ML20036E118
| ML20036E118 | |
| Person / Time | |
|---|---|
| Issue date: | 02/05/1998 |
| From: | Callan L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Diaz N, Dicus G, Shirley Ann Jackson, Mcgaffigan E, The Chairman NRC COMMISSION (OCM) |
| Shared Package | |
| ML20036E120 | List: |
| References | |
| REF-GTECI-*****, REF-GTECI-NI, TASK-*****, TASK-OR NUDOCS 9802120004 | |
| Download: ML20036E118 (4) | |
Text
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i M Eru k UNITED STATES
- g. s' NUCLEAR REGULATORY COMMISSION l
2 WASHINGTON, D.C. 20555-0001
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February 5,1998 MEMORANDUM TO: The Chairman Commissioner Dicus t
Commissioner Diaz Commissioner McGaffi a FROM:
L Joseph Callan f i
Executive Director f( r perations i
SUBJECT:
STATUS OF THE ENVIRONMENTAL QUALIFICATION TASK ACTION PLAN (WITS ITEM 9300107)
The purpose of this memorandum is to update the Commission on the status of the Environmental Qualification Task Action Plan (EQ-TAP) and to inform the Commission of the i
staff's decision to address the remaining EQ concems under Generic Safety issue (GSI) 168,
- Environmental Qualification of Electrical Equipment." In a staff requirements memorandum dated June 28,1993, the Commission directed the siaff to treat environmental qualification of l
electric equipment as a potential safety issue within the existing regulatory process for l
operating reactors and to periodically inform the Commission of staff efforts. The most recent Commission update on the status of the EQ-TAP was issued on November 15,1996.
Attachment i reports the status of the EQ-TAP. This report documents the actions taken on each item of the EQ-TAP by the Offices of Nuclear Reactor Regulation (NRR) and Nuclear i
Regulatory Research (RES) since its inception. With the deciur n to accomplish the remaining EQ-TAP activities under GSI-168, the staff will keep the Commission infor'd of future.
j activities regarding the resolution of potential EQ safety issues by updat.m
- UREG-0933,
'Prioritization of laneric Safety issues."
Summarv of Accomolishments Since Last Uodate Over the past 12 months, the staff participrted in or sponsored four public meetings. Two F
meetings were held with industry groups in late 1996 to keep the industry informed on the f
progress of the action plan. RES sponsored two additional meetings in early 1997 to provide a ll forum for the public and the staff to discuss the implementation of the cable research program.
The staff obtained additional reports and test data from the industry during the last year that pfX D n g may address some of the technical concems currently being evaluated by the cable research gu program. The reports and test data aie under review by RES.
The staff completed its programmatic review of the NRC EQ program arad the review of the e
assessment of risk with regard to EQ. The most significant items identified under the
@D pregrammatic review were the lack of a " feedback mechanism" (i.e., programmatic OSh 1.n 1 S CONTACT: C. Gratton, SPLB/DSSA/NRR llll.NllI!,!!! h
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l requirements to determine h currant condition of EQ equipment in plants so that it could be 1
evaluated against the assumptions a xi parameters used for qualification) and the need to conrfuct research relative to electrical cable testing and condition monitoring.- The staff realized l
. the need for confirmatory cable testing ad condition monitoring research during the development of the action plan and incorpo;ated insights r.a concems from the programmatic l
l review as they were available into tne d.4e research program. The staff will consider the -
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results of the cable research and the feasibility of" feedback mechanisms" as part of the l
resolution of GSI-168.
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Tests to evaluate EQ technical concems and condition monitoring techniques under the cable research program continue to make progress. The cable research program focuses on low-l voltage electric cables used in instrumentatior= and control applications. Six loss-of-coolant-j,
' accident (LOCA) test runs are planned to study three types of cables. Each test run will feature j
one of the three cable types and will involve preaging to simulate 20,40 and 60 years of i
l equivalent operation and LOCA testing. Unaged and naturally aged cables will also be included i
i, in the testing. The first LOCA test was completed in 1997 and the interim report describing the j
i test results is being reviewed by the staff. Some anomalies were observed on the artificially l
preaged cables that were aged to simulate 20 years of service. The neoprene jackets i
degraded following thermal aging. A complete evaluaticn of the results from the first test will be j
completed by the end of February 1998.
Baseline testing for the second set of cables is currently underway. Aging of the test specimens is scheduled to be completed by the end of January 1998, with LOCA testing i
scheduled for the sernd quarter of 1998. Testing and evaluation of all cable sets are j
l scheduled to be completM oy the end of 1999.
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Mannaina the Ramahdion of EQ Concerns Under GSI-168
.i The purpose of the EQ-TAP was to evaluate and resolve known EQ concems and to identify l
l and resolve other EQ concems that may exist. Within the scope of the EQ-TAP, the staff j
committed to evaluate the differences in EQ requirements between older and newer plants, 1
review the development and implementation of existing EQ requirements, and assess the j
adequacy of accelerated aging practices currently in use for demonstrating environmental i
j qualification.
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Since the inception of the EQ-1AP, the staff-i Completed a programmatic review of the NRC EQ orogram to gain insight into the.
development and implementation of existing EQ requirements and to determine whether v/saknesses identified in other similar NRC programs were evident in the EQ program.
j This comprehensive review included an evaluation of the relevant recommendations j
from the Fire Prctecticn Program Reassessment Report, a survey of NRC and industry
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EQ experts, a review of NRC EQ program requirements, a review of NRC EQ audit and j
j inspection practices, and a review of Le practices implemented by licensees with regard to the EQ rule.
