ML19290C061
| ML19290C061 | |
| Person / Time | |
|---|---|
| Issue date: | 05/28/1979 |
| From: | Hanauer S Office of Nuclear Reactor Regulation |
| To: | Mattson R Office of Nuclear Reactor Regulation |
| References | |
| REF-GTECI-A-24, REF-GTECI-IS, TASK-A-24, TASK-OR NUDOCS 8001090108 | |
| Download: ML19290C061 (32) | |
Text
\\/
ck MAY 2 81979
,q-k d.
e a
MEMORANDUM FOR: Roger J. Mattson, Director Division of Systems Safety, NRR FROH:
S. H. HHnauer, Assistant Director for Plant Systems, Division of Systems Safety
SUBJECT:
ORGANIZATION 90 IMPROVE MANAGEMENT OF EQUIPMENT ENVIR0tNENTAL AND SEISMIC QUALIFICATION REVIEWS In an effort to improve our work on environmental and seismic qualification of safety related equipment, I roccamend a minor reorganization be sede githin the ADPS organization. The change will permit a better nanaged review of cases and generic Task A-24. The branches affected are ICSB and PSB. The plan is to l
form two sections in PSB for (1) electrical and (2) mechanical and qualification.
I believe the changes will serve to concentrate the review effort, perform the l
required contract management, coordinate qualification efforts with other branches j
(MEB, SEB, CSB, RSB, and ASB) and provide the necessary support to the Seismic Qualification Review Team effort. The enclosure sets forth the scope of work, i
alternatives with pros and cons, and my recommendation.
/g DISTRIBUTION:
NRR READING FILE j l
i CENTRAL FILE PS READING BH E tan e r for Plant Sp m Division of Systems Safety
Enclosures:
Discussion of Organization Equip. Environ'1 & Seismic Qual. Casework
& Generic Rvws A&ble I, Manpower Req'd to do Equip. Qual. Job, ICSB & PSB Table II, Comparisons of Manpwr Allocations Appendix A, PSB, Mech. & Qual. Section-Appendix B, PSB, Electric Pwr Section cc:
F. Schroeder 1730 158 R. Satterfield F. Rosa V. Benaroya C. Long R. Tcdesco J. Knight B. Grenier DSS:PS:AD SHHanauer 5/ /79 8001090 407 i
s' ENCLOSURE Discussion of Organization
~
Equipment Environmental and Seismic Qualification Casework and Generic Reviews S. H. Hanauer May 22,1979 Scope The environmental qualification review effort has been carried out by ICSB and PSB with support from MEB, AAB, RSB, CSB, and ASB.
For plants conforming to IEEE-323-1971, individual reviewers in each branch include environmental qualification in the'r work.
In addition, generic task action plan A-24 is a separate effort to resolve the qualification issue for plants conforming to b.'
Experience has shown that our fragmented approach has created both internal and external problems in performing reviews and completing the work in a timely manner.
This proposal would place our total effort into one section and thereby provide for improved line management, more consistrat interpretation and application of acceptance criteria, single point coordination with other branches and more effective management of technical assistance contracts.
Manpower A projection of environmental qualification estimated mar. power requirements is given in Table I.
The work effort in PSB and ICSB is similar in many respects and has been aggregrated.
The work effort for ASB is not included.
- The seismic qualification technical review is done primarily in MEB and SEB; the work included here is intended to represent what ICSB and PSB are already doing.
1730 159
-2 The manpower projection does not include the technical assistance on ICSB environmental qualification being provided by ORNL at a current level of 2 M yr/ year. The projection does include the manpower required to administer this ORNL contract.
Also, the manpower projection does not include the PSB case review assistance being provided by ORNL at a FY 80 level of 4 M yr/ year which currently includes assignment to the ORNL reviewers of environmental qualification within the PSB scope.
Organization Alternatives In the following paragraphs, three alternative organizations are discussed.
Table II shows the manpower requirements of each, based on the total FY 80 For the reorganiza' ion alternatives (2 and 3),
t requirements of Table I.
allocations are shown for both the present overall limit of 31 people in (ICSB & PSB).
An increased limit should be considered, based on adding the additional manpower I believe will be needed for the projected workload.
This increase, and TMI add-ons, are not included in Table II.
Alternative 1.
Present Method Individual reviewers in ICSB and PSB include environmental and seismic qualification in their case reviews, including applicable portions of topical reports. Task action plan A-24 is currently being done separately with the Task Manager being a member of ICSB. Therefore, environmental qualification for lead plants being reviewed using IEEE-323-1974 is not being done by the case reviewers in ICSB and PSB.
To do the work, one would have to assign 2 reviewers in PSB and 3 in ICSB to equipment qualification.
With all vacancies filled, and present staffing limits, that would leave 10 reviewers in PSB and 10 in ICSB for 1730 160 t
e.
work outside equipment qualification. These would not be "whole bodies,"
since qualification would be part of each case review. Today, only about 1 reviewer (equivalent) in PSB and 1 in ICSB are working on qualification.
Pro Minimum disruption Minimum staff requirements Con Work is not getting done Non-uniformity of reviews Line management is inadequate Conclusion - Needs to be improved.
Alternative 2.
New Section in ICSB Form a third section in ICSB to deal with the overall environmental and seismic qualification effort. This would require es,tablishment of a new Section - Chief position. The 4 professionals in the section would include people in varicus disciplines.
PSB professionals would descrease by 2; these people, already doing qualification reviews., would transfer to the new section in ICSB.
ICSB non-qualification reviewers would remain the same or increase by 1 if we got an extra position for the new section leader.
