presentations (NRC/ACRS meeting December 1, 1983) where application of this definition was discussed.
CP&L has also reviewed in detail the latest available draft (November 9, 1983) of Regulatory Guide (RG) 1.89, Revision 1, and NRC's in-depth analysis of public comment, dated November 4, 1983, on proposed RG 1.89, Revision 1, containing a compilation of public comments and NRC staff responses.
Based upon this guidance, CP&L interprets the term "si nificantl more severe" (as incorporated in the NRC definition above) as follows:
"A mild environment may exceed the normal expected environment but does not expose the equipment to sudden or prolonged high-stress conditions during or following design basis events."
This clarification focuses on the intention of the SHNPP "harsh" environment qualification effort to review and evaluate the potential for equipment common-mode failures due to high stress from the environment, in accordance with'he prescribed methods required by the EQ Rule. This effort is preceded by a review of equipment locations and design capabilities to determine which equipment may be stressed in this manner.
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It is important to consider that since the EQ Rule, and even its precedent NUREG-0588, were issued during an advanced stage of the SHNPP program, environmental qualification including consideration of equipment aging was ongoing, or completed, for safety-related equipment in accordance with the General Design Criteria and RG 1.89, Revision 0.
This was documented originally in the PSAR, and subsequently in the FSAR, including reference to the industry standards being utilized.
The major impact of later NRC directives on environmental qualification has been on the extent to which documentation is submitted and/or made available to the NRC Equipment Qualification Branch for review and site audit. CP&L has been aware of the need for radiation qualification either by test or analysis and has included it in the SHNPP program dating as far back as issuance of IEEE 323-1971. Therefore, the SHNPP specifications and qualification plans included this requirement.
The initial task, then, in applying the EQ Rule to SHNPP, was to determine which equipment in the existing program was included under the scope of this rule.
III. Selection of E ui ment Covered b 10 CFR 50.49 The equipment selection process covers both equipment functions and equipment environments. Therefore, review and analysis other than those concerning environmental stress severity are clearly necessary to determine which equipment is covered by the EQ Rule. These tasks encompass most plant equipment in some manner and are subject to the quality assurance program requirements per 10 CFR 50, Appendix B. For example, some of the review processes involved are as follows:
A. E ui ment function durin desi n basis events safety system functions and the components which are relied on to remain functional are identified and segregated from those systems and components which do not have a safety application.
B. Nonsafet -related e ui ment this equipment is reviewed to determine if its failure under environmental conditions could prevent the accomplishment of safety functions.
C. Post-accident monitorin e ui ment this equipment is reviewed per the guidance in RG 1.97.
D. Establishment of environmental conditions the environmental conditions for safety-related equipment are determined for various plant operating conditions and design basis events.
E. Review of the severit of accident conditions the severity of the environmental conditions during/after the applicable postulated accident are assessed for safety-related equipment.
It should be noted that specific qualification information (i.e.,
documentation) is explicitly within the scope of the EQ Rule only for the equipment covered by the rule (refer to 10 CFR 50.49(d)). Therefore, II-4 (9957PSA/cfr)
with respect to environmental stress severity (i.e., significance of a change in equipment environmental conditions), it is CP&L's understanding that information supporting the case-by-case equipment assessment is one aspect of that specific qualification documentation.
k However, in conjunction with this assessment, CP&L recognizes an implicit concern in the EQ Rule regarding the methodology for determining the significance of environmental conditions for safety-related equipment.
As this methodology directly affects the scope of the rule, review by the Equipment Qualification Branch is warranted. In fact, the SHNPP project has allotted specific resources and schedule to the special "harsh" environmental qualification effort based on its understanding of the scope of the harsh environment environmental qualification review aqd audit. CP&L's 10 CFR 50.49 scope definition for SHNPP was carefully considered addressing the available guidance prior to the March 21, 1984 presentation given to NRC. Furthermore, CP&L is pursuing environmental qualification per the FSAR, regardless of whether favorable conditions are expected at the equipment location.
IV. Determination of "Radiation-Harsh" Environment With regard to the discussion at the March 21, 1984 meeting concerning the significance of radiation dose, the following considerations are applied for equipment at a location where other environmental conditions are clearly "mild":
A. It is noted that the SHNPP safety-related equipment design/purchase specifications have conservatively specified a total integrated dose (TID), encompassing forty years installation during normal plant operation and one year post-accident installation, as opposed to segregating a normal dose versus accident dose. Therefore it is appropriate to assess the equipment design capability based on TID, considering the available test data or analysis supported by tests.
This conservative approach provides assurance that components sensitive to low level doses are not excluded from radiation qualification testing. An alternative approach, such as assessing a harsh environment based on the percentage dose increase due to an accident, may not provide the same assurance at a location where the calculated normal dose is above a component's threshold dose.
Therefore, by specifying the TID, radiation conditions can essentially be considered as normal conditions (where other conditions are mild and within certain limits, as described in Item 2, below) ~
B. If the TID at the equipment locat)on, which includes gamma and beta contributions, is greater than 10 rads the environment is considered harsh (i.e., equipment qualification is covered by 10 CFR 50.49),
except under the following conditions:
- l. Equipment lo~ations exposed to a TID greater than 10 3 rads but less than 10 rads, which exclude critical semiconductor components and organic materials potentially sensitive in this II-5 (9957PSA/cfr)
range(*). Critical components or materials are those which are essential for performance of a safety function.
