ML20002B715
| ML20002B715 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 10/09/1980 |
| From: | Cavanaugh W ARKANSAS POWER & LIGHT CO. |
| To: | Seyfrit K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| 1-100-03, 2-100-06, IEB-79-01B, IEB-79-1B, NUDOCS 8012220587 | |
| Download: ML20002B715 (4) | |
Text
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CENTRAL FILES PDR:MQ LPDR M
sk[h[f'N NSIC STATE ARKANSA WER & LIGHT COMPANY POST OFFICE BOX 559 4
'RDdk. AmtAlyiAgp203 [501)371-4422
$l 71[3%,CES WILLIAM CAVANAUGH 111 CL -
vice Prescent Genersoon & Constmcoon
' ,.;M October 9, 1980 1-100-03 2-100-06 Mr. K. V. Seyfrit, Director Office of Inspection & Enforcement U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive Suite 1000 Arlington, Texas 76011
Subject:
Arkansas Nuclear One - Units 1 and 2 Docket No. 50-313 & 368 Licensing No. DPR-51 & NPF-6 IE Bulletin 79-018 - Environmental Qualification of Class IE Electrical Equipment - Supplement 2 (File:
1510.6,2-1510.6)
Gentlemen:
By Memorandum and Order dated May 23, 1980, the Nuclear Regulatory Com-mission directed that the NRC Staff complete Jts review of environmental qualification of safety related electrical equipment and issue Safety Evaluation Reports for each plant by February 1,1981.
Further the Commission directed that by June 30, 1982, all safety-related electrical equipment in all operating power reactors shall be environmentally qualified to the 00R Guidelines or NUREG-0588.
To implement the Com-i mission's Order, on August 29, 1980, the NRC Staff issued orders in the dockets for Arkansas Nuclear One ("AN0"), Units 1 and 2, amending both ANO operating licenses to require that certain information on environmental qualifications be provided to the NRC Staff by November 1, 1980 (45 Fed. Reg. 60078 (September 11,1980))..Thereafter, on Sept-ember 19, 1980, the NRC Staff issued revised orders in these dockets l
specifying that the information required by November 1,1980, was tnat "information which fully and completely responds to the staff's request as specified in IE Bulletin 79-01B" (45 Fed. Reg. 65708 (October 3, 1980)). Thus, the information required to be submitted by AP&L by November 1,1980, was that specified in I&E Bulletin 79-018 dated Jan-uary 14, 1980, as modified by Supplement No. I to Bulletin 79-01B dated February 29, 1980.
8012220 %
Mr. K. V. Seyfrit October 9, 1980 AP&L embarked on an extensive effort to assemble the requested infor-mation and respond in a timely manner to Bulletin 79-01B, as amended by Supplement No.1, well before the Staff issued the orders in the ANO dockets. H ormation soughtgwever, in view of the lack of clarity as to the in-and the magnitude of work required to respond, it became apparent that AP&L and most (if not all) other NRC licensees could not comply with the response schedule originally set forth ir.
Bulletin 79-018. Accordingly, by letter dated June 23, 1980, AP&L proposed a plan and schedule for completion of a full response to the bulletin by December 31, 1980.
No response to this prorc4ed plan and schedule was received from the NRC Staff.
Upon Stuff issuance of the orders in the ANO dockets requicing a full response by November 1,1980, AP&L accelerated its plan and schedule to a.;sure that every effort would be expended to provide the information specified in Bulletin 79-01B, as amended by Supplement No.1, )y Nov-ember 1, 1980.
Against this background, AP&L is perplexed and concerned with the sign-ificant changes which the NRC Staff most recently sought to make in the scope of information required by November 1.
On September 30, 1980, the Staff issued Supplement No. 2 to Bulletin 79-01B in which it over-i roce the instructions contained in Supplement No.1, thereby requiring that significant additional information be provided by November 1.
Far example, Supplement No. 2 would require information relating to equip-ment installed as a result of TMI lessons learned activity.
This infor-mation was explicitly excluded in Supplement No.1 from the scope of information required by Bulletin 79-01B.