To make the change today, PSB would transfer 1 professional and 1 vacancy to ICSB for the new section; ICSB would transfer 1 professional and 2 vacancies (including 1 section/ leader position) to the new section.
These would be "real people," not fractions of all the re.iewers.
1730 161
Pro Continuity of reviews and implementation of acceptance criteria Uniformity of reviews Provides for central source of manpower for 00R assistance, SQRT team efforts and IE efforts Provides for centralized coordination of efforts from other NRR branches to accomplish the qualification effort.
Con Additional work for branch chief of a heavily impacted branch Reviews involve some skills not really relevant to the expertise O '.',
of many ICSB personnel Most of the equ.ipment involved is in PSB's area of review responsibility 4.
Would require assigning personnel without I&C background who could only be used in the single effort of environmental qualification review Will require 1 additional section leader compared to alternate 1.
Conclusion - Marginally acceptable Alternative 3.
New Section in PSB one dealing with electrical power and one combining Form two sections in PSB:
the present PSB mechanical review areas and the environmental and seismic The members of the new section would be a suitable mix qualification area.
of people with various specialties, including mechanical, electrical, instrumentation, and materials.
This would require two new section leaders in PSB, plus transfer of 3 If the total number of (ICSB & PSB) qualification reviewers from ICSB to PSB.
1730 162
-5 s
positions remained constant, that would leave 10 non-qualification reviewers in ICSB, as in the other alternatives, but the number of non-qualification reviewers in PSB would decrease by one to 9.
If we get an extra position or two for the new section leaders, the decrease (which I do not favor) would not be necessary.
Pro PSB needs section leaders to assist branch chief, thus reducing the workload of the chief of a heavily impacted branch.
Environmental qualification and mechanical reviews involve some of the same skills, but electrical / instrument expertise is also involved.
C,'
Most of the equipment involved is in PSB's area of review responsibility Provides for central source of manpower for D0R assistance, SQRT team efforts and IE efforts Provides diversity of work tasks for the personnel assigned to the new section Position descriptions may be made broader and therefore the positions easier to fill Provides for centralized coordination of efforts from other NRR branches to accomplish the qualification effort Con Requires additional staff position compared to Alternatives 1 and 2, because of the increased management manpower.
Conclusion - Acceptable; preferred alternative 1730 163
4.
The other alternatives listed below were considered, but seemed less desirable than the three discussed above:
Separate branch New Section in ASB Putting ASB "outside containment environment envelope" with the ICSB/PSB work 5.
ASB Scope No reorganization or additional staffing is needed for ASB in connection with this proposal. A draft work plan for equipment qualification review of ASB systems is under consideration.
l . '-
6.
Conclusion I recommend implementing alternative 3.
Its cost is small 2 additional managers compared to the present arrangement - and is well worth its benefits.
The principal gain is the additional management attention thus made available for qualification work, as well as for both mechanical and electrical power systems reviews in PSB.
1730 164 4
TABLE I Manpower Required to do Equipment Qualification Job
- ICSB and PSB FY79+
FY80 FY81**
9 14 3
Case Reviews Dependent on Topical Reports 1.5 2
1.5 Task Action Plan A-24 Management 6
5.5 3
Contract Administration 3
3 3
00R SEP Support Manpower IEEE 323-1971 Casework (includes support to DOR) 4 10 5
4 8
10 IE_E 323-1974 Casework 1
2 2
Research Coordination 1
1 2
Standards and SRP development 2
2 0
IE Bulletin Responses Commission, F0IA and General Correspondence 2
2 2
33.5MM 49.5MM 31.5MM Total
- These manpower projections do not include technical assistance on casework or Generic issue A-24.
- The estimates for FY81 are believed to be lower than actual requirements because casework delayed for FY79 and 80 will increase the load.
- These figures for FY79 are Pre-TMI.
1730 165
TABLE II COMPARIS0N OF MANPOWER ALLOCATIONS Person - Years Per Year Component
- 1. Present
- 2. Add'1
- 3. Form Method Section Sections on ICSB in PSB Requirements for Environmental Qualification Professionals to do the work in Table I 4.5 4.5 4.5 Manpower Allocation ICSB Professionals Equip. Qual.
3 4,
0, Total 13 14 10 Managers 3
4 3
Secretarial 1
1 1
L '. _'
PSB -
Professions)
Equip. Qual.
2 0,
4, Total 12 10 13 Managers 1
1 3
Secretarial 1
1 1
Total ICSB and PSB 31 31 31
+ Assumes constant total strength, all vacancies filled, in (ICSB & PSB) -
in reality, additional manpower authorization may be available.
1730 166 s
APPENDIX A POWER SYSTEMS BRANCH MECHANICAL SYSTEMS AND QUALIFICATION SECTION
~
~
May 22, 1979 '
~
Functional Statement _
The section is responsible to the Power Syster, Branch Chief for the review, and evaluations of the functional capability of certain auxiliary systems and components related to electric power production and emergency power systems and the environmental and seismic qualification programs for all electrical power, instru-mentation and control equipment. These review areas cover systems and components needed for safe plant operation and safe shutdown during normal, transient and accident conditions as described in applications for Construction Permits, Standard Plant Design Approvals and Operating Licenses for nuclear power plants p.-
~
The section to as'sure public health and safety and protection of the environment.
performs studies and analyses of technical issues within the branch's area of review.
PERFORMANCE REQUIREMENTS 1.
Performs licensing case reviews.
Evaluates the design of certain auxiliary systems and components, a.
as proposed in Safety Analysis Reports, from the standpoint of functional capability, integrity and systems operation under normal plant operation and for safe plant shutdown during normal, transient and accident conditions.