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The Commissioners 3
Identified EQ-related technical and programmatic concems through a review of the development and implementation of existing EQ regulations, through the review of current EQ-related literature and test data, and through interactions with the public.
Completed a review and documentation of existing EQ-related literature. Reports and
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data collected during the literature review were used to resolve many of the technical concems identified by the EQ-TAP. A database containing EQ-related literature and test reports was established for future reference. The staff also reviewed the results of industry operating experience with EQ and examined equipment replacement experience at several operating reactors.
Completed an evaluation of the differences between the EQ requirements at older plants and newer plants and documented the findings of that evaluation in the EQ status update memorandum to the Commission dated November 15,1996.
i Developed and implemented a cable research program (currently ongoing) to address technical concems related to accelercted aging practices, technical concems not resolved through a review of EQ-related literature and industry reports, and to evaluate promising condition monitoring methods. Cable research program tests are being performed on low-voltage instrumentation and control (l&C) cables.
The activities completed to date comprise the bulk of the work originally planned for the EQ-TAP. They address most EQ concems and identify what further actions are necessary to l
resolve the remaining EQ concems. The remaining actions, including the completion of the ongoing cable research program under the management of RES, are long term and can be managed through the resolution of GSI-168. The staff initiated GSI-168 concurrent with the EQ TAP to assure appropriate management and oversight should any EQ-related generic 1
safety issue be identified during the reviews performed for the EQ-TAP. Although none of the i
remaining EQ conccms have been identified as generic safety issues, GSI-168 is the most appropriate management system to track and report of the progress of resolving these EO-
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related concems considering the long term nature of the cable research program.
Since the concerns identified by the EQ-TAP have either been resolved by the review of existing EQ-related literature or are being addressed by the cable research program, and since it will take time to complete the cable research program, the staff has decided to close the EQ-TAP and subsume the remaining activities associated with the EQ-TAP into GSI-168. In addition to closing the action plan, responsibility for resolving GSI-168 is being transferred from NRR to RES. The RES operating plan ~: Judes the cable research program and allocates the resources necessary to complete the program. Progress reports on the resolution of GSI-168 will be updated in NUREG-0933. NRR is also working closely with RES to update the User Need Request memorandum originally issued April 22,1993, to reflect changes in schedules and deliverables as a result of the staff's decision to close the EQ-TAP and transfer the responsibility for r+ solving GSI-168 to RES. Closing the EQ-TAP and transferring the resnistion of GSI-168 to RES will complete NRR's planned activities for the EQ-TAP described in the Regulatory improvements Oversight section of the NRR's FY 1998-1999 Operating Plan.
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The Commissioners 4
On the basis of staff reviews in accordance with the EQ-TAP, the staff has not identified any l
. signincant safety concern that requires immediale regulatory action.
Attachment:
Final Status Report on the Environmental Qualification 10 CFR 50.49 Task Action Plan i
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ATTACHMENT FINAL STATUS REPORT ON THE ENVIRONMENTAL QUALIFICATION 10 CFR 50.49 TASK ACTION PLAN d
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January 1998 i
Office of Nuclear Reactor Regulation Division of Systems Safety and Analysis i
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FINAL STATUS REPORT ENVIRONMENTAL QUALIFICATION 10 CFR 50.49 TASK ACTION PLAN Puroose The Environmental Qualification Task Action Plan (EQ-TAP) was established to evaluate and resolve known environmental qualification (EQ) concems and to identify and resolve any other EQ concems that may exist. The origirial plan was submitted to the Commission in July 1993.
Since that time, periodic status updates have been cubmitted to the Commission, most recently on November 15,1996. This report documents specific actions taken on each item of the EQ-TAP by the Offices of Nuclear Reactor Regulation (NRR) and Nuclear Regulatory Research (RES).
Summary As des ad in the IEQ-TAP submitted to the Commission in July 1993, the EQ-TAP was establish )d to focus on three issues: (1) evaluating the differences in EQ requirements between older and newer plants, (2) assessing the adequacy of accelerated aging practices that are currently used for demonstrating equipment qualificaiion, and (3) performing a programmatic review of EQ requirements to identify and resolve any other EQ concems that may exist. In the November 15,1996, EQ-TAP status update to the Commission, the staff documented the closure of the first issue. The closure was based on the staff's conclusion that actions taken by the Nuclear Regulatory Commission (NRC) and licensees since the implementation of the EQ rule and the marp s inherent in the qualification process itself ensured an acceptable level of safety independent of which qualification requirement was implemented.
The second issue regarding the adequacy of accelerated aging practices is being investigated by j
the cable researen program that RES is conducting on low-voltage instrumentation and control (l&C) cables. This cable research program is scheduled to be completed by the end of 1999.
For the third issue, the staff completed a comprehe mye review of NRC EQ requirements and their implementation and determined that the most ugnificant programmatic finding was the lack of a " feedback mechanism" (i.e., programmatic requirements to determine the current condition of EQ equipment so that it can be evaluated against the assumptions and parameters used for qualification) requiring that licensees assure the continued qualification of EQ equipment as nuclear power plants continue operation. The concept of E feedback mechanism was discussed in the November 15,1996, EQ-TAP status update to the Commission. The cable research program is currently evaluating promising condition monitoring techniques for low voltage l&C cables (see item 7.b. below).
