ML20035C861

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Responds to 930122 Reply Discussing NRC Notification of Potential Deficiency in Environ Qualification of Electrical Cables W/Bonded Jackets
ML20035C861
Person / Time
Issue date: 03/30/1993
From: Russell W
Office of Nuclear Reactor Regulation
To: Rasin W
NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT &
References
IEIN-92-081, IEIN-92-81, NUDOCS 9304090156
Download: ML20035C861 (3)


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March 30, 1993 Mr. William H. Rasin Vice President and Director Technical Division Nuclear Management and Resources Council 1776 Eye Street, N.W.

Suite 300 Washington, D.C.

20006-2496

Dear Mr. Rasin:

I am responding to your January 22, 1993, reply in which you discussed the U.S. Nuclear Regulatory Commission's (NRC's) notification of a potential deficiency in environmental qualification of electrical cables with bonded jackets.

Specifically, you addressed the NRC's proposed actions for bonded jacket electrical cables as discussed in NRC Information Notice (IN) 92-81,

" Failure of Electrical Cables with Bonded Hypalon Jackets."

We appreciate NUMARC and NUGEQ working together to resolve this issue. NUGEQ will obtain useful information on this issue from its poll of its members to determine those instances in which bonded jacket electrical cables in plant locations where service conditions exceed the equivalent of 50 *C (122 *F) for 40 years. However, you have not established a schedule in which to complete the poll or the assessment.

We do not think that this assessment should wait until the Sandia National Laboratories completes its test report. As stated in the letter of December '22, 1992, the NRC asked if NUMARC would coordinate the industr.

effort to resolve this issue, since we believe that these generic actions are independent of plant-specific actions associated with IN 92-81.

The staff agreed to meet with NUMARC and representatives of the industry on this topic at Sandia.

Each licensee is responsible to review the applicability of IN 92-81 for its plant (s) and consider necessary actions as appropriate.

Thus, in IN 92-81, the NRC referenced Generic Letter (GL) 88-07, " Modified Enforcement Policy Relating To 10 CFR 50.49, ' Environmental Qualification of Electrical Equipment Important to Safety for Nuclear Power Plants.'" The notice referenced the letter to remind licensees of the implications of the generic letter in relation to the information notice.

In GL 88-07, the NRC stated When a potential deficiency has been identified by the NRC or licensee in the environmental qualification of equipment (i.e., a licensee does not have an adequate basis to establish qualification), the licensee is expected to make a prompt determination of operability (i.e., the system or component is t

capable of performing its intended design function), take immediate steps to establish a plan with a reasonable schedule to correct the deficiency, and have written justification for continued operation, which will be available for NRC review.

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Mr. William H. Rasin March 30, 1993 The licensee may be able to make a finding of operability using analysis and partial test data to provide reasonable assurance i

that the equipment will perform its safety function when called i

upon.

In this connection, it must also be shown that subsequent failure of the equipment, if likely under accident conditions, will not result in significant degradation of any safety function or provide misleading information to the operator.

In GL 88-07, the NRC gave the licensees guidance on actions to be taken for equipment declared inoperable because of environmental qualification results, including shutting down the plant until the problem is corrected.

The licensees would also have to determine whether their findings are reportable.

If you have any questions, please contact Mr. Conrad McCracken at (301) 504-2873.

ORIG!NAL S"3HED BY W. T. RU23 ELL William T. Russell, Associate Director for Inspection and Technical Assessment Office of Nuclear Reactor Regulation DISTRIBUTION Central file SPLB File WRussell AThadani GHolahan CMcCracken LKokajko ADummer JTatum SJones HGarg PShemanski

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l' Mr. William H. Rasin The licensee may be able to make a finding of operability u 'ng analysis and partial test data to provide reasonable assu nce that the equipment will perform its safety function whe called upon.

In this connection, it must also be shown that ubsequent failure of the equipment, if likely under accident

nditions, will not result in significant degradation of any afety function or provide misleading information to the operat Generic Letter 88-07 provides guidance to the lice ees on actions to be taken for inoperable equipment due to environmental qu ification results, including plant shutdown until the problem is corrected. Also, the licensees would have to determine whether its findings are report e.

If you have any questions regarding this-tterr contact Mr. Conrad McCracken at (301) 504-2873.

ncerely, William T. Russell, Associate Director for Inspection and Technical Assessment Office of Nuclear Reactor Regulation DISTRIBUTION Central File SPLB File WRussell i

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