Specifically, the following are analyzed and examined to assure compliance with NRC regulations and other safety criteria derived from these regulations as identified in the Standard Review Plan, Regulatory Guides and Industry Standards and Codes.
1730 167 A-1
A-2 (1) The design bases, features and performance criteria, including applicants' analyses and postulated accidents and operational occurrences that support the adequacy of the design ba.ses, of the auxiliary systems and the technical areas listed.
This work includes:
(a) Emergency Diesel Auxiliary Systems; (b) Main Steam Supply System (beyond outer MSIV);
(c) Turbine Generator; (d) Main Condenser; (e) Turbine Bypass System; p;..,'
(f) Turbine Speed Control and Overspeed Protection Systems (i)
The applicants' calculational procedures and the analytical models used to verify system performance.
(ii)
The need for and establishment of preoperational and start-up t'esting programs for systems and components.
(iii) The plant's technical specifications concerning the suitability of the safety limits, limiting safety systems settings, and the limiting conditions for operations; and the adequacy of the frequency and scope of periodic surveillance requirements.
(2) The seismic and environmental equipment qualification test criteria and programs used to verify design adequacy related to all electrical power, instrumentation and control equipment.
b.
In performing reviews, drafts questions and positions or requests meetings with the applicant through the Licensing Project Manager to 1730 168
A-3 obtain additional or clarifying information, and to resolve incon-sistencies in interpretation of safety criteria.
Prepares reports of technical evaluations and recomended actions for inclusion ir. the Safety Evaluation Report by the Licensing Project Manager.
Performs independent calculations and analyses to confirm or verify c.
applicants' prediction,s of systems and component performance under postulated transient and accident conditions.
d.
As identified in the Standard Review Plan, provides technical data and assistance in the areas described above to technical reviewers in other branches who need this information in the conduct of their reviews.
C' :.
Performs on-site technical audits of applicants' plant designs for selected
- e.
systems in the branch's area of responsibility to observe "as built" implementation of NRC safety criteria, f.
Prepares responses and makes presentations to the Advisory Committee on Reactor Safeguards and upper management on significant technical issues, concerns, or positions developed on licensing cases.
Assists in the preparation and presentation of testimony to be g.
presented at public hearings to describe and support technical analyses, evaluations, and positions developed in licensing cases.
2.
Performs Topical Report reviews.
Evaluates Topical Reports submittd by reactor vendors, architect-a.
engineering firms, and major component manufacturers on safety-relatad subjects in the branch's area of review and in accordance with applicable sections of the Standard Review Plan.
1730 169
A-4 b.
Obtains adjit;onal infewtion and coordinates with other technical review branches as may be needed for the review of these reports.
Prepares and submits a report containing the evaluation and the recommended c.
NRC position regarding the acceptability of.such reports.
Performs studies of technical issues and problems of limited scope and 3.
normal complexity within the branch's area of review.
Prepares reports containing technical bases and recommended positions.
Ir. some cases, these positions are incorporated into other major technical studies which result in modifications to the Standard Review Plan, or may later be used as basis for Regulatory Guides and Commission Regulations.
O ~;
' Reviews and provides comments and reconinendations on Regulatory Guides and 4.
Industry Standards developed by or forwarded from the Office of Standards Development.
5.
Provides technical assistance to the Division of Operating Reactors on significant safety matters within the branch's area of responsibility that affect operating reactor plants.
Particip'ates on research review groups to provide licensing input and 6.
monitor the progress of research programs; recommends changes in research programs necessary to meet licensing needs.
Provides technical assistance to the Office of Inspection and Enforcement, 7.
the Office of Nuclear Material Safety and Safeguards and the Office of International Programs on matters which fall into the branch's area of responsi-bility or employee's area of technica cognizance.
1730 170
A-5 Identifies the need for technical assistance which can be obtained under 8.
contract, develops appropriate work scope, and provides technical management of contracts.
Assists in the selections of contractors as part of Source Evaluation 9.
Boards.
Drafts correspondence and reports in response to inquires received from 10.
members of Congress, other Federal Agencies, state and local governments, and from the general public.
1730 171 O
e 9
I
APPENDIX B POWER SYSTEMS BRANCH _
ELECTRIC POWER SECTION Functional Statement The section is responsible to the Power Systems Branch Chief for the reviews and evaluations of the functional capability of electric power systems and components including related instrumentation and controls. These review areas cover systems and components needed for safe plant operation and safe shutdown during normal, transient and accident conditions as described in applications for Construction Permits, Standard Plant Design Approvals and Operating Licenses for nuclear power plants to assure public health and safety and protection of the environment. The Section performs studies and analyses of technical issues within
'the branch's area of review.
PERFORMANCE REQUIREMENTS 1.
Performs licensing case reviews.
Evaluates the design of electric power systems and components a.
including related instrumentation and control, as proposed in Safety Analysis Reports, from the standpoint of functional capability, integrity, and systems operation under normal plant operation and for safe plant shutdown during normal, transient and accident conditions.
Specifically, the following area analyzed and examined to assure com-pliance with NRC regulations and other safety criteria derived from these regulations as identified in the Standard Review Plan, Regulatory Guides, and Industry Standards and Codes.
1730 172 B-1
B-2 (1) The design bases,' design and performance criteria and the systems features of electric power systems and components including related instrumentation and control for the following systems and technical areas summarized below:
a.
Offsite Power Systems; b.
A-C Power System (Onsite);
D-CPowerSystem(Onsite);
c.
d.
Emergency Communication Systems; Turbine Speed Control and Overspeed Protection Systems; and e.
f.