Wh reviewing and evaluating the status of the EQ-TAP (Item 6), the staff determ;r.cd that those at plan items associated with identifying EQ concems and gathering and evaluating existing industry reports and data to address those concerns were essentially complete. The remaining EQ-TAP activities involve evaluating the technical concems through research and performing the necessary regulatory actions to implement options to resolve EQ concems. These are long-term actions.
Since the concems identified by the EQ-TAP have either been resolved by the review of existing EQ-related literature or are being addressed by the cable re33 arch program, and since it will take time to resolve the cable research program, the staff has decided to close the EC;-TAP and subsume the remaining activities associated with the EQ-TAP into Generic Safety issue (GSI) 168, " Environmental Qualification of Elec'.rical Equipment." The responsibility for resolving GSI-168 will be transferred to RES and the work scope for its resolution will be updated in NUREG-0333, "Prioritization of Generic Safety issues."
EO-TAP Accomolishments 1.
Inform the Commission, Senior Nuclear Regulatory Commission (NRC) Managers, and the Nuclear industry of the Emerging EQ lasue.
Completed. NRR issued two information notices on EQ and issued a memorandum to the Commission conceming the emerging EQ issues. NRR presented a paper on EQ at the 1993 NRC Regulatory Information Conference and made a presentation on EQ to staff members of the House Subcommittee on Mining and Energy.
2.
Encourage Nuclear Industry Participation in identifying and Resolving Specific 4
EQ Concerns.
Completed. Periodically throughout the performance of the action plan, the staff held rneetings and workshops to keep the public informed of the progress of and the findings from various action items within the EQ-TAP ar.d to solicit ideas and feedback regarding the action plan's scope and direction. Since the last action plan update, the staff has made presentations on the status of the EQ-TAP at two industry meetings and has held two RES-sponsored public meetings to discuss, and obtain comments on, the condition monitoring and the LOCA test programs, which are part of the cable research program.
Even though this item is considered completed, the staff will continue to provide open communication with the nuclear industry regarding the resolution GSI-168.
3.
Programmatic Review a.
Review license renewal background information.
Completed. The staff collected and reviewed information tha: was developed for the NRR License Renewal Project Directorate. A summary report on EQ requirements and the bases for any di'ferences was issued on March 22,1994. The staff found no issues that required immediate action, but noted potential issues and concems in the summary repert issued under EQ-TAP Action item 3.g.
i b.
Review Fire Protection Reassessment Report for recommendations relevant to the NRC EQ program.
Completed. The staff reviewed the February 27,1993, reassessment of the fire protection program to determine whether issues from that report were applicable to EQ. The staff issued a report on its findings on May 10,1994. The staff found no issues requiring immediate action, but noted potential issues and concems in the summary report issued under EO-TAP Action Item 3.g.
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c.
Elicit opinions from others (regions, EQ experts).
Completed. The staff surveyed industry EQ experts and regional and headquarters-based NRC employees familiar with EQ requirements to determina whether potential EQ problems existed that were not included in the staff's review. The staff issued a report on the results of the survey on June 12,1994. Technical concems identified by the survey participants were included in the review of technical issues (FQ-TAP ltem 7). Potential programmatic issues regarding the NRC EQ program were also identified. The staff found no issues requhing action, but noted potential issues identified by the survey in the final report under EQ-TAP Action item 3.g.
d.
Review existing EQ program requirements.
Completed. The sts" compared the existing EQ program requirements documented in 10 CFR 50.49, NUREG-0588, the Division of Opersting Reactors Guidelines, Regulatory Guide 1.89, IEEE Standard 323-74, etc., and issued a report on potential progran'matic problems The staff found no issues requiring immediate action, but noted potential issues and concerns in the final report under EQ-TAP Action item 3.g.
e.
Review audit and inspection practices of the NRC.
Completed. The staff reviewed the EQ inspection guidance for both operating reactors and equipment vendors and issued a report on April 14,1995. The staff found no issues requiring immedit.te action, but noted potential issues and concems in the final report under EQ-TAP Action item 3.g.
f.
Review EQ implementation practices of licensees.
Completed. The staff made four site visits to gather and evaluate information about the implementation of the EQ ru!e nt individual sites. Information regarding a fifth plant's EQ program was also reviewed. The staffissued a report on its findings on October 7,1994. Plant equipment replacement data was also collected for input into EQ-TAP ltam 4.b. The staff found no issues requiring immediate action, but noted potential issues in the final report under EQ-TAP Action N m 3.g.
g.
Finalize review results.
Completed. The staff consolidated and documented the potentialissues identified while completing EQ-TAP ltems 3.a. through 3.f. and validated the potentialissues through a peer review, using individuals that are knowledgeable and experienced in EQ.
The most significant finding from the progran ~ iew was the lack of a programmatic feedback mechanism (i.e., programmatic requirements to determine the current condition of EQ equipment so that it can be evaluated against the assumptions and parameters used for qualification) requiring that licensees assure the continued qualification of EQ equipment as nuclear power plants continue operation. This finding as well as the other findings and recommendations from the program review will be considered as the staff resolves GSI-168.
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4.
Data Collection and Analysis
' Review published documents and industry reports pertaining to EQ.
