ML20046A594
| ML20046A594 | |
| Person / Time | |
|---|---|
| Issue date: | 06/16/1993 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20046A579 | List: |
| References | |
| NUDOCS 9307290084 | |
| Download: ML20046A594 (10) | |
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R-ll ENVIRONMENTAL-QUALIFICATION (EQ) 10 CFR 50.49 g
y TASK ACTION PLAN l
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OFFICE OF' NUCLEAR-REACTOR: REGULATION q
. DIVISION OF SYSTEMS SAFETY AND ANALYSIS
. PLANT SYSTEMS BRANCH.
i BALANCE OF PLANT SYSTEMS SECTION PDRl r.......
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4 ENVIRONMENTAL QUALIFICATION (EQ) 10 CFR 50.49
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. TASK ACTION PLAN' LPurpose T_he purpose of this task action plan.(TAP) is to evaluate and resolve existing '
. environmental qualification (EQ) concerns and to identify and resolve' any other EQ issues that may exist.
Backcround As a result of the staff's activities related to l'icense renewal, EQ was identified as an area that required further review. ~As discussed in SECY-93-049, a major concern related to EQ was whether the EQ requirements for older plants were adequate to support license relewal.
Consequently ~, the staff concluded that differences in EQ requirements between older and. newer 1
plants constituted a potential generic. issue which should be evaluated 'for backfit independent of license renewal activities.
l In support of the license renewal initiative, EQ testing of electric cables was performed by Sandia National Laboratories TNL) under contract with.the -
NF'.
Some tests were performed.to determine t effects of aging on typical-m electric cable products used in nuclear power-p'. nts.
In. addition, other SNL-tests (unrelated to license renewal) were performed to assess the ' ' _
functionality of damaged electric cables duringl loss-of-coolant acc_ident conditions. - After accelerated aging, some_ of the environmentally qualified cables either. failed or exhibited marginal insulation resistance during -
accident simulation, indicating'that qualification of some electric cables may-be non-conservative.
Depending on the specific application,. failure of-electric cables _during or following design-basis events could compromise the 0
ability of safety-related equipment to function.
While some of the SNL tests may have been more severe than required by'NRC-regulations, the test results raise questions with respect;to the environmental qualification and accident performance capability of certain artificially aged equipment. The SNL test results are discussed in?
a NUREG/CR-5772, " Aging,' Condition Monitoring, and Loss-of-Coolant ( Accident (LOCA)' Tests of Class IE Electrical. Cables," Volumes 1, 2 and '3; NRC--
Information Notice (IN) 92-81, " Potential Deficiency of Electrical Cables with Bonded Hypalon Jackets," dated December 11, 1992;'and NRC Information Notice
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93-33, " Potential Deficiency of Certain Class IE Instrumentation and Control Cables," dated April 28, 1993. The SNL test results associated with LOCA testing of damaged electric cables (referred to in IN 92-81) are scheduled. to -
be published as a NUREG/CR in July 1993.
Independent _of the SNL tests, the NRC staff recently performed a preliminary ~
t risk scoping analysis to assess the potential impact of inadequate equipment qualification on core damage frequency. The scope of the analysis was limited to core damage prevention, considering internal events only with postulated
- failures of in-containment electrical-equipment, with. emphasis on electric-cables. The major conclusions of the preliminary risk scoping analysis are that (1) EQ failures could have significant risk impact if electrical ~
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component reliabilities are reduced in the presence of a harsh environment, (2) the magnitude of the impact on core damage frequency is plant specific, and (3) the lack of reliability data and limitations in current probabilistic risk assessment models result in :!gnificant uncertainty.
Based on the results of the preliminary risk scoping study, the staff concluded that a more detailed LQ risk assessment should be completed.
Separate from the license renewal and risk assessment activities associated with EQ, the staff recently completed an assessment of the NRC fire protection program in response to issues that were raised by the Office of the Inspector General (OIG) in a report dated August 12, 1992.
The staff's assessment of the fire protection program dated February 27, 1993, identified a number of' weaknesses and made specific recommendations for programmatic. improvements.