- 2. Equipment locations exposed to a TID greater than 10 3 rads but less than 10 rads, which include critical semiconductor components and potentially sensitive organic materials may be excluded based on qualification tests or analysis supported by tests indicating that the TID can be absorbed without serious degradation (i.e., the TID is well below the material capabilities) so that it does not place in substantial doubt the ability of the components to function.
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- 3. Shielded equipment locations may be excluded considering the appropriate shielding factors, provided the sum of the gamma and re)uced beta dose is (1) )0 rads, maximum, of (ii) greater than 10 rads but less than 10 rads and the equipment location satisfies condition B,l or B,2, above.
CP&L recognizes that the EQ Rule does not list specific values of environmental parameters, in part due to variations in equipment selection/qualificaton processes employed at specific plants, which includes different vintage plants. Therefore, CP6L has specified the above considerations in the qualification process for the Harris Plant.
The SHNPP methodology for addressing radiation conditions is more conservative than the position indicated by the industry and submitted to NRC by the Atomic Industrial Forum(**), which argues for exemption from radiation qualification based on threshold values, no matter how the equipment is applied or under what conditions.
The industry position is as follows:
"That equipment located in areas where total integrated gamma dose levels over the life of the plant or equipment including the post-accident doses do not exceed 10 5 rads (conservatively estimated to be one order of magnitude less than the threshold of detectable effects) should be exempt from requirements to demonstrate its radiation aging capabilities by type testing and/or analysis.
solid state electronic devices, the threshold level should be 10F~r rads gamma."
- EPRI Report NP 2129, dated November 1981, Radiation Effects on Organic materials in Nuclear Plants, provides a basis for assessing the sensitivity of materials listed in its Table 4-1, to doses in this range.
- Atomic Industrial Forum letter from R. M. Eckert to R. H. Vollmer, USNRC, dated August 24, 1982, transmitting a Nuclear Industry Position Paper on Radiation Considerations for Equipment Qualification.
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V. Conservatism in the Radiation Environmental .Conditions Dose values for 40 years normal operation were derived primarily. from previously established dose rates developed for plant shielding and personnel protection purposes (see Section 12.3 of the PSAR). Radiation source and equipment locations, shielding configurations, system and equipment operations were considered. Maximum dose values (based on assumptions of nuclide activities in the reactor coolant corresponding to 1.0 percent failed fuel, extreme of operation, etc.) rather than the average or expected dose rates (allowed in the introduction of Position 1.4 of NUREG-0588) are used. Thus, the calculated normal operations doses are conservatively high The DBA radiation exposure is predicted on assumed instantaneous release fractions of different classes of radionuclides from the core following the incipience of the accident. These assumptions are stated in NUREG-0588 and elsewhere (such as TMI document NUREG-0578 and NUREG-0737, and Regulatory Guide 1.4). Both beta 'and gamma doses to equipment were considered in arriving at a total dose for qualification purposes, including a one year post-DBA period following 40 years normal operations. Time-dependent radionuclide transport phenomena, such as plateout and washout (removal from the containment atmosphere by containment spray), were factored into the source term development, and hence, the dose calculations. Details of the methods and assumptions will be provided in the SHNPP environmental qualification submittal.
The assumption in NUREG-0588 of instantaneous release of radionuclides from the core coincident with the start of an accident is extremely conservative. There is ample evidence based on NRC and industry sponsored research (e.g., WASH-1400) to demonstrate substantial conservatism in the NRC assumption as follows:
C. The core cannot begin to melt, and thus release the bulk of its contained radionuclide inventory, for a time period on the order of 10 minutes, under the worst case accident scenario.
D. Even as the core meltdown begins all radionuclides would not be released at once but rather would be released over some extended period of time.
E. Different radionuclides would have different release rates. In addition, the chemical form of the fission products released from fuel is of equal importance to the percent that is released.
VI~ Conservatism of the Harris E Pro ram CP&L believes that the provisions of the EQ Rule allow for the considerations presented herein. The overall SHNPP environmental qualification program (harsh and mild environments) is a conservative one. If CP&L determines that an environment is harsh due to radiation dose alone, CP&L has strived to obtain a type test that includes preaging and operability under multiple environmental parameters,'ince criteria to address things such as combined environments are not well established. The NRC staff concurred with the conservatism of this II-7 (9957PSA/cfr)
approach at the March 21, 1984 meeting. Finally, under the SHNPP environmental qualification program no electrical equipment is automatically considered exempt from radiation testing, even that equipment which may be exposed to doses below those considered mild.
In addition, CP&L has often purchased equipment on a lot basis and qualified it for the worst case environment (i.e., in-containment design basis accident (DBA) environment, maximum duration, maximum performance ratings) regardless of various individual locations, to minimize the number of different plant components. Therefore many components located in environments considered mild are qualified for more severe conditions.
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