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I Completed. RES through Brookhaven National Laboratmy (BNL) completed its review of j
' fo:wign and domestic test reports on EQ and the Electric. Meer Research Institute \\NUS
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Corporation EQ database focusing on published qualification and research reports on low-l i
voltage instrumentation and control cables. The laitial report on the findings from the BNL l
. literature survey was published as NURr CR-6384, Volumes 1 and 2, in April 1996. Of the 43
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EQ-related issues considered for resol wn under the EQ-TAP,18 issues were resolved using '
i information in existing literature. The staff determined that research on six other issues should j
p not be pursued because their resolution offered only minimal benefits. BNL recommended that the remaining 19 issues be resolved by the cable condition monitoring research and test i
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program (EQ-TAP ltem 7).-
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RES held a public open meeting witn the industry in August 1996 to discuss the fit.Jings from NUREG/CR-6384. During the meeting, industry representatives committed to provide.
additional data and industry reports that they believed addressed several of the 19 outstanding i
e technical issues. Over the past year, the staffs contractor has received the reports and in a dupplerrent to the initial report evaluated their contents. The supplemental report is currently i
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under review by the staff. Preliminary indications are that 13 of the 19 outstanding issues could j
be resolved without further research. The staff expects to complete its review in January 1998.
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f While the staff is continuing their review of the supplemental report oescribed above, and the results of that review may resolve some of the EQ technical concems under evaluation in the cable research program, no further activities are planned for this action plan item, T
b.
Gather equipment replacement experience.
Completed.. The staff issued a final report on September 15,1994, which included information
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from the site visits made'under Task 3.f. Based on the findings from the site visits and the
. staff's review of existing industry replacement precuoes, it was recommended that cables, con.uctors, and penetrations be retained in the NRC's EQ aging reviews.
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Review operating oxperience data.
Completed. The staff issued the final report on June 30,1994. The staff reviewed licensee f
event reports (LERs), Institute of Nuclear Power Operations (INPO) reports, and the Nuclear l
Plant Reliability Data System (NPRDS) data. The staff concluded that the number of EQ-l related problems at operating plants has been small relative to the total number of problems reported by plants, and that the majority of the EQ problems are attributable to poor installation, poor maintenance practices, or the equipment's not being qualified for the actual in-plant i
service.
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Review information on equipment failures at Three Mile island (TMI) via the Department of Energy. '
i Completed. RES through BNL has completed its rev:sw of the relevant information regarding equipment failures at TMI. BNL has included the restults of the review in the final report for Task 4.a (NUREG/CR-6384).'
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Develop an EQ database.
t Completed. The purpose of the EQ database was to develop a searchab!e source of EQ-related test reports, research documuts, and other data that could be used to resolve existing EQ-related technical concems. The database was developed by RES in December 1995 and has been periodically updated as new reports and industry data became available.
The staff will continue to update the database and use it as a reference it oughout the resolution of GSI-168.
5.
Risk Assessment
- a. Perform preliminary scoping study.
Completed in a memorandum to T. Murley, A. Thadani detailed the results of the preliminary scoping study, The results indicated that EQ equipment failures in a harsh environment could significantly affect core damage frequency (CDF), though the magnitude of the CDF impact ras plant specific. The study also concluded, however, that the lack of reliability data bases resulted in significant uncertainty in the results. The report recommended the staff perform a more detailed EQ risk assessment.
- b. Perform final PRA.
Completed. The staff reviewed the findings from the initial scoping study (EQ-TAP Item 5.a), a followup study by Argonne National Laboratory to search the existing literature for reliability data for electrical components in harsh environments, and BNL's literature review (EQ-TAP 4.a), Based cri the results of the staff review, a draft report was issued in April 1996 on risk issues with regard to environmentally qualified equipment. This report summarized previous work performed in the area of probabilistic risk assessment (PRA) and EQ and concluded that available information and data are not adequate to support a more detailed PRA of EQ issues; therefore, further work on PRA should not be performed under the EQ-TAP.
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c.
Incorporate probabilistic risk assessment insights.
Completed. This task was established to ensure that risk insights from the EQ-TAP were incorporated in the other activities of the action plan. Although the staff contidered the results of the preliminary scoping study while the preparing of the action plan, the other uses of risk were dependent on the results of the activities performed under EQ-TAP ltem 5.b.
The staff concluded from the ac6ities conducted under EQ-TAP 5.b. that further risk assessment activities were not warra.Med under the action plan. Notwithstanding this finding, a staff senior level advisor on probabilistu safety assessment reviewed the results of the earlier activities to assess the risk of EQ and identified potential uses for risk assessments that may be
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helpful as the staff resolves GSI-168.
6.
Review and Evaluation of the Status of the EQ-TAP Completed. Because of the breadth of this action plan, the staff performed an additional review of the EQ technical concems to ensure that they warranted further research. The staff reviewed the list of unresolved technical concems currently being evaluated by the cable e
research program against the reports issued for EQ-TAP ltems 1-5 and the reports and data collected for the literature review. The staff determined that the list of technical concems under evaluation by the cable research program for low-voltage l&C cables was appropriate.
nQ is currently reviewing several technical reports which may resolve some of the remaining technical er v. erns (see EQ-TAP ltem 4a.). RES expects to complete the review of these reports by toe end of January 1998.
7.
Technicalissues a.
Evaluate uncertainties associated with accelerated a@g methodology.
Ongoing. The purpose of this action plan item was to develop and implement a test program to evaluate the use of accelerated aging in the qualification of safety-related equipment within the scope of 10 CFR 50.49. Since the last EQ-TAP update on November 15,1996, progress toward tesolution of this action item has been as follows.