Electric Power / Fire Protection Interface Oi
The review of these systems encompasses the sensors, initiating circuits, logic elements, power supplies, distribution circuitry, bypasses, interlocks, redundancy and diversity features, actuated devices, wiring, cables, raceways, monitoring systems and alarms.
(2) The applicant's analyses of the limiting conditions of operation, postulated accidents, operational occurrences, and failure modes and effects.
(3) The need for and establishment of preoperational and start-up testing programs for electric power systems and components including related instrumentation and control.
(4) The plant's technical specifications concerning the suitability of the safety limits, limiting safety system settings, and the limiting conditions for operations; and, the adequacy of the frequency and scope of periodic surveillance requirements for electric power systems and components including related instrumentation and control.
1730 173
B-3 b.
In performing reviews, drafts questions and positions or requests meetings with the applicant through the Licensing Project Manager to obtain additional or clarifying information needed to resolve inconsistencies in interpretation of safety criteria.
Prepares reports of technical evaluations and recomended actions for inclusion in the Safety Evaluation Report by the Licensing Project Manager.
Performs independent calculations and engineering analyses to confirm c.
or verify applicants' predications of systems and component performance under postulated transient and accident conditions.
d.
As identified in the Standard Review Plan, provides technical data and
- e. -
assistance in the areas described above to technical reviewers in other branches who need this information in the conduct of their reviews.
Performs on-site technical audits, of the applicant's plant designs for e.
selected systems in the branch's area of responsibility to observe "as built" implementation of NRC safety criteria.
f.
Prepares responses and makes presentations to the Advisory Committee on Reactor Safeguards and upper management on significant technical issues, concerns, or positions developed on licensing cases.
Assists in the preparation'and presentation of testimony to be presented at g.
public hearings to describe and support technical analyses, evaluations, and positions developed in licensing cases.
1730 174
B-4 2.
Performs Topical Report reviews, Evaluates Topical Reports submitted by reactor vendors, architect-a.
engineering firms, and major components manufacturers on safety-related sut3jects in the branch's area of review and in accordance with applicable sections of the Standard Review Plan.
b.
Obtains additional information and coordinates with other technical review branches as may be needed for the review of these reports.
Prepares and submits a report containing the evaluation and the recommended c.
NRC position regarding the acceptability of such reports.
3.
Performs studies of technical issues and problems of limited scope and normal C 0-complexity within the branch's area of review.
Prepares reports containing technical bases and recommended positions.
In some cases, these positions are incorporated into other major technical studies which result in modi-
~
fications to the Standard Review Plan, or may later be used as bases for Regulatory Guides and Commission Regulations.
4.
Reviews and provides coments and recommendations on Regulatory Guides and Industry Standards developed by or forwarded from the Office of Standards Development.
5.
Provides technical assistance to the Division of Operating Reactors on significant safety matters within the branch's area of responsibility that affect operating reactor plants.
Participates on research review groups to provide licensing input and monitod 6.
the progress of research programs; recommends changes in research programs necessary to meet licensing needs.
1730 175
B-5 7.
Provides technical assistance to the Office of Inspection and Enforcement the Office of Nuclear Materials Safety and Safeguards and the Office of Inter-national Programs on matters which fall into the branch'; area of responsibility or employee's area of technical cognizance.
Identifies the need for technical assistance which can be obtained under 8.
contract, develops appropriate work scope, and provides technical management of contracts.
Assists in the selection of contractors as part of Source Evaluation Boards.
9.
- 10. Drafts correspondence and reports in repsonse to inquiries received from members of Congress, other Federal Agencies, state and local governments, and p;.-
'from the general public.
1730 176 9
6
.};
[ fkuna:c. v w
XF n,.. u n...n, s,, : m
.ae,.s.s y
f/f A
5
?
0 &ff f'
EQUDPMENT QUADE:DGTUON e
~
~'
AN UPDATED VIEW FROM THE
< / >',
/
.r l '
. e 7 J< c UTILITY PERSPECTIVE 7-
),+ s -
t A <S t
M.D. Su'ouff PRESENTED AT ANS 25TH ANNUAL CONVENTION J UN E,1979 ATLANTA, GEORGIA b
Washington Public Power Supply System 3000 George Washington Wav Richland. Washington 99352 mmg og 3 yg e e M e M M ir L 1730 177
.s,-
EQUIPMENT QUALIFICATION-AN UPDATED VIEW FROM THE UT
-1 M. D. Sulouff Washington Public Power Supply System Richland, Washington Abstract For about four years, WPPSS has been heavily involved in equipment qualification as it relates to qualifying Class IE Electrical /I&C and interfacing mechanical equipment.
WPPSS's early involvement included establishing a position with IEEE 323-1974 and implementing a program to satisfy this position.
The program has evolved around the changing documentation requirements issued by regulatory agencies with res ect to equipment qualification.
Due to early efforts to' establish an equipment qualification program and have it in place when necessary, direct schedule imp 6ct on the WPPSS projects has been relatively low.
The cost impact has not been low, however.
The estimated costs for five nuclear power plants for this program are 136,000,000.
and reducing these costs whenever possible.WPPSS has been actively involved in The equipment qualification issue can be solved when maximum attention is directed by utilities, A/Es and vendors to sharing knowledge, insurin that documentation is available to utilities, and forming owners groups,g when possible, to share costs.
Introduction To Ecuioment Qualification-What Is It?
A definition of the term, equipment qualification, is contained in IEEE 323-1974.,A take off from that definition is:
Equipment qualification is the documenting that electrical equipment important to plant safety and the safety of the public (Class IE equipment) will function during normal, abnormal, or postulated accident conditions.