Another example involves the requirements relating to equipment neces-sary to achieve cold shutdown. Based upon Bulletin 79-01B, as amended by Supplement No.1, AP&L had planned to address the cold shutdown issue by providing justification that environmental qualification of such equipment is not needed to achieve a safe shutdown (i.e. hot shutdown) condition. This approach is consistent with Supplement No.1 (see A.3) i and the fact that the ability to achieve cold shutdwon using safety grade equipment was not a design re However, Supplement No. 2 (see A.1)quirement for either ANO reactor.
seems to eliminate the option contained in Supplement No I to justify that qualification of equip-ment needed to achieve cold shutdown is not required.
This signifi-cantly alters the scope of the evaluation to determine what equipment is required, in addition to a listing and evaluation of components.
AP&L was unaware of these attempts. to expand the scope of information to be reported by November 1 until it received Supplement No. 2 on 1
This lack of clarity as to the information sought prompted a series of " workshop" meetings between the NRC Staff and industry in July 1980.
These meetings " highlighted the fact that in some cases, the scope and depth of the 79-01B :
review was not clear to licensees." See Supplement No. 2 to Bulletin 79-018, at p.1 (September 30,1980).
Mr. K. V. Seyfrit October 9, 1980 October 2,1980. AP&L has evaluated the feasibility of providing this additional information by November 1, and has concluded that there is insufficient time remaining to do so.
In view of the foregoing, AP&L hereby requests that the November 1,1980, deadline for the submission of information sought in Supplement No. 2 be extended to January 1,1981. We assume that the NRC will be able to grant this request informally by letter.
If necessary to fulfill this request, however, the NRC Staff should treat this as an application, pursuant to 10 C.F.R. 50.90, to amend the opera AN0 plants to incorporate this schedule change,ging licenses for the and should handle the application on an expedited basis.
In order to avoid any misunderstanding, the following will sumarize AP&L's position. AP&L intends to provide the information requested in Bulletin 79-01B, as amended by Supplement No.1, by November 1,1980.
AP&L also will provide information by November 1,1980, reflecting the status of its efforts to provide the additional information required by Supplement No. 2.
However, AP&L requests that the deadline for submittal of the additional information required by Supplement No. 2 be extended to January 1, 1981.
An additional concern is that Supplement No. 2 would require that all spare parts used to replace installed parts must be qualified to IEEE 323-1974 "unless there are sound reasons to the contrary." Supplement No. 2 would establish the effective date of this requirement as May 23, 1980.
However, this position is contrary to the information contained in Supplement No.l.
Further, when industry sought clarification on this issue during the regional meeting in Dallas on July 27, 1980, the NRC Staff was unable to provide it.
In any event, we assume that the Staff is not attempting to impose the May 23, 1980, date on the AN0-reactors at this stage.
Certainly nothing contemplated in the orders issued by the Staff in the ANO dockets would support such a result.
Those orders required the submission of information, but did not impose technical requirements on the AN0 plants.
Such technical issues presumably will be the. subject of the forthcoming Safety Evaluation Reports for the AN0 reactors evaluating the adequacy of the environmental qualifications programs at ANO.
We note that the Staff orders issued in.the ANO dockets are basically requests for information. AP&L fully intends to comply with these orders.
Further AP&L will provide additional information sought by Supplement 2 by January 1, 1981 as discussed above.
Therefore, we see no point at this time in requesting a hearing on the requirement to submit information requested by Bulletin 79-01B, as amended by Supplement 1.
We are concerned, however, about the potential direction of the Staff's.
analysis of the cold shutdown issue in the context of plants such as -
ANO where, as noted, the achievement of cold shutdown using safety 2
Such amendments involve no significant hazards considerations, and as such may be issued by the NRC Staff without' publication of prior ' notice.
10 C.F.R. 2.105 and 50.91.
Mr. K. V. Seyfrit October 9, 1980 grade equipment was not a design requirement. We are also concerned about other technical aspects of the environmental qualifications issue, such as the qualification of " spare" and " replacement" parts.
Accordingly, we explicitly reserve our right to request a hearing at the appropriate time on the technical ~ aspects and merits of any design modifications which may be imposed on AP&L by the NRC Staff.
We are continuing to give this matter our highest attention and priority.
ery trul' yours,
[- - D William Cavanaugh II ~' WC:DH:pw .}}