Tests to evaluate EQ technical concems and condition monitoring techniques under the cable research program continue to make progress. The cable research program focuses on low-voltage electric cables used in instrumentation and control applications. Six loss-of-coolant-accident (LOCA) test runs are planned to study th ee types of cables. Each test run will feature
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one of the three cable types and w... involve preaging to simulate 20,40 and 60 years of equivalent operation and LOCA testing. Unaged and naturally aged cabies will also be included in the testing. The first LOCA test was completed in 1997 and the interim report describing the test resulte is being reviewed by the staff. Some anomalies were observed on the artificially preaged cables that were aged to simulate 20 years of service. The neoprenejackets degraded following thermal aging. A complete evaluation of the results from the first test will be completed by the end of February 1998.
Baseline testing for the second test run of cables is now underway. After baselining is complete, aging of the test samples will begin, followed by LOCA testing, which is scheduled for the second quarte, of 1998. The remaining test runs of low voltage cables (sets 3-6) t ill be tested over the next 18 months, with completion of all testing and evaluation scheduled for the end of 1999.
Although the EQ-TAP is being closed, ongoing research activities will continue through the resolutan of GSI-168, as discussed above. RES will be responsible for the cable research program as it evaluates EQ technical concems related to the qualification testing methodology under GSI-168. Recommendations for further action based on the results of the cable research program will be developed as part of the resolution of GSI-168.
b.
Investigate Condition Monitoring (CM) methods.
Ongoing. The purpose of this action item was to c'evelop and implement a test program to investigate methods of monitoring the condition, or performing inservice inspection, of environmentally qualified cables to determine the degree of degradation over time. To accomplish this tap., the staff developed the cable research program, which includes provisions for monitoring the cy'.tition of the cable test samples throughout the testing, using several CM methodologies.
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Since the last update, the first set of test cables has completed the aging and i.OCA test '
sequer,a. CM data was taken throughout the cable baselining, aging, and testing programn to evaluate CM methodologies. The data collected for the first set of cables is currently under 1
evaluation by the staffs contractor under the direction of RES.
i Although the EQ-TAP is being closed, evaluation of condition monitoring raethods will continue i
as the staff resolves GSI-168. Recommendations based on the results of this evaluation will be developed as part of the resolution of GSI-168.
c.
Evaluate the impact of the new source term on EQ.
i Completed. The purpose of this action item was to develop a staff position on the use of the new (revised) source term described in NUREG-1465, " Accident Source Terms for Light Water Nuclear Power Plants," February 1995.
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The staff performed an interim study of the effects of the revised source term on the qualification of plant equipment. The staff based its study on a draft of NUREG-1465 and issued a draft report on December 30,1994. The staff found that some benefits could be gained from performing qualification calculations using the revised source term, but that the i
j 2.snefits were highly dependent on plant design.
j Since EQ information has been developed that the steff can use in implementing the revised source at operating plants and since EQ is only one part of the staff's and industry's overall l
efforts to implement the revised source term at operating plants, further action under the EQ-TAP is not warranted. However, RES and NRR will follow the implementation of the revised source term at operation plants and will consider how the information gained about this effort can be used by the staff.
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Options for Resolution Completed. Based on the reviews performed for the EQ-TAP, the staff has identified the l
following options to retolve the concems identified in this action plan. Should the cable research program identify limitations in the original qualification methodology, practical approach 3s to condition monitoring currently being evaluated by the cable research program 1
can be used to supplement the original EQ requirements and guidance for low voltage I&C cables. Practical condition monitoring techniques for equipment other than low voltage l&C cables are not within the reope of this action plan and would be developed separately. Should i
the results of the cable research program indicate that the original qualification methodology was adequate to predict the qualified life of EQ equipment, no further action would be required, although the use of practical condition monitoring techniques could be evaluated on an enhancement basis to supplement EQ requirements or used in the implementation of the 4
Maintenance Rule.
i The staff has considered the possibility that the cable research program will identify limitations in the original qualification methodology, and that no practical conditior monitoring technique will be identified. Through the extensive investigation of EQ requirements performed as part of this action plan, the staff has gained confidence that the original qualification methodology contains sufficient margin to ensure an acceptable level of safety even if some limitations are identified. The staff will reevaluate their options for resolution as part of the resolution of GSI-168 should this outcome occur.
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Implementation i
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Transferred to GSI-168. The purpose of this action item is to decide on the appropriate regulatory option, plan and take the action, and document the basis for the action. With the closing of the EQ-TAP, activites associated implementing selected optior.s for resolution will be j
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subsumed into GSI-168.
i Conclusions a
Through the EQ-TAP, the staff has gained extensive knowledge about the implementation of the
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EQ program by the NRC and licensees and about significant EQ-related concems. Although i-some activities continue, the EQ-TAP has been instrumental in resolving many concems and
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identifying the course of action needed to resolve the remaining concems.
- In particular, the staff resolved the questions about the differences in EQ requirements between older and newer plants. The staff also completed a comprehensive programmatic review of the NRC EQ program and found that the signiricant programmatic issue was the lack of a feedback mechanism requiring that licensees assure the continued qua!ification of EQ equipment as
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l nuclear power plants continue operation.
