ML20053B094
| ML20053B094 | |
| Person / Time | |
|---|---|
| Issue date: | 03/03/1982 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | Advisory Committee on Reactor Safeguards |
| References | |
| ACRS-1952, NUDOCS 8205280026 | |
| Download: ML20053B094 (11) | |
Text
M8 ga g g '
fB J
DATE ISSUED: 3/3/82
- ]U $
L k L A a Mes-Md.t h3 0 ACRS QUALIFICATION PROGRAM FOR SAFETY-RELATED EQUIPMENT SUBCOMMITTEE MEETING FEBRUARY 10, 1982 WASHINGTON, D.C.
PURPOSE:
The purpose of the meeting was to review the NRC Equipment Qualification Program Plan as outlined in SECY 81-504 and discuss some questions posed by M. Bender relating to the requirements of IEEE Standard 323-1974.
ATTENDEES:
Principal attendees of the meeting include:
ACRS NRC r-O J. Ray, Chairman Z. Rosztoczy J. Ebersole, Member G. Bagchi gECEft'ED gy g
I. Catton, Consultant S. Aggarwal W. Lipinski, Consultant H. Garg
")
1 nac
//
J. Kennedy g
R. Riggs p
~
P. Shemanski l
l l
A complete list of attendees is attached to the office copy of these minutes.
MEETING HIGHLIGHTS, AGREEMENTS, AND REQUESTS 1.
In Open Executive Session, the Subcommittee discussed a proposed review plan of the NRC Equipment Qualification Program. The following comments were noted:
Dr. Catton feels the codes used to describe the type of environment the 0
equipment will be qualified to are deficient. Mr. Ebersole said that the equipment should be qualifided to demonstrate operability under accident conditions (rated flows, etc.).
He also said it may be possible to locate equipment in non-hostile areas (out of containment), but even here consider-ation should be given to the possibility of hostile exposure to accident or error (inadvertant spraying of equipment, etc.). He also said that in his view there is a lack of information on the capabilities of valves (MSIVs and PORVs) to meet qualification requirements.
""" Som 8205280ccG canc, g,_ 739p
Qualification Program Meeting 2/10/82
' The Subcommittee endorsed the idea of visiting the relevant test laboratories to review test procedures, equipment, etