ML20045D083
| ML20045D083 | |
| Person / Time | |
|---|---|
| Issue date: | 12/08/1992 |
| From: | Kress T, Ward D Advisory Committee on Reactor Safeguards |
| To: | Advisory Committee on Reactor Safeguards |
| References | |
| ACRS-2848, NUDOCS 9306250311 | |
| Download: ML20045D083 (10) | |
Text
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CERTIFIED BY:
D d
[p[ d Mf3 T. Kress ~12/8/92 kg DATE ISSUED: 11/18/92 D. Ward - 11/23/92
SUMMARY
/ MINUTES OF THE ACRS SUBCOMMITTEE ON PLANT LICENSE RENEWAL / RELIABILITY AND QUALITY SEPTEMBER 16, 1992 BETHESDA, MARYLAND INTRODUCTION The ACRS Joint Subcommittees on Plant License Renewal / Reliability and Quality met at 1920 Norfolk Avenue, Bethesda, Maryland, on September 16, 1992.
The meeting commenced at 8:30 a.m. in Room P-110 and was adjourned at about 12:00 noon.
The purpose of the meeting was to review the staff's Branch Technical Position (BTP) on the Environmental Qualificaticn (EQ) of Electrical Equipment for License Renewal.
We have received no written comments nor request to make oral statements from the members of the oublic.
The entire meeting was open to public attendance.
Mr.
E.
Igne was the cognizant ACRS Staff Engineer for this meeting.
ATTENDEES Principal meeting attendees included:
ACRS D.
Ward, Chairman, Subcommittee on Plant License Renewal T.
Kress, Chairman, Subcommittee on Reliability and Quality-C.
Wylie, Member W.
Lindblad, Member J.
Carroll, Member C.
Michelson, Member NRC P. Shemanski S.
Reynolds F.
Akstulewicz G. Hubbard R.
Parkhill A.
Dummer J.
O'Brien M. Case S.
Lee J.
Craig C.
Regan S. Aggarwal S.
Carfagno, Consultant OTHERS C.
Lewe, Halliburton NUS A.
Beard, Halliburton NUS T.
Penland Winston & Strawn K.
Cozens, NUMARC T.
Pickens, NSP J.
Edson, INEL R.
Hill, SNL L.
Bustard, SNL D. Walters, NUMARC f
P.
Holzman, Strategic Technology and Resources (STAR) hg G.
Sliter, EPRI m e m a m m a'N 3
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' Joint PLR/RQ 2
~ September 16, 1992 L.
Conners, STS D. Harrison, DOE T.
Chota, OGDEN R.
Condello, Baltimore Gas & Electric D.
DiBello, Baltimore Gas & Electric D.
Tamai, Baltimore Gas & Electric OPENING REMARKS Mr.
D. Ward in his opening remarks, stated that the BTP on EQ'of Electrical Equipment for License Renewal'has been under consider-ation by both the industry and the NRC for a number of years.
The document which we recently received for review is still in its early stage of development.
Consequently, this document has not yet been made available to the public (including NUMARC), although NUMARC has had numerous' interactions with the NRC on this matter.
This BTP will become an appendix or section to the standard review plan for plant license renewal.
The staff has requested ACRS comments on this BTP.
Mr. Ward suggested that ACRS ' comments may be provided after the public comments have been received and resolved by the staff.
However, Mr. Ward stated that if we have useful opinions on the BTP at this time, then we should recommend that this matter be brought to the full Committee at the October 1992 meeting for consideration.
liRR PRESENTATION Introductory Comments - Mr.
F.
Akstulewicz NRR Mr.'Akstulewicz stated that the staff is requesting ACRS comments:
recommending publication of the draft BTP on the EQ of-electrical.
equipment for license renewal for public comment.
Mr. Akstulewicz noted that this matter was discussed with the Committee for the Review of Generic Requirements (CRGR) and have received a tentative approval to publish this document for public_ comment..
He intro-duced Dr. Carfagno, formerly Director of Engineering at Franklin Institute and Mr. J. Edson of INEL, who assisted the staff on this.
matter.
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September 16, 1992 s
I BTP on Environmental Oualification on Electrical Eauionent for License Renewal - Mr.
P.
Shemanski. NRR Mr. Shemanski, discussed the BTP on EQ on Electrical Equipment for License Renewal.
He stated that for license renewal the EQ program is a compliance issue (10 CFR 50.49) for the extended period of operation.
The BTP provides a method acceptable to the staff in determining what is required for compliance.
He noted that the license renewal rule (10 CFR 54) incorporates the EQ rule (50.49).