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j' Additionally, the staff determined which technical concems should be included in a cable i
research program to assess the adequacy of accelerated aging practices used for demonstrating qualification. Through this effort, RES has implemented a program to evaluate the original j
. ualification methodology and promising condition monitoring methods. This program which uses l
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' low voltage I/C cables is scheduled for completion in late 1999 and will provide the technical basis for resolving the remaining EQ technical concems, which will be included in the resolution of GSI-
.168.
i In addition, the EQ-TAP gathered information that can be used in future activities regarding EQ.
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~ This information includes a dat6ase of EQ-related reports and data, reports summarizing the results of cable research and qualification efforts, information on equipment replacement and operating experience, approaches for using risk assessment in CQ, and insights into the use of the revised source term on EQ at operating plants.
~ The staff has determined that the EQ-TAP has accomplished its intended purpose, first through the identification of EQ concems, then, by res,olving most of the EQ concems through a thorough review of existing EQ-related literature, and finally, by developing a cable research program to
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resolve the remaining technical issues and evaluate promising condition monitoring techniques.
j As discussed above, all concems have not been resolved; however, clear paths toward resolution i
of the concems have been established. Since the bulk of the work has been completed under the action plan, and since it will take time to resolve remaining technical concems through the cable research program, the staff has determined that it is appronriate to close the EQ-TAP and the resolve the remaining concems through GSI-168.
On the basis of s""1rviews in accordance with the EQ-TAP, the w ins not identified any significant safety concem that requires immediate regulatory acti 0
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The Commissioners 4
On the basis of staff reviews in accordance with the EQ-TAP, the staff has not identified any i
significant safety concem that requires immediate regulatory action.
Attachment:
Final Status Report on the Environmental t
Qualification 10 CFR 50.49 Task Action Plan cc:
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DOCUMENT NAME: A:EQTAPCP.R15
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' 1/12/97 3/98 yt/fW f)
{Y fi DISTRIBUTION:
File Center EDO rf DEDRrf JCallan AThadani scc!1 ins FMiraglia GHolahan SNewt,.stry i
TMarsh GHubbard JTatum CGratton LOlshan LShao KBohrer (WITS 9300107)
MMayfield JVora SAggarwal PShemanski SPLB R/F AEl-Bassioni NSaltos BSheron GLainas JCalvo
)
EWeiss FBurrows Enox JWermiel AMarinos HGarg i
PMagnanelli(WITS 9300107) MKnapp SPLB Correspondence File HThompson PDR i
l OFFICIAL RECORD COPY
j The Commissioners 4
On the basis of staff reviews in accordance with the EQ-TAP, the staff has not identified any significant safety concern that requims imrnediate regulatory action.
N x
Attachment:
N.
,4
Final Status Report on the Environmental Qualification 10 CFR 50.49 TasICA'ction Plan Y[' \\
cc:
,/
DISTRIBUTION: See next sheet
,/
DOCUMENT,NAME: A:EQTAPCP.R14
- See Previous Crcurrence
\\
SPLB*
SPLB:BC*
Tech Ed.*
AD:
D:DSSA*
AA$
RR CGratton LBMarsh Kleene GLa' s GHolahan BS4 n
11/12/97 11/12/97 11 7
12 !98 11/21/97 RES*
tD EDO 2
MKnapp l
r JCallan HI 11/26/97 1
3 12/ /9p DISTRIBUTION:
File Center EDO rf DEDR rf JCallan AThadani SCollins FMiraglia GHolahan SNewberry TMarsh GHubbard JTatum CGratton LOlshan LShao KBohrer (WITS 9300107)
MMayfield JVora SAggarwal PShemanski SPLB R/F AEl-Bassioni NSaltos BSheron Glainas JCalvo EWeiss FBurrows JKnox JWermiel AMarinos HGarg PMagnanelli(WITS 9300107)
MKnapp SPLB Correspondence File HThompson OFFICIAL RECORD COPY
)
The Commissioners 3
Identified EO-related technical and programmatic concems throu review of the staff's development and implementation of EQ regulations, thro the review of EQ-related literature and test data, and thmugh interactions w' the public.
' Completed an evaluation of concerns regarding the differ ces between the EQ requirements at older plants and newer plants and decu ented the findings of that i
evaluation in the EQ status update memorandum to t Commission dated November 15,1996.
Developed'and implemented a cable research program (currently ongoing) to address technical concerns related to accelerated aging, practices, technical concems not resolved through a review of EQ-related literature, and industry reports and to evaluated condition monitoring. methods. Cable reseafch program tests are performed on low-voltage instrumentation,and control (l&C} 6 ables.
These activities have addressed most EQ con /
N cerns and have identified what further actions are the RES's ongoing cable research program,er'nain. These actions, includi necessary to resolve those concerns that r will be accomplishod through the resolution of GSI-168, which was established to trac /an,d resolve any EQ-related concerns identified as part of the EQ-TAP.
Since the concerns identified by thyEQ-TAP have,either been resolved by the review of existing EQ-related literature or ard being addressed by the cable research program, and since it will take time to resolve the ca e research program}the staff has decideo r cbse the EQ-TAP and subsume the remaini activities associated w'ith the EQ-TAP into GSI-108. The responsibility for resolving GS)-168 is being transferred to RES and its progress wili be updated in NUREG-0933, "Prioritizatipn of Generic Safety issues." InNddition, NRR is working closely with RES to update the Usef Need Request memorandum origlnally issued April 22,1993, to reflect changes in schedujds and deliverables as a result of the staff's decision to close the EQ-TAP and transfer the' responsibility for resolving GSI-168 to RES.
