ML060950215

GALL AMP: X.E1. Environmental Qualification (EQ) of Electric Components (Audit Worksheet GALL Report AMP)

ML060950215
Person / Time
Site:	Vermont Yankee
Issue date:	03/22/2006
From:	Morgan M NRC/NRR/ADRO/DLR/RLRC
To:	Office of Nuclear Reactor Regulation
morgan M NRR/NRC/DLR/RLRC, 415-2232
Shared Package
ML060950189	List: ML060950195 ML060950215 ML060950218 ML060950220 ML060950224 ML060950235 ML060950250 ML060950258 ML060950262 ML060950269 ML060950271 ML060950277 ML060950279 ML060950284 ML060950290 ML060950301 ML060950311 ML060950323 ML060950328 ML060950331 ML060950347 ML060950351 ML060950356 ML060950364 ML060950370 ML060950372 ML060950375 ML060950540 ML060950549 ML060950559 ML060950567 ML060950570 ML060950573 ML060950579 ML060950582 ML060950587 ML060950596 ML060950606 ML060950610 ML060950620 ML060950624 ML060950629 ML060950632 ML060950634 ML060950637 ML060950645 ML061000078 ML061000090 ML061000096 ML061000101 ... further results
References
%dam200611, TAC MC9668
Download: ML060950215 (10)

Text

AUDIT WORKSHEET GALL REPORT AMP PLANT: ______________________________

LRA AMP: __________________________ REVIEWER: ______________________

GALL AMP: X.E1, Environmental Qualification (EQ) of Electric Components DATE: __________________________

Program Auditable GALL Criteria Documentation of Audit Finding Element A. The reanalysis of an aging evaluation is normally performed Consistent with GALL AMP: Yes No Program to extend the qualification by reducing excess conservatism Document(s) used to confirm Criteria:

Description incorporated in the prior evaluation. Reanalysis of an aging evaluation to extend the qualification of a component is performed on a routine basis pursuant to 10 CFR 50.49(e) as part of an EQ program. While a component life limiting condition Comment:

may be due to thermal, radiation, or cyclical aging, the vast majority of component aging limits are based on thermal conditions. Conservatism may exist in aging evaluation parameters, such as the assumed ambient temperature of the component, an unrealistically low activation energy, or in the application of a component (de-energized versus energized).

The reanalysis of an aging evaluation is documented according to the station's quality assurance program requirements, which requires the verification of assumptions and conclusions. As already noted, important attributes of a reanalysis include analytical methods, data collection and reduction methods, underlying assumptions, acceptance criteria, and corrective actions (if acceptance criteria are not met).

B. All operating plants must meet the requirements of Consistent with GALL AMP: Yes No 10 CFR 50.49 for certain electrical components important to Document(s) used to confirm Criteria:

safety. 10 CFR 50.49 defines the scope of components to be included, requires the preparation and maintenance of a list of in-scope components, and requires the preparation and X.E1 Environmental Qualification (EQ) of Electric Components 1

Program Auditable GALL Criteria Documentation of Audit Finding Element maintenance of a qualification file that includes component Comment:

performance specifications, electrical characteristics, and the environmental conditions to which the components could be subjected.

C. 10 CFR 50.49(e)(5) contains provisions for aging that Consistent with GALL AMP: Yes No require, in part, consideration of all significant types of aging Document(s) used to confirm Criteria:

degradation that can affect component functional capability.

10 CFR 50.49(e) also requires replacement or refurbishment of components not qualified for the current license term prior to the end of designated life, unless additional life is established Comment through ongoing qualification.

D. 10 CFR 50.49(f) establishes four methods of demonstrating Consistent with GALL AMP: Yes No qualification for aging and accident conditions. Document(s) used to confirm Criteria:

Comment E. 10 CFR 50.49(k) and (l) permit different qualification criteria Consistent with GALL AMP: Yes No to apply based on plant and component vintage. Supplemental Document(s) used to confirm Criteria:

EQ regulatory guidance for compliance with these different qualification criteria is provided in the DOR Guidelines, Guidelines for Evaluating Environmental Qualification of Class 1E Electrical Equipment in Operating Reactors; NUREG-0588, Comment Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment; and Regulatory Guide 1.89, Rev.