In view of the weaknesses that were identified relative to the' NRC fire protection program, the staff concluded that other programs such as EQ should also be reviewed to identify and correct any programmatic weaknesses that may exist.
Although the original issue involved whether the EQ requirements for older
_ plants were adequate for license renewal, the issue has evolved into whether existing EQ standards and regulations are_ adequate for all operating reactors.
With the preliminary risk scoping assessment indicating that inadequate EQ-could be a significant contr"iutor to core damage frequency, the staff has determined that focused 3taf? and management attention are necessary to fully address EQ concerns. This TAP will focus NRC staff attention to:
(1) evaluate differences that currently exist in EQ requirements between older and newer plants; (2) assess the adequacy of accelerated aging practices that are currently used for demonstrating equipment qualification; and (3) perform a F
programmatic review of EQ requiremants to identify and resolve any other EQ.
issues that may exist.
Although this TAP describes planned actions, it should be recognized that this is an evolving issue and the actions, as described,' may be modified as additional information is nbtained through further research and review of indusi-operating experi...ae.
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ENVIRONMENTAL QUALIFICATION (EQ)-
10 CFR 50.49:
TASK ACTION PLAN-Action Items 1.
Inform the Commission, senior NRC management, and the industry of the emerging EQ issue.
Scope - Activities for the Office of. Nuclear Reactor Regulation (NRR){
include preparation of NRC Information' Notices, a letter to the Commission, a Research User Need Request, and making a_preser.tation6atl the NRR Regulatocy Information Conference to inform the ne;essary: people.
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of the emerging EQ issue.
j Completion Date - 5/28/93 Status - NRR. issued Information Notice 92-81 on 12/11/92. an'd j
Information Notice 93-33.on 4/28/93. On 5/27/93, NRR issued a letter to the Commission on EQ. NRR staff presented a paper on EQ at: the: NRC 5
Regulatory Information Conference on 5/4/93. ' NRR staff made a-
"1 presentation on EQ to staff members of the House Subcommittee.o: Mining:
and Energy on 5/28/93..SPLB issued a Research User Need Memo on j
4/22/93.
j 2.
Encourage industry participation in identifying ae5 resolving' specific; EQ concerns.
j kgp_q -_ NRR activities will include initiation of.open exchanges--of--
information with industry groups. NRP. and the Office of Nuclear Reactor-Research (RES) will hold meetings with NUMARC, NUGEQ, and EPRI-to 4i apprise them of EQ review activities anu exchange information.): SPLB-f will be responsible for-coordinating acti Pies.with.these industry U
groups.
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Comoletion Date - Ongoing 4
Status - NRR and RES met with NUr4 ARC on 6/16/93.
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Programmatic Review 1
a.'
Review license renewal background information.-
Scope - The Plants Systems Bcanch (SPLB) of NRR will collect!and evaluate.information that has been developed during the last few years:
on EQ from the NRR License Renewal Project Directorate...SPLB will' review and evaluate the differences in the EQ ~ requirements and the basis.
Tj for the differences..
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y Completion Date - 7/93 c!
Status - SPLB has collected and reviewed the license renewal information'.
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EQ Action Plan page 2 pertaining to EQ. Currently, SPLB is in the process of documenting the results.
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Review Fire Protection Reassessment Report.
r Scope - SPLB will review recommendations from the NRC staff's reassessment of the fire protection program dated 2/27/93, and identify specific issues that could relate to EQ.
Completion Date - 7/93 Status - SPLB is reviewing the fire protection reassessment report.
c.
Elicit opinions from others (Regions, EQ experts).
Scone - SPLB will survey NRC regional offices, NRC headquarters, andL industry experts for potential problems with environmental qualification and evaluate the results of the survey.
l Comoletion Date - 12/93 Status - SPLB is developing the survey questions.
d.
Review existing EQ program requirements.
Scope - SPLB will review EQ program requirements to determine whether EQ issues, in addition to those already identified, exist'and need to be addressed.
SPLB will review 10 CFR 50.49, NUREG-0588,- DDR Guidelines, Reg Guide 1.89, IEEE/323-1971, IEEE/323-1974, etc. to determine'if i
potential programmatic problems exist.