An important paint to emphasize is that equipment qualification does not simply include subjecting the equipment to the effects of temperature, pressure or humidity.
It includes insuring that the equipment will perform in.the presence of all postulated service conditions; including seismic.
The type of qualification used depends on the equipment to be qualified.
The types ~ of equipment which compose a nuclear power plant are many.
They-include mechanical and electric components.
Equipment qualification principles in this discussion will apply primarily to ISC/ electrical equipment.
1730 178 e
1
What types of equipment are required to be qualified?
i Typical types are:
o Large Mainsteam and Feed Water isolation valves.
o Switch gear.
o Motor Control Centers.,
o Dry-type transformers.
o Battsrier, battery chargers.
o Diesel Generator Control equipment.
This list may seem small until it is recognized that these major " blocks of equipment" contain components which are also necessary to be qualified in order to ensure that the equipment block can perform its safety function under the service conditions postulated.
When all of the 4,000 pieces of equipment per unit must be listed and undergo qualifi f components are taken into account, WPPSS has found that in excess of cation as well as be tracked for replacement and periodic maintenance.-
This list may ct. nge from plant to plant and utility to utility.
It appears to be.however, representative.
All of this equipment must be subjected to a qualification process to be considered qualified with respect to the definition.
There are essential elements, however, of qualification which can be obtained by interpre-tation of IEEE 323-1974 and other more specific standards. These elements ~
appear to be the " basics" which must be addressed by the qualifier:
1)
Identification of Ecuipment and Its Application - This includes an equipment description; including manufacturer's model number, methods of mounting and interfaces with other equip-ment (e.g., connections to piping).
2)
Preparation of a Qualification Program - The essential elements of any qualification program should include:
Identification of potential aging mechanisms.
Development of a qualification plan.
Implementation of the qualification plan.
Determination of the qualification status (e.g., pass / fail).
3)
Documentation of the Program - The qualification plan, test results and other data necessary to substantiate qualification should be provided.
There are general methods used to ensure that Class IE equipment is in fact qualified according to the definition.
These methods are analysis, combined analysis / test and type testing.
Generally, type testing or combined analysis / testing is used to qualify active, Class IE I&C/ electrical equipment.
The qualification methods expose the equipment to the postu-lated service conditions.
The common tests used to simulate service conditions mentioned in IEEE 323-1974 are:
1730 179 2
1)
Aging - Them:al and mechanical conditioning of the devices using any method described above.
2)
Radiation - Exposure of the device (s) to an actual radiation source is generally the technique used; alt; hough analysis is growing in popularity as more data is gained with respect to the effects of radia-tion on e'quipment functions.
3)
Seismic Forces - All qualification methods are commonly used to expose the device to the required response spectras.
4)
Ooeration Cycling - The device's safety function (e.g., valve actuator unit closes during a postulated DBE) should be checked during and after exposure to the postulated event.
5)
Design Basis Event (DBE) Qualification - If it is possible that the equipment could be exposed to LOCA conditions during operation, it will generally be subjected to those same simulated conditions usir.g type testing.
The data obtained and the subsequent ability of the device to perform its safety function after completion of the qualification program will determine the qualification status of the device (s).
This brief dis-cussion has brushed the subject of equipment qualification and what it is.
The next aajor point is--Hcw did we get into all of this?
Background-Why are we nerforming eouipment oualification?
b Equipment qualification is not such a recent issue as some may think.
The issue has about a ten-year history.
It is useful to look at the events which occurred to gain a better perspective on why we are doing what we are.
The events occurred in the following sequence:
1)
IEEE 279 was issued in 1971 - Section 4.4 of that standard, contained the worcs, " equipment qualification".
The standard also required that the " range of energy supply" be addressed as well as requiring the system's minimum perfomance functions be analyzed or te;,ted to assure functionality during postulated conditions.
2) 10 CFR 50.55a endorses IEEE 279-1971 - Making it a requirement in the cesign of nuclear power plants.
3)
IEEE 323-1971 Issued, Aoril 1971 - This standard required environmental qualification of Class IE equipment located in containment but did not specifically require aging of equipment.
1730 180 3
y.
4)
Other similar standards issued - The industry prepared guides for the qualification of major components such as Electric Valve Operators, Motors and Cables.
This occurred primarily 2
in 1971 and 1972.
The seismic qualification of those components was also addressed by IEEE-344-1971, issued during this period.
5)
The industry issued IEEE 323-1974 for trial use on February 28, 1974 - Unanimous approval of revision 7 was provided by the IEEE1 standards board.
For the first time, an IEEE standard specifically required aging and sequential qualification of Class IE electrical /I&C equipment.
The standard was basically derived from and based on IEEE 323-1971.
6)
Industry tries to interoret the agina reouirements of IEEE 323-1974. -
During 1974 and 1975 the major areas of change from the 1971. version of IEEE 323 were noted by the industry; especially the requirement for aging equipment.
There was a lack of sufficient utility knowledge and information to enable all groups to implement effective. age qualification programs.
Many positions were proposed by companies to the NRC.
The NR_C stated that the industry had established the standard and
.Should be willino to acice oy it., in July,1975 NPEC issued a position statement to be included in the for.iard of IEEE standard 323-1974 which attempted to clarify the aging issue.
7)
Utilities orcanize in small consortiums-1975 throuch 1976 - To establish a position statement to IEEE 323-1974.
Many.of them, including WPPSS, viere trying to establish positions in their PSAR's with respect to the standard.
The basic problem appeared to be that the state-of-the-art had not advanced sufficiently to allo.i the aging requirement to be implemented.
8)
ACRS (Advisory Co. mittee on Reactor Safeauards) tries to interpret the radiation source tem in IEEE 323-1974 ;Regu-latory Guide 1.89 was issued for corraent in 1975.