1, Environmental Qualification of Certain Electric Equipment Important to Safety for Nuclear Power Plants. Compliance with 10 CFR 50.49 provides reasonable assurance that the component can perform its intended functions during accident conditions after experiencing the effects of inservice aging.

F. EQ programs manage component thermal, radiation, and Consistent with GALL AMP: Yes No cyclical aging through the use of aging evaluations based on Document(s) used to confirm Criteria:

10 CFR 50.49(f) qualification methods. As required by 10 CFR 50.49, EQ components not qualified for the current X.E1 Environmental Qualification (EQ) of Electric Components 2

Program Auditable GALL Criteria Documentation of Audit Finding Element license term are to be refurbished, replaced, or have their qualification extended prior to reaching the aging limits Comment established in the evaluation. Aging evaluations for EQ components that specify a qualification of at least 40 years are considered time-limited aging analyses (TLAAs) for license renewal.

G. Under 10 CFR 54.21(c)(1)(iii), plant EQ programs, which Consistent with GALL AMP: Yes No implement the requirements of 10 CFR 50.49 (as further defined Document(s) used to confirm Criteria:

and clarified by the DOR Guidelines, NUREG-0588, and Regulatory Guide 1.89, Rev. 1), are viewed as aging management programs (AMPs) for license renewal. Reanalysis of an aging evaluation to extend the qualification of components Comment under 10 CFR 50.49(e) is performed on a routine basis as part of an EQ program. Important attributes for the reanalysis of an aging evaluation include analytical methods, data collection and reduction methods, underlying assumptions, acceptance criteria, and corrective actions (if acceptance criteria are not met). These attributes are discussed in the "EQ Component Reanalysis Attributes" section.

H. This reanalysis program can be applied to EQ components Consistent with GALL AMP: Yes No now qualified for the current operating term (i.e., those Document(s) used to confirm Criteria:

components now qualified for 40 years or more). As evaluated below, this is an acceptable AMP. Thus, no further evaluation is recommended for license renewal if an applicant elects this option under 10 CFR 54.21(c)(1)(iii) to evaluate the TLAA of EQ Comment of electric equipment.

A. The reanalysis of an aging evaluation is normally performed Consistent with GALL AMP: Yes No to extend the qualification by reducing excess conservatism Document(s) used to confirm Criteria:

EQ incorporated in the prior evaluation. Reanalysis of an aging Component evaluation to extend the qualification of a component is Reanalysis performed on a routine basis pursuant to 10 CFR 50.49(e) as Attributes part of an EQ program. While a component life limiting condition Comment may be due to thermal, radiation, or cyclical aging, the vast majority of component aging limits are based on thermal X.E1 Environmental Qualification (EQ) of Electric Components 3

Program Auditable GALL Criteria Documentation of Audit Finding Element conditions. Conservatism may exist in aging evaluation parameters, such as the assumed ambient temperature of the component, an unrealistically low activation energy, or in the application of a component (de-energized versus energized).

The reanalysis of an aging evaluation is documented according to the station's quality assurance program requirements, which requires the verification of assumptions and conclusions. As already noted, important attributes of a reanalysis include analytical methods, data collection and reduction methods, underlying assumptions, acceptance criteria, and corrective actions (if acceptance criteria are not met).

B. Analytical Methods: The analytical models used in the Consistent with GALL AMP: Yes No reanalysis of an aging evaluation are the same as those Document(s) used to confirm Criteria:

previously applied during the prior evaluation. The Arrhenius methodology is an acceptable thermal model for performing a thermal aging evaluation. The analytical method used for a radiation aging evaluation is to demonstrate qualification for the Comment:

total integrated dose (that is, normal radiation dose for the projected installed life plus accident radiation dose). For license renewal, one acceptable method of establishing the 60-year normal radiation dose is to multiply the 40-year normal radiation dose by 1.5 (that is, 60 years/40 years). The result is added to the accident radiation dose to obtain the total integrated dose for the component. For cyclical aging, a similar approach may be used. Other models may be justified on a case-by-case basis.