Completion'Date - 8/93 Status - SPLB is' reviewing the EQ program requirements in order to-determine-if potential programmatic problems exist.
e.
Review NRC audit / inspection' practices.
Scope-.SPLB will review EQ inspection guidance and'a sample of reports:
from licensee EQ inspections and vendor EQ inspections-to identify-potential programmatic problems.
SPLB will review inspection findings, enforcement' policy (Generic Letter 88-07), enforcement actions, and-
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history.-
Completion Date - 10/93 Status - SPLB is scheduled to begin the review in August 1993.
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Review licensee implementation practices.
Epooe - SPLB will review and evaluate selected licensees' implementation'
EQ Action Plan page 3 of their EQ programs through site visits to determine whether problems exist.
Completion Date - 4/94 Status - SPLB will be coordinating the site visits with an SPLB contractor.' The site _ visits will be performed in conjunction with the contracted efforts stated in task 4.b.-
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Finalize Review Results Scope - SPLB will document and finalize the results of the programmatic review in a final ' report.
Completion Date - 6/94 Status - SPLB will prepare the final report after completion of the activities identified in 3.a-f.
4.
Data Collection and Analysis a.
Review published documents and industry reports pertaining'to-EQ.
Scope - SPLB and RES will review and evaluate information ab3ut aging to assess the validity of. qualification methods. The information to-be reviewed includes:
Sandia test reports (NUREG-5772, 3538,~3588, and others), NPAR reports,- information available from-international EQ/ aging studies (IAEA meeting in 6/93),'information fromLEPRI regarding test programs, and other information as identified.
SPLB and RES will review.
and evaluate vendor and licensee ' qualification test reports to determine -
the test conditions and results.
Completion Date - 4/94 Status - SPLB issued a Research User Need Memo onl4/22/93.
SPLB and RES are discussing the activities required and the individual responsibilities of each office.
SPLB expects a response from the user need request by 7/1/93, b.
Equipment Replacement Experience
. Scope - SPLB will make site visits to-a sample of plants to review.,
qualification tests, E0 binders, and maintenance and replacement records:
of EQ components. SPLB will review and evaluate equipment replacement.
schedules to provide insight as to where NRC should focus its resources'-
in the performance of EQ aging reviews.
Completion Data - 4/94 Status - SPLB and an SPLB contractor will be performing this task. SPLB' issued a 50W for contractor assistance to TAMS on 6/4/93.
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EQ Action Plan page'4 c.
Review operating experience data.
Scope - SPLB, with contractor assistance, will review Licensee Event Report (LER) and Nuclear Plant Reliability Data System (NPRDS) _ data, and will identify and evaluate whether ' environmentally qualified.
equipment is experiencing age-related degradation.
Completion Date - 12/93 Status - SPLB reviewed the LER data base that contains 72 reports of; cables that failed under normal operating conditions for -arious reasons. SPLB issued a S0W for contractor assistance to TAMS on 6/4/93.
The SPLB contractor will be conducting a more detailed review.
d.
Review TMI information via DOE.
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Scope - RES, with SPLB assistance, will obtain and evaluate _information N
on equipment failures during the TMI accident.
Completion Date - 4/94 Status - RES is contacting the Department of Energy to obtain information.
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EQ Data Base Scope - SPLB, with RES input, will develop an integrated data base using qualification test reports, research tests, and other test activities i
related to qualified equipment to provide a source of information for
_ future EQ activities.
Completion Date - 8/94 Status - SPLB will be developing the integrated data base in fiscal yearL 1994.
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Risk Assessment r
a.
Preliminary Risk Scoping Study Scope - The Probabilistic Safety Assessment Branch (SPSB) ~of NRR will' perform a preliminary risk scoping analysis to quantify the risk impact-of environmentally qualified electrical equipment.
Completion Data - 3/30/93 Status - SPSB completed a preliminary risk scoping analysis which was-issued on 4/8/93, in memorandum to T. Murley from A. Thadani.