In addition, the Part 54 rule incorporates four other~ rules; 50.48, fire protection; 50.61, pressurized thermal shock; 50.62, ATWS; and 50.63 station blackout. These rules essentially address compliance issues.
In reply to a question by Mr. Ward, Mr. Shemanski stated that systems and components required to comply with 50.49 are specified in the EQ master list.
This list will not be modified for the license renewal term.
Mr. Shemanski did say that the BTP also addresses those components outside the scope of 50.49, but is within the scope of the license renewal rule (Part 54).
These components are a subset of electrical components where aging aspects for the renewal term are addressed.
The main focus of the BTP is to address components presently on the EQ master list.
1 Mr. Shemanski, stated that the EQ rule requires that the appli-cants / licensee define the end of a component's qualified life ~and-demonstrate preferably by the tests, that the component will perform its required safety function, up to the end of its qualified life.
For current plants, the qualified life for long-lived electrical components has been established primarily by-tests, as 40 years (current license term).
In reply to a question l
by Mr. Ward, Mr. Shenanski stated that qualified life for electri-cal equipment is more explicitly defined, than,. for example, mechanical components.
The BTP addresses EQ of electrical equipment beyond the qualified life of 40 years.
He noted that the staf f generally will not accept analysis alone, in lieu of testing, l
in establishing qualified life for components.
Mr.
Shemanski, discussed the philosophy of the EQ development program.
The Commission's position was designed to provide the t-w rene r-
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Joint PLR/RQ 4
September 16, 1992 policy of upgrading the EQ and reliability of installed electric equipment.
For short-lived components (less than 40 years) the EQ rule required component be replaced to a higher standard unless, there are sound reasons (Reg. Guide 1.89) to the contrary.
For long-lived components, two standards IEEE 323-1971 and 1974 are currently being used.
In reply to a question by Mr. T. Kress, Mr.
Shemanski stated that there are about 87 " grandfathered" nuclear plants that were qualified to the interim guidance for EQ requirements.
- 1) They are Division of Operating Reactor (DOR)
Guidelines and 2) NUREG-0588, " Interim Staff Position on EQ of Safety-Related Electrical Equipment").
There are approximately 24 nuclear plants that meet the current EQ standard IEEE 323-1974.
The current standard IEEE 323-1974 is based on preaging and testing.
The major difference between IEEE 323-1971 and 1974 is that the 1971 version does not require preaging of the component before testing.
He defined preaging as simulating a component to its end of life condition by an accelerated process.
The EQ testing requirement of 1974 subjected the preaging component to a design basis event e.g., LOCA, main steamline break, etc.
In reply to Mr.
W.
Lindblad's question, Mr. Shemanski stated that analysis without testing is generally unacceptable, except that the effects of radiation on electrical equipment may be performed by analysis only, if synergistic effects are not significant.
It was noted that the 1974
- standard, also provides for additional margin considerations.
Mr.
Shemanski noted that for license renewal, extension of a-grandf athered nuclear plant, qualified in accordance with IEEE 323-1971 (older standard) is not technically appropriate.
Mr. Shemanski discussed the implementation of the BTP on EQ for license renewal by referring to a flow diagram that describes several acceptable alternatives such as 1) testing, 2) similarity,
- 3) reanalysis or extrapolation, 4) ongoing qualification (added as a result of CRGR recommendation), and 5) replacement.
The basis for the BTP on EQ for license renewal that is'within the scope of 10 CFR 59.49 is the IEEE 323-1974 standards.
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Joint PLR/RQ 5
September 16, 1992 In response to a question by Mr. Ward, Mr. Shemanski stated that 1
the use of PRA can be used in determining the addition of compo-nents important to license renewal, but not to delete components based solely on PRA.
Mr. Akstulewicz agreed that there has not yet been a resolution of the use of PRA in maintenance and license
)
renewal.
Mr. Shemanski, stated that the IEEE 323-1971 plants may most likely I
be qualified by testing.
Another path for EQ for these plants is ongoing qualification as suggested by CRGR.
In this alternative method an equipment is qualified for a shorter period of time, say 5 or 10 years, and when that period of time is reached, the equipment is replaced.
This method is not new and is discussed in the IEEE standards.
In response to a question by Mr. Lindblad, regarding what attributes have to be demonstrated at the conclusion of the test program, Mr. Shemanski stated that the equipment must meet its performance specifications.
In the EQ of tables, the preaged cable is wrapped around a mandrel, tested in the LOCA chamber, then submerged in water for about 10 minutes.