C. Data Collection and Reduction Methods: Reducing excess Consistent with GALL AMP: Yes No conservatism in the component service conditions (for example, Document(s) used to confirm Criteria:

temperature, radiation, cycles) used in the prior aging evaluation is the chief method used for a reanalysis. Temperature data used in an aging evaluation is to be conservative and based on plant design temperatures or on actual plant temperature data. Comment When used, plant temperature data can be obtained in several ways, including monitors used for technical specification X.E1 Environmental Qualification (EQ) of Electric Components 4

Program Auditable GALL Criteria Documentation of Audit Finding Element compliance, other installed monitors, measurements made by plant operators during rounds, and temperature sensors on large motors (while the motor is not running). A representative number of temperature measurements are conservatively evaluated to establish the temperatures used in an aging evaluation. Plant temperature data may be used in an aging evaluation in different ways, such as (a) directly applying the plant temperature data in the evaluation, or (b) using the plant temperature data to demonstrate conservatism when using plant design temperatures for an evaluation. Any changes to material activation energy values as part of a reanalysis are to be justified on a plant-specific basis. Similar methods of reducing excess conservatism in the component service conditions used in prior aging evaluations can be used for radiation and cyclical aging.

D. Underlying Assumptions: EQ component aging evaluations Consistent with GALL AMP: Yes No contain sufficient conservatism to account for most Document(s) used to confirm Criteria:

environmental changes occurring due to plant modifications and events. When unexpected adverse conditions are identified during operational or maintenance activities that affect the normal operating environment of a qualified component, the Comment affected EQ component is evaluated and appropriate corrective actions are taken, which may include changes to the qualification bases and conclusions.

E. Acceptance Criteria and Corrective Actions: The reanalysis Consistent with GALL AMP: Yes No of an aging evaluation could extend the qualification of the Document(s) used to confirm Criteria:

component. If the qualification cannot be extended by reanalysis, the component is to be refurbished, replaced, or requalified prior to exceeding the period for which the current qualification remains valid. A reanalysis is to be performed in a Comment timely manner (that is, sufficient time is available to refurbish, replace, or requalify the component if the reanalysis is unsuccessful).

1. Scope of A. EQ programs apply to certain electrical components that are Consistent with GALL AMP: Yes No X.E1 Environmental Qualification (EQ) of Electric Components 5

Program Auditable GALL Criteria Documentation of Audit Finding Element Program important to safety and could be exposed to harsh environment Document(s) used to confirm Criteria:

accident conditions, as defined in 10 CFR 50.49 and Regulatory Guide 1.89, Revision 1.

Comment

2. Preventive A. 10 CFR 50.49 does not require actions that prevent aging Consistent with GALL AMP: Yes No Actions effects. EQ program actions that could be viewed as preventive Document(s) used to confirm Criteria:

actions include (a) establishing the component service condition tolerance and aging limits (for example, qualified life or condition limit) and (b) where applicable, requiring specific installation, inspection, monitoring or periodic maintenance actions to Comment:

maintain component aging effects within the bounds of the qualification basis.

3. Parameters A. EQ component qualified life is not based on condition or Consistent with GALL AMP: Yes No Monitored/ performance monitoring. However, pursuant to Regulatory Document(s) used to confirm Criteria:

Inspected Guide 1.89, Rev. 1, such monitoring programs are an acceptable basis to modify a qualified life through reanalysis.

Monitoring or inspection of certain environmental conditions or component parameters may be used to ensure that the Comment:

component is within the bounds of its qualification basis, or as a means to modify the qualified life.

4. Detection of A. 10 CFR 50.49 does not require the detection of aging effects Consistent with GALL AMP: Yes No Aging Effects for in-service components. Monitoring or inspection of certain Document(s) used to confirm Criteria:

environmental conditions or component parameters may be used to ensure that the component is within the bounds of its qualification basis, or as a means to modify the qualified life.