The source term definition provided in the guide caused considerable controversy.
This was due to the assumption that the worst case fuel meltdown would occur and release of gasses was.to be based on that condition.
The Regulatory Guide also endorsed IEEE 323-1974.
The NRC continued trying to specify a suffi-ciently conservative radiation tem in a simple manner so as to eliminate the need for detailed radiation dose calculations.
9)
Qualification standards issued based on IEEE 323-1974, 1974 through 1976 - IEEE Standards were issued to provide informa-tion on how to qualify major equipment such as Electrical Penetration assemblies (IEEE 317-1976), Class IE motors (IEEE 334-1974), and Class IE Electric Cables (IEEE 383-1974).
IEEE 344-1975 was issued during this period.
1730 181 4
..,./.
/
/
10)
Reculatorv Guice 1.89. " Qualification of Class IE for Euciear Pcuer Piants" was issued in Novemoer auioment that a conservative radiation source term be t
, 1974 - Tliis required qualification of Class IE equipment.
red in the 11)
Various utilities such as WPPSS establis PSAR's on how they planned to meet IEEE
~
n their used position was that the applicant would comply with IEEE 323-1974 A widely 323-1974 to the extent that the state-of-the-art allowed implementation of the aging criteria.
12)
_C_onnectors fail Sandia lab's LOCA testino - In Augus testing on connectors.results were received frca Sandia labs electrical connectors, typical of signal carrying conn purchased according to IEEE-323, had failed the LOCA test programs for environmental qualification.
results, it was found that most of the tested electrical From the test and conductor-to-ground resistance. connectors exhibite r
tendency of electrical wires to rub against sh the connector.
ners of 13)
U_nion of Concerned Scientists (UCS) petitioned Conare the NRC to take "emercency and remedial action" rec ss and
_ connector failures - The Union of Concerned Scientists peti-ardina the in November,1977tioned the NRC to ".... halt further failure of Cl They also addressed the question of fire equipment"
- protection.
several utilities to conduct qualification of connec ensure that they would meet the sequential testing require
~^
ments of ~ IEEE 323-1974.
14) flRC issues recuirements for aoolications imolementing IEE and IEEE 344-1975 -
plans and test procedures used to qualify Class I I&C equipment be provided to the staff for review prior to th formal submittal of the FSAR.
all the Class IE equipment.
They also required a list of e
15) state that they will comply when the data is a 16)
Utilities provide reouested information 1 submit test plans and test procedures to the NRC.Mid 1978'- Utilities require summaries of the equipment qualificat
_ Due to the also reference a Standard Question No. 4.
They the documentation required to ensure that C o
is qualified.
ent 1730 182 5
Standard Quastion No. 4 requires surr. aries of test results for Class IE equipment not subject to a DSA with progressively 1
more information required for equipment subject to a DBA.
17)
NRC issues IE circular 78-08,tiav 31, 1978. - This circular states thn documented oualification was found to be inade-quate in many cases.
The NRC emphasized that items such as-connectors, penetrations, terminal blocks, limit switches, and
, ca'ble splices should have qualification documentation.
No written response to the circular was required..
- 18) U?PSS and other utilities meet with the NRC to clarify Standard Ouestion No. 4 and how tney plan to qualify eouipment -
1978 Throucih 1979 - Ucilities caet with the NRC to discuss and propose programs to meet IEEE 323-1974 and Regulatory Guide 1.89..
- 19) UPPSS and other utilities necotiate with NSSS sucoliers and
, Balance-of-Plant ecuiomant vendors to establish acceptable cualification programs - 1978 Through 1979 - Utilities were working witn the NSSS vendors to establish an equipment qualification program.
Negotiations were also held between the utilities and the individual balance-of-plant equipment vendors to establish acceptable qualification programs.
20)
Tnree Mile Island incident occurs March 28, 1979 - All facts are certainly not in from the incident, but it does appear that the environmental qualification of equipment will be further studied to determine if the present qualification procedures are adequate; in light of the incident.
A reviefv of the evolution of equipment qualification, covers a span of approximately ten years.
It starts out with the industry trying to define what equipment qualification is, and continues with NRC, indus-tries and utilities trying to further define the type of qualification documentation acceptable.
Today, we find vendors have the capability to qualify a larger per-centage of the plant equipment.
Current Status of the WPPSS Equioment Qualification Program The WPPSS approach to equipment qualification consists of:
ensuring th'at :.he Class IE electrical /I&C equipment meets the intent o
of the "WPPSS Acceptance Criteria for Class IE Qualification".
o Documenting that fact.
~
Providing sufficient information to the NRC to minimize time for o
the operating license and also to establish that the e,quipment is, in fact, qualified.
} / 3()
]83 6
./.
i The. approach W?PSS is taking to equipment qualification cons following steps:
s of the 1)_
An information report has been prepared which states the positi of the Supply System on environmental and seismic equipmen on cation, provides a basic sample of the types of equipment to be qualified, discusses the qualification methodology and also pro example summaries of major equipment qualification programs Docume.tation required by Standard Question No. 4 along with th required format is also provided in the information report report is applicable to both UNP 1/4 and WNP 3/S projects and will This be submitted to the NRC for review.
2)
W?PSS is anticipating that the NRC will review the information the documentation contained is acceptable. report and con 3)
WPPSS will then incorporate comments from this information and submit section 3.10, " Seismic Qualification of Seismic C Instrumentation and Electrical Equipment," and 3.11 Design of Mechanical and Electrical Equipment," of the FSAR Environmental will reference summary reports on types of equipment qualificatio
, which The Summary Report will describe the safety function perform the equipment, the manufacturer and model number of the equipm the qualification plan methodology, summary of test results 'a d
- ent, references to detailed documentation available for audits n
summaries will then be referenced in SRP 3.10-3, 4 and SRP 311-2 These 3, and 4.