On the basis of staff rev/
\\
iews in accordance with the EQ-TAP, the staff tias not identified any significant safety concern that requires immediate regulatory action.
l
Attachment:
Final Status Report on the Environmental Qualification 10 CFR 50.49 Task Action Plan cc:
/
DISTRUBTiON: See next sheet 3 "4 DOCUMENT NAME: A:EQTAPCP.R13 y
)
U
- See Previous Concurrence SPLB*
SPLRBC*
Tech Ed.*
AD:DE D:DSSA*
AADT:NRR CGratton LBMarsh Kleene Glainas GHolahan BSheron 11/12/97 11/12/97 11/14/97 12/ /97 11/21/97 12/ /97 RES*
DD:NRR D:NRR EDO MKnapp FMiraglia SCollins JCallan 11/26/97 12/ /97 12/ /97 12/ /97 OFFICIAL RECORD COPY
Th Commissioners 4
'These a ivities have addressed most EQ concerns and have iden fied what further ac ns are necessary to resolve those concerns that emain.
These actions, neluding the completion of the RES's ongoin cable'research
. program will be omplished through the resolution of G -168. GSI-168 was established to-resolv Q-related concerns.
NRR has ha responsibility for the resolution of GSI-16 ince its inception, and de loped the EO-TAP as a means to identify and resolv Q-related concerns.
Since the concerns identified by the
-TAP have either been resolved by the review of existing EQ-related literature o r6beingaddressedbythecable.
research program, and since it will take tj>rfe esolve the cable research program.thestaffhasdecidedtoclose)toGSI-168.
he E0-TAP d subsume the remaining activities associated with the'EO-TAP '
responsibility for resolving GSI-168 is being transferr d to RES and its pr ress will be updated in NUREG-0933. "Prioritization of eneric Safety Issues."
addition. NRR is working closely with RES to upd e the User Need Request memor dum originally issued April 22. 1993, to ref ct changes in schedules and deliverables as a result of the staff's decis' n to close the EQ-TAP and transfer the responsibility for resolv' g GSI-168 to RES.
On the basis of staff eviews in accordance with the EQ-TAP. the staff has identified any sig icant safety concern that requires immediate regulatory action.
Attachment:
Final St s Report on the Environmental Quali ication 10 CFR 50.49 Task Action Plan j
cc:
SECY OGC OCA OPA CFO CIO 0ISTRUBTION: See next sheet y
DOCUMENT NAME: A:EQTAP
/f*
- See Previous Concurrence SPLB*
SPLB:BC*
Tech Ed.*
AD:DE D:DSSA AADT:NRR CGratton LBMarsh Kleene GLainas GHolahan BSheron l
11/12/97 11/12/97 11/14/97
/ /97 11/21/97
/ /97 I
RES*
DD:NRR D:NRR EDO MKnapp FMiraglia SCollins JCallan 11/26/97
/ /97
/ / 97
/ /97 0FFICIAL RECORD COPY
_.. _ _. _... ~ _ _
4 The Commissi ers 4
information on uipment replacement and operati experiente, approaches for using' risk' assess nt in E0 and insights int he use of the revised source term in E0 at oper ing plants.
l Since the bulk of the ork of the actio plan has been completed, and since i+
l will take time to resol the remaini issues through the cable research program, the staff-has de ded to ose the E0-TAP. The remaining open_ items
- are included in GSI-168. T re onsibility for resolving GSI-168 is be"]
j transferred to RES and the pr ess will be updated in NUREG-0933, i
~Prioritization of Generic S e Issues."
In addition. NRR is working closely with RES to update he Us Need Request memorandum originally issued
{
April 22.1993, to refle changes schedules and deliverables as a result j
of the staff's decisio to close'the 0-TAP and transfer the responsibility
{
for resolving GSI-16 to RES.
J On the basis of s aff reviews in accorda e with the E0-TAP. the staff has not identified any gnificant safety concern hat requires immediate regulatory action. The r maining technical and regula ory issues will be addressed through the esolution of GSI-168.
Attachment:
Final Status Report on the Environmental Qualification 10 CFR 50.49 Task Action Plan cc:
SECY OGC OCA OPA CFO CIO DOCUMENT NAME: A:E0 TAP DISTRIBUTION: See next sheet
- See Previous Concurrence M' I'7 I SPLB*
SPLB:BC*
Tech Ed.*
AD:DE D:DSSA*
AAD).NRR l
CGratton LBMarsh Kleene Glainas GHolahan BSheron i
11/12/97 11/12/97 11/14/97
/ /97 11/21/97
/ /97
)
RES*
DD:NRR D:NRR EDO l
MKnapp FMiraglia SCollins JCallan i
11/26/97
/ /97
/ / 97
/ /97 i-0FFICIAL RECORD COPY l
~
The Commissioners 4
1 information on equipment replacement and operatin experience. approaches for using risk assessment in E0. and insights into e use of the revised source
. term in E0 at o rating plants.
Since the bulk of t work of the action p n has been comple_
. and since it-will take time to re ve the remaining sues through the cable research program, the staff nas cided to close he E0-TAP. The remaining open items are included in GSI-168.
e respons' ility for resolving GSI-168 is being transferred to RFS and the p gress ill be updated in NUREG-0933.
"Prioritization of Generic Sa sues."