Comment:

5. Monitoring A. 10 CFR 50.49 does not require monitoring and trending of Consistent with GALL AMP: Yes No and Trending component condition or performance parameters of in-service Document(s) used to confirm Criteria:

components to manage the effects of aging. EQ program actions that could be viewed as monitoring include monitoring how long qualified components have been installed. Monitoring or inspection of certain environmental, condition, or component Comment:

parameters may be used to ensure that a component is within X.E1 Environmental Qualification (EQ) of Electric Components 6

Program Auditable GALL Criteria Documentation of Audit Finding Element the bounds of its qualification basis, or as a means to modify the qualification.

6. Acceptance A. 10 CFR 50.49 acceptance criteria are that an inservice EQ Consistent with GALL AMP: Yes No Criteria component is maintained within the bounds of its qualification Document(s) used to confirm Criteria:

basis, including (a) its established qualified life and (b) continued qualification for the projected accident conditions.

10 CFR 50.49 requires refurbishment, replacement, or requalification prior to exceeding the qualified life of each Comment:

installed device.

B. When monitoring is used to modify a component qualified life, Consistent with GALL AMP: Yes No plant-specific acceptance criteria are established based on Document(s) used to confirm Criteria:

applicable 10 CFR 50.49(f) qualification methods.

Comment:

7. Corrective A. If an EQ component is found to be outside the bounds of its Consistent with GALL AMP: Yes No Actions qualification basis, corrective actions are implemented in Document(s) used to confirm Criteria:

accordance with the station's corrective action program. When unexpected adverse conditions are identified during operational or maintenance activities that affect the environment of a qualified component, the affected EQ component is evaluated Comment:

and appropriate corrective actions are taken, which may include changes to the qualification bases and conclusions. When an emerging industry aging issue is identified that affects the qualification of an EQ component, the affected component is evaluated and appropriate corrective actions are taken, which may include changes to the qualification bases and conclusions.

Confirmatory actions, as needed, are implemented as part of the station's corrective action program, pursuant to 10 CFR 50, Appendix B. As discussed in the appendix to this report, the staff finds the requirements of 10 CFR Part 50, Appendix B, acceptable to address the corrective actions.

8. A. Confirmatory actions, as needed, are implemented as part of Consistent with GALL AMP: Yes No X.E1 Environmental Qualification (EQ) of Electric Components 7

Program Auditable GALL Criteria Documentation of Audit Finding Element Confirmation the station's corrective action program, pursuant to 10 CFR 50, Document(s) used to confirm Criteria:

Process Appendix B. As discussed in the appendix to this report, the staff finds the requirements of 10 CFR Part 50, Appendix B, acceptable to address the confirmation process.

Comment:

9. A. EQ programs are implemented through the use of station Consistent with GALL AMP: Yes No Administrative policy, directives, and procedures. EQ programs will continue to Document(s) used to confirm Criteria:

Controls comply with 10 CFR 50.49 throughout the renewal period, including development and maintenance of qualification documentation demonstrating reasonable assurance that a component can perform required functions during harsh Comment:

accident conditions. EQ program documents identify the applicable environmental conditions for the component locations. EQ program qualification files are maintained at the plant site in an auditable form for the duration of the installed life of the component. EQ program documentation is controlled under the station's quality assurance program. As discussed in the appendix to this report, the staff finds the requirements of 10 CFR Part 50, Appendix B, acceptable to address the administrative controls.

10. Operating A. EQ programs include consideration of operating experience Consistent with GALL AMP: Yes No Experience to modify qualification bases and conclusions, including Document(s) used to confirm Criteria:

qualified life. Compliance with 10 CFR 50.49 provides reasonable assurance that components can perform their intended functions during accident conditions after experiencing the effects of inservice aging. Comment:

X.E1 Environmental Qualification (EQ) of Electric Components 8

EXCEPTIONS Item Program Elements LRA Exception Description Basis for Accepting Exception Documents Reviewed Number (Identifier, Para.# and/or Page #)

1.

2.

ENHANCEMENTS Item Program Elements LRA Enhancement Description Basis for Accepting Enhancement Documents Reviewed Number (Identifier, Para.# and/or Page #)

1.

2.

DOCUMENTS REVIEWED DURING AUDIT Document Number Identifier (number) Title Revision and/or Date 1.

2.

3.

4.

X.E1 Environmental Qualification (EQ) of Electric Components 9