The cable is then electrically energized and performance test on the cable performed.
It was stated by Dr. Carf agno, NRC consultant, that the cable bend test (cable wrapped around a mandrel) is performed to determine the residual capability (cable insulation brittleness) of the cable.
Mr. Shemanski next discussed EQ of electrical equipment outside the scope of 10 CFR 50.49 but within the scope of 10 CFR 54.
This group of equipment is not on the EQ master list, and these equipment are generally located in mild environment.
He stated that for this group of electrical equipment, no additional testing is required.
For these components, the applicant / licensee would identify age-related degradation unique to license renewal based on past failure data, replacement data, maintenance data, etc.
The applicant / licensee must_
also demonstrate that age-related degradation unique to license renewal is effectively managed by_
- 1) monitoring compliance with design of purchase specifications,
- 2) certifications of compliance with vendor recommendations and
- 3) other vendor information supporting performance.
m Joint PLR/RQ 6
September 16, 1992 In reply to a question by Mr. Kress on database or equipment.
performance and age-related degradation, Mr. Akstulewicz stated that the NRC does not have' a program where, for example, in-containment cable predicted performance is compared with actual cable failure data.
In reply to a question by Mr. Lindblad, regarding the basis of the statement that says that extension of the previous decision to grandfather equipment qualified to the DOR guidelines or NUREG-0588 is not technically appropriate for license renewal, Mr. Shemanski stated that for the most part the statement is based on engineering judgement and some additional technical data' obtained since the grandfathering decision was.made that indicated that the grandfa-ther exemption cannot be extended into the license renewal stage.
Further, Mr. Shemanski stated that the LOCA condition may not be the worst-case environment for cable degradation.
In fact, a SBLOCA envjronment may be more detrimental for cable performance because of longer time period at a lower peak temperature.
l Mr. Ward complimented the staff on a very clear and responsive presentation.
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1 NUMARC PRESENTATION Introductory Statements - Mr.
D.
Walters, NUMARC i
Mr. D. Walters stated that NUMARC has not yet seen the BTP on EQ of.
electrical equipment. He noted that NUMARC has done extensive work in evaluating EQ and plant extension for low voltage harsh environment cables.
NUMARC has extensively. interacted with the-staff on this matter..
Details of this work are reported in the-Industry Report on License Renewal entitled,
" Low Voltage In-Containment Environmentally Qualified Cables."
He stated that as' a result of meetings with the staff, the document will be revised, but for the most part the document is final.
Mr. Walters stated that Mr.
P.
Holtzman of STAR and Mr.
L.
Bustard, SNL will discuss NUMARC's concerns on the issues identified in the Industry Report
' Joint PLR/RQ 7
September 16, 1992 4
that is related to the staff's BTP on EQ of Electrical Equipment for License Renewal.
Electrical Eauinment. Current Licensina Basis Mr.
P.
Holzman.
NUMARC Consultant Mr.
- Holzman, stated that 10 CFR 50.49 addresses electrical equipment exposed to harsh accident environmental requirements.
The rule also requires specific consideration of aging for all equipment covered by the rule.
He presented an overview of the four methods used to maintain the current licensing basis (CLB) on EQ of electrical equipment. These involve reevaluation, requalifi-cation, refurbishment and replacement.
Reevaluation is based on improved knowledge or -information regarding the equipment.
Requalification, with respect to cable, involves retesting.to establish a new qualification basis. Refurbishment is maintenance, particularly including periodic parts replacement that is required in order to maintain qualification that has been determined in the qualification documents.
Replacement is an ongoing process when the qualified life of components expires or cannot be extended.
Mr. Holzman pointed out that these four methods are effective practices under the CLB for establishing and maintaining qualifica-tion and that these practices would continue for license renewal.
Mr. Holzman discussed qualification during the license renewal period.
For short-life components (qualified life less than 40 years) he stated that there is no aging degradation unique to the license renewal period because for these short-lived components periodic replacement will continue during the renewal period and the current methods to establish and maintain qualification does address aging for timeframes less.than 40 years.
For long-lived components (equal to or greater than 40 years), he noted that the CLB and rule do not explicitly limit qualification methodologies to a maximum qualified life of 40 years.
Further, that no technical issues appear unique to qualified life values beyond 40 years, and that existing CLB methods for maintaining qualification can be used to revise equipment qualified life values beyond the 40 years for the license renewal term.
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September 16, 1992 2
Mr. Holzman stated that one of the options available to revise qualified life values is reevaluation. He stated that reevaluation is a set of activities that reassesses the existing qualification data based on improved knowledge and data.