4)
WPPSS has established means to ensure that the equipment is in f quali5ied.
and correct qualification of equipaant before award act contract implementation and prior to-contract closecut.
The thrust of this program is to qualify Class IE equipment documentation and to summarize that documentation for
, to obtain without impact on the WPPSS projects, however.This WPP
_Eauipment Oualification Procram Impact on WPPSS Projects Equipment qualification is'a licensing issue and c~auses impact in several areas.
These are:
o Schedule.
o Cost.
Engineering design changes.
o The impact of these factors is different for each project due to va requirements between the projects.
rying For example, WNP-2 is meeting IEEE 323-1971, while WNP-1/4 and 3/S must
/
naet the IEEE 323-1974 criteria.
1730 184 7
./
~~
~
I:
Schedule Imoact
.1 The schedule impact on WNP-2, the WPPSS E'.G olant, occurs primarily due to an increase in the ahof eq0ipnent quihfitction documentation license (OL). review necessary to be completed prior to the issuance of the ope J
For WNP 1/4 and WNP 3/5 projects, the schedule impact is not a signifi cant issue.
It could be in the future, however, when delays in equip-ment sh'pping become necessary due to a qualification program not being comple'.ed.
testing; which would delay equipment shipping.The potential also e
~
Schedule impact is not the only problem facing WPSSS with respect to equipment qualification.
In addition, costs to qualify equipment and to ensure that documentation is available to prove qualification are significant.
Cost Imoact The equipment qualification costs for the WPPSS projects can be catego-rized into four major areas:
Obtaining equipment qualification documentation.
o Review of equipment qualification documentation for adequacy.
o Additional costs for qualification programs.
o HSSS vendor qualification.
c WNP-2 is being licensed under the criteria of IEEE 323-1971.
One of the problems facing WPPSS right now, is to obtain the necessary documentation with respect to the seimic and environmental qualification to meet that criteria. ' In some cases, documentation was submitted by the vendors but exists in the form of a certificate of compliance rather than a. full j
qualification test report.
The estimated cost to obtain the existing docu-p//
mentation ranges between 5100,000 to $150,000.
g, gf/
The review of existing documentation and that which is being obtained by y.e/"
4+/
..(
the process mentioned above is also costly.
It is estimated that $200,000 will be spent in engineering time reviewing the qualification documen-tation to ensure adequacy.
Should any equipment require requalification or should it be necessary to replace that equipment, it is estimated that that cost would be $500 to $1 million.
These costs include man hours, installation and vendor g
charges.
This cost could be much higher depending on the type of
[
requalification or replacement requirements.
Overall, it is estimated that the costs for WNP-2 will approach one to two million dollars in the equipment qualification area.
WNP-2 is not alone in the costs.
additional costs for equipment qualification.WNP-1/4 and 3/5 are also accruing 1730 185 8
.(
For WXP-1/4 and 3/5, the criteria is different.
323-1974 apply.
In these plants, the requirements of IEEE No. 4, which requires submittal of selected test resultsIn addition, NRC St t
additional data with respect to equipment qualification, is also a
, sua:naries and requirement.
It is estimated that the additional costs for new qualification progr t
to meet IEEE 323-1974 per Class IE' contract. requirements run approximately $100 000 to S500 000 l
mentation and electrical equipment contracts existing on WN
(
3/5, is estimated that the total qualification cost will be $10 toh
$25 million.
This cost consists of several major items.
0, s
Thes,e are:
Response to Standard Question No. 4.
o Upgrading NSSS vendor qualification programs to meet IEEE o
requirements'.
323-1974 On-going qualification costs. [ d o
The additional costs for qualification programs related to IEEE exist mainly in the addi.ional paper work and testing which the vendor 323 1974 is required to perform to qualify a device.
the Class IE, in-containment device on one contract was approxima three times the cost of an outside containment Class IE d same manufacturer and model number.
Class IE, outside containment cent in the same location and the percentage diffe increasing; not decreasing.
f results and data be submitted to the h2C staff for revi quotes fr,om various consultants and WPPSS internal estimates indicate Recent that it will cost approximately $150 to $200,000 marize qualification plans, tests and also to provide the information in per project to sum-the fonnat requested.
The total cost for WNP-3/5 and 1/4 would $400,000 for both projects.
The other are equipment qualification programs.a of major cost increase is in the NSSS
/
~
On WNP-1/4 and 3/5, WPPSS prefers the approach of requiring the vend kUd M to type test and provide a qualified life approaching 40 p uA approach is also being negotiated with the NSSS vendors. years.
This is estimated that the t For WNP-1/4 it pj qualification program. otai ' cost will approach $3 million for this pra
$6 to $10 million total cost.The WNP-1/4 program is WPPSS' share of an estimated gg7 being used for WNP-3/5.
A combined analysis / testing approach is 510 million will be sp For this project, it is estimated that $5 to qualification program.ent in the initial qualified life and on-going to reduce the costs of equipment qualification.Many utilities are fonning own The total costs related to equipment qualification, for all projects at WPPSS appears to be around 535 million.
This figure is conservative.
1730 186 9
/
WPPSS Involvement in Equioment 0:alification-Waat Are We Doina About It?
q WPPSS believes that the most effective way of solving equipment qualifi-cation problems, reducing costs and meeting the licensing requirements is to get actively involvad.