On the basis of staff reviews '
a ordance with the E0-TAP. the staff-nas not identified any significant s ety co ern that requires immediate rege'atory action. The remaining tec ical and r ulatory issues will be addressed through the resolution of SI-168.
Attachment:
Final Status Repor on the Environmental Qualification CFR 50.49 Task Action Plan cc:
SECY OGC OCA OPA CFO CIO DOCUMENT NAME: A:E0 TAP DISTRIBUTION: See next sheet
- See Previous Concurrence SPLB*
SPLB:BC*-
Tech Ed.*
AD:DE D:DSSA*
AADT:NRR CGratton LBMarsh Kleene GLainas GHolahan BSheron 11/12/97 11/12/97 11/14/97
/ /97 11/21/97
/ /97 or i
DD:NRR D:NRR EDO dK/i FMiraglia SCollins JCallan (1/}p 97
/ /97
/ / 97
/ /97 0FFICIAL RECORD COPY i
.The Comissioners' 4
technical issues. The cable research program for low-voltage I&C cables is scheduled for completion in late 1999.
In additio the E0-TAP gathered information that can be used in. future activities garding E0. This information includes a database of E0-related reports.and d a reports summarizing the result of cable research and qualification e orts, information on equipmen replacement and operating experience, appro hes for using risk' assess nt in E0. and insights into the use'of.the revised urce term in E0 at op ating plants.
Since the bulk of the wo of the acti plan has been completed, and since it will take time to resolve e remaini issues through the cable research program, the staff has deci to c se the E0-TAP. The remaining open items are_ included in GSI-168. The s nsibility for resolving GSI-168 is being _
transferred to RES and the progr ss will be updated in NUREG-0933.
"Prioritization of Generic Saf y ssues."
On the basis of staff revi s.in acco dance with the EO-TAP. even though'the cable research program a any necessa followup activities may take 2-3 years to complete. the aff has not ide ified any significant safety concern that requires'immedia regulatory action.
Attachment:
Final Status Repor on the Environmental Qualification CFR 50.49 Task Action Plan cc:
SECY CGC OCA OPA CF0 CIO DOCUMENT NAME: A:E0 TAP DISTRIBUTION: See next sheet
- See Previous Concurrence SPLB*
SPLB:BC*
Tech Ed.*
AD:DE D:D AADT:NRR
,7
/*[/h CGratton LBMarsh Kleene Glainas GHo BSheron 11/12/97 11/12/97 11/14/97
/ /97
\\\\/ /97
/ /97 RES DD:NRR D:NRR EDO MKnapp FMiraglia SCollins JCallan
/ /97
/ /97
/ / 97
/ /97 I
0FFICIAL RECORD COPY
The Commissioners 5
has not identified any significant safety concern that requires immediate regulatory action.
Attachments:
1.
EO-TAP Te hnical Issues 2.
Status Re rt on the Environmental Qualifica ion Task Action Plan cc:
SECY i
WC
[A OPA N
CF0 CIO DISTRIBUTION:
File enter EDO rf DEDR rf JCallan AT dani SCollins FMiraglia GHolahan S 'wberry arsh GHubbard JTatum Gratton L shan LShao KBohrer (WITS 93 107) hMa field JVora SAggarwal PShemanski SPLB F
AEl-Bassioni NSaltos BSheron Glainas JCalvo EWeiss FBurrows JKnox JWermiel AMarinos HGarg PMagnanelli (WITS 9300107)
MKnapp SPLB Correspondence rile
'HThompson DOCUMENT NAME: A:E0 TAP
- See Previous Concurrence jn t
g, SPLB*
SPLB:BC*
Tech Ed.*
AD:DE D:DSSA AADT:NRR CGratton LBMarsh Kleene Glainas GHolahan BSheron i
11/12/97 11/12/97 11/14/97
/ /97
/ /97
/ /97 RES DD:NRR D:NRR EDO MKnapp FMiraglia SCollins JCallan
/ /97
/ /97
/ / 97
/ /97 0FFICIAL RECORD COPY t
' ' ~
The Commissioners 5
\\
Even though the above efforts may take 2-3 years to complete, based on the results of the E0-TAP, the staff has not identified any significant safety.
concern that requires immediate regulatory action.
Attachments:
i 1.
E0-TAP Technic Issues 2.
Status Report on he Environmenta Qualification Ta Action Pla cc:
DISTRIBUTION-Gentra141 ED0 rf DEDR rf JCallan AThadani SCollins FMiraglia
]
GHolaban-SNewbe y Marsh GHubbard JTatum CGra on L shan LShao KBohrer (WITS 9300107 MMa ield JVora SAggarwal P emanski SPLB F
AEl-Bassioni NSaltos Sheron Glainas JCalvo EWeiss FBurrows JKnox JWermiel AMarinos HGarg PMagnanelli (WITS 9300107)
MKnapp SPLB Correspondence File HThompson DOCUMENT NAME: A:E0 TAP r
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/ /97
/ /97
/ /97
/ /97
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JCallan
/ / 97
( / /97/
/ /97
/ /97 v-0FFICIAL RECORD COPY i
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6 DOCUMENT NAME: A:E0 TAP i
SPLB:BC AD:DE D:DSSA AADT:NRR DD:NRR D:NRR LBMarsh Glainas GHolahan BSheron FMiraglia SCollins i
/ /97
/ /97
/ /97
/ /97
/ /97
/ /97 I
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~
- t eene JCallan 11/14/ 97
/ /97
/ /97 OFFICIAL RECORD COPY