Reevaluation may also include supplemental monitoring and reconfiguration / operation changes.
When revaluation is not successful, requalification, refurbishment or replacement must be implemented.
Mr. D. Walters, NUMARC, stated that the CLB is not limited to 40 years, as the staff believes.
In reply to a question by Mr. Kress regarding industry disagreement with the staff on maintaining EQ during license
- renewal, Mr. Holzman stated that the industry believes that qualification in accordance with the DOR guidelines are acceptable means of demonstrating EQ during the renewal period.
In
- addition, Mr. Walters, stated that there is a second principle in the statement of considerations in the license renewal rule that says that the plant specific licensing basis must be maintained during the renewal term in the same manner and to the same extent as it was in the original license term.
In reply to a question by Mr. Lindblad, Mr. L.
Bustard, SNL, stated that moisture has a very i
minor impact on the aging rate of cables.
Industry Report on Low Voltace Environmentally Oualified Cable Mr.
L.
Bustard, Sandia National Laboratory (SNL)
Mr. Bustard stated that the Industry Report (IR) on cables has been submitted to the NRC.
Initial discussions were held with the staff and industry has responded to NRC concerns.
He stated that potentially significant age-related degradation mechanisms to cables are embrittlement of cable insulation and embrittlement of cable jackets. Further, current qualification practice is designed to-address the embrittlement age-related issue.
The IR provides a
several approaches for demonstrating qualification through the license renewal period.
They are reevaluation, requalification, and replacement which is consistent with the CLB.
He stated that reevaluation may demonstrate that extended life is encompassed by the existing qualification basis.
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September 16, 1992 o
In reply to a question by Mr. Ward, Mr. Craig, NRR, stated that the central difference of the staff's and industry position is that the staff believes that extending a judgement to grandfather a limited set of equipment without an engineering basis is unacceptable. The argument that has been presented, would have a cable that is not preaged, be qualified as indicated by industry for 100 or 150 years.
The staff don't believe that there is a technical basis for the industry conclusion.
Further, Mr. Craig stated that to his knowledge, there are no demonstrated methods to test cables in the plant to determine the extent of the degradation that exists today.
Additionally, Mr. Craig stated that it is the absence of tests, to
' determine the extent of cable degradation, that we believe is the reason for the need to preage and test.
The staff stated that if qualification was according to DOR guidelines, EQ by reevaluation is not valid.
NUMARC Summary Statements - Mr.
D.
Walters. NUMARC Mr. Walters, stated that the industry believe that the CLB provides adequate level of safety for the current and renewal terms.
Further, that qualification based on methodologies including the DOR guidelines can effectively manage aging during the renewal term.
NRR Summary Statements - Mr.
J.
Craia, NRR Mr. Craig stated that the BTP on EQ of electrical equipment should j
4 be made available for public comment.
He believes that the staff position is a balanced technical approach while the industry believe that the staff's approach are too conservative.
He stated that there is a substantial body of argument that states that the staff is not conservative enough.
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' Joint PLR/RQ 10 September 16, 1992 o
FURTHER SUBCOMMITTEE ACTIONS AND FOLLOW-UP ITEMS Further Subcommittee Action The subcommittee plans to refer this matter to the full Committee during the October 1992 meeting.
Follow-uo Item D.
Ward requested that Mr. Igne send a copy of NUREG/CR-5772, Vol 1,
" Aging, Condition Monitoring, and Loss-of-Coolant Accident (LOCA) Tests of Class 1E Electrical Cables," to the subcommittee members.
BACKGROUND MATERIAL PROVIDED THE SUBCOMMITTEE FOR THIS MEETING 1.
Memo for Raymond F.
Fraley, ACRS, from John W.
Craig, NRR,
Subject:
Request for Review of Branch Technical Position on Environmental Qualification of Electrical Equipment for 4
License Renewal, and enclosure entitled " Branch Technical Position PDLR SRP-LR F-2, Environmental Qualification of Electrical Equipment for License Renewal."
2.
NUMARC Report Number 90-08, "The Low-Voltage, In-Containment, Environmentally-Qualified Cable License Renewal Industry Report," dated July 1990.
NOTE:
Additional meeting details can be obtained from a transcript of this meeting available in the NRC Public j
Document Room, 2120 L Street, IN, Washington, DC 20006, (202) 634-3273, or can be purchased from Ann Riley and Associates, Ltd., 1612 K Street,IM, Suite 300, Washing-ton, DC 20006, (202) 293-3950.
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