There are three main activities which WPPSS conducts, related. to equipment qualification.
These are:
o Generic activities '
o interface with vendors o
d6cumentation activities Generic activities are those which are applicable to all WPPSS projects.
An example of generic activity is:
developing an initial position on IEEE 323-1974 with respect to aging.
The generic activities are primarily perfomed by an organization in engineering which monitors equipment qualification activities on the projects.
A project equipment qualifi-cation engineer for each project handles the general day-to-day equipment qualification activities relating to that project.
Another type of generic activity is the development of the WPPSS standard specification for equipment qualification.
The standard specification has several major benefits.
These consist of allowing the buyer to include costs for replacement 6f equipment in the bid evaluation; xhh1-would penalize vendors with a 1cw qualified life, allowing the buyer to BgN evaluate tne quality of tne vendor s equipe.t gliallrication program
%,g, prior to contract award and allcuing vendors to respond to buyer's specific equipment qualification requirements when bidding.
% ( #N3 In another, similai generic activity, WPPSS has held NRC meetines to fim up equipment qualification requirements and to discuss' responses to those requirements with the staff.
Other generic activities are participation in equipment qualification work with EPRI, IEEE corr:nittees and other industry associations.
A very important generic activity is to insure that Class IE spare parts / maintenance procedures consider aspects of equipment qualification (e.g., on-going qualification)..
The primary means for insuring that equipment qualification requirements get implemented is to take steps which ensure that the vendor building that equipment understands those requirements.
WPPSS gets heavily involved with the architect engineer and vendors in the implementation of vendor's equipment qualification programs.
Reviews of the program are conducted as they are received and discussions are held with vendors to ensure that the "WPPSS Class IE Equipment Qualification Acceptance Criteria" is met.
Meetings with the vendor then take place to review the test results and resolve anomolies.
~The only real result of equipment qualification is the production of documentation which ensures that the equipment installed in the plant
' will perform its safety function during all postulated service conditions.
To accomplish this, WPPSS maintains files systems and a computerized record tracking, system.
1730 187 10
l l
Enginee.-ing working files are used which contain the equipment qualifi-catio.. plans, test results, and correspondence solely relating to q
equipment qualification.
Project files, controlled through Quality Assurance procedures, are also available at each site containing the same iafomation.
All infomation related'to equipment qualification such as correspon-dance, plans and test results,' is logged on a computerized sort to provide instant recall of information related to equipment qualification.
One of the requirements of Standard Quastion No. 4 is to provide a list of Class IE equipment; another activity related to documentation.
WPPSS prepares Class IE equipment lists, in conjunction with the architect /
engineer, which contain equipment qualification related data.
This list will be used by operations, by the NRC, and by engineering to be able to ascertain the qualification status of a particular piece of Class IE instrumentation / elect'rical equipment.
Items such as the equipment's safety function, qualified life, location, type of seismic qualification perfomed and type of environmental qualification perfomed are examples of infomation included in the Class IE equipment list.
Ecuipment Ocalification-The Future This paper has examined the past, present status and how WPPSS has been involved in equipment qualification.
It is anticipated that the future.
of equipment qualification will be less concerned with the technical problems of qualification and more concerned with ensuring that documentation is available to prove qualification.
The Three Mile Island plant incident and its effect on equipment quali-fication is unknown at the present time.
The investigation results could cause additional requirements related to equipment qualification.
- The equipment qualification documantation problem can be solved by utilities, 'A/Es and other consultants sharing data necessary to meet equipment qualification requirements.
For example, the Licensing Information Service (LIS) of NUS is starting an organization to provide data to meet 78-08 circular and 79-01 bulletin.
LPK1 has task Torces to discuss solutions to tne equipment qual 1T1 Cation problem and to produce a data base containing aging mechanisms of materials and equipment.
Work is also underway by Sandia, Wyle, and other test labs to develop aging libraries containing information on the materials' aging mechanisms.
Test labs and others are also developing qualification methods for complex electronic systems.
Surnary Equipment qualification to meet both technical and documentation require-ments, is becoming more and more complex and costly.
It appears that, however, the nuclear industry is on the " knee" of the learning curve.
e 1730 188 11
./
p
/
This means that the industry is beginning to be able to quclify certain types of equipment to the necessary requiremants.
Considerable sums of money are being invested in qualification and documentation of that qualification.
More and more utilities, vendors, consultants and architect engineers are working together to reduce the equipment quali-fication costs and problems.
This.is being accomplished by sharing documentatica, costs and knowledge.
In spite of'the different goals, requirements, and schedules, we must continue 'dcnin the path of encouraging the various groups building nuclear power plants to get on with the job and solve the equipment qualifi-cation problem.
References:
1.
Sgicification Recuirements for Qualification, by Newell S. Porter, WP?SS, Paper Presented at Three Day Course, Drexel University.
2.
" Washington Public Power Supply System Equipment Qualification Program For Class IE Instrumentation and Electrical Equipment for WNP 1/4 and 3/5 Projects - Information Report," WPPSS Document Mc. -0025.
3.
" Regulatory Guide 1.70, Standard Format and Content of Safety Analysis Report for Nuclear Power Plants - LWR Edition," Revision 3.
4.
" Regulatory Guide 1.89, Qualification of Class IE. Equipment for Nuclear Power Plants."
5.
Standard Question on Environmental Qualification of Class IE Equipment, (PSB Standard Quastion No. 4), (ICSB Review Reminder Ho'. 32, Rev. 1).
6.
"IEEE 323-1974, IEEE Standard for Qualifying *.~. lass IE Equipment for Nuclear Power Generating Stations".
i730 189-W D
S e
12