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l' EQ Action:P1an
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- b. - Final Risk Analysis -
's Ec_qpe SPSB with contractor assistance will' perform a more detailed assessment of the risk. associated'with EQ' issues.. SPSB will incorporate?
results of other tasks into the final risk analysis..
Completion Date.- 10/94
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Status - The SPSB has a contractor working on the detailed assessment.;
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PRA Insights Scope - SPLB will coordinate with'SPSB and RES to incorporate insights 1
from PRA into the other tasks-in the action plan. Based on-the results' of the final risk analysis, NRC will. makela determination of the riskt significance of the differences in'EQ requirements.
Comoletion Dat'e - 10/94 Status - Preliminary risk scoping. study has been considered lin establishing tasks.of-the ' action plan.
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Technical Issues -
a.
Uncertainties associated with accelerated ' aging methodology.
Scope' SPLB will coordin_ ate with RES t'o develop and implement' a test program that evaluates. the use of accelerated aging in-the qualification L of safety-related equipment within the scope of 10 CFR 50.49.
Completion Date - 10/94 Status
.SPLB issued.a Research User Need Memo;on 4/22/93.::.SPLB and RESi are. discussing the activities required and the individual'-
responsibilities of each office. 'SPLB expects-a response fromithe' user need request by 7/1/93..
b.
Condition Monitoring Methods Scope - SPLB will coordinate with RES-to develop and, implement a: test'
-program to investigate and develop methods that can be' used for a
condition monitoring or inservice inspectionsLof qualified 'equipmentLto' determine the actual condition. of installed plant' equipment' ~
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Completion Date
.10/94.
Status - SPLB issued a Research User Need Memo on 4/22/93.
SPLB^and RES are discussing the activities' required and the ' individual responsibilities of each office..SPLB expects a response from-the user.
.need request by 7/1/93.
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. EQ Action Plan-
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Impact of new source term on'EQ.
Scope - Since the: usage of a new source term is'an..ongoin'g activity, SPLB.and ~ RES will follow its development and analyze its~; impact on:.EQ issues.-
' Completion Date --7/94 Status - SPLB and RES will start this effort in 1994.
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Options forLResolution Sfop_e - NRR and RES. will. develop options for the' resolution of EQi q
concerns, including' Generic. Letter,' rule. change, or documentation'of:
acceptability of the current EQ rule and standards.
In developing options, the staff mast consider the impact. of changes on
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license renewal, because the regulatory initiative-will carry over into!
the renewal-term.t The possibility 'of capture.of EQ condition; monitoring -
and upgrades'under the maintenance rule should be)considored. -.The '.'
resolution must address all EQ components ~and-should.not be; restricted:
to cables.
It may be, necessary to develop-new acceptance criteria for :
EQ testing, elongation testing, indenter 1 testing, etc.
Comolet' ion Date '- 10/94
~ Status..- N/A 8.
Implementation a.
NRC Regulatory Initiative Scope - NRR and RES will decide on appropriate.'regulsiory action; plan-and implement-the action; and documentithe basis for the action.
Possible actions to be considered by NRR and RES may include.~a Generic Letter or Rulemaking.
Comoletion Date =TBD c
Status - N/A b.
Industry Action /NRC Review and Verification Scope - NRR will' monitor licensee actions in' response lto the NRC staff's:
initiative on EQ.
NRR and NRC Regional Offices will verify that r
1icensees'have taken:. appropriate action _ to correct any EQ problems.
n Completion Date - TBD Status - N/A O
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JEQ Action Plan pageL7 r
ENVIRONMENTAL QUALIFICATION (EQ)1 10 CFR 50.49 TASK ACTION PLAN STAFF RESOURCE ESTIMATES
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NUCLEAR REACTOR REGULATION p
Plant Systems Branch (SPLB):
2.5-3.0 Professional Staff.
June 1993 through October.1994-Probabilistic Safety Assessment Branch (SPSB):
0.5 Professional Staff June 1993 through October 1994
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NUCLEAR REACTOR RESEARCH Electrical and Mechanical Engineering Branch (EMEB)-
2.0 ProfessionalEStaff June'1993 through:0ctober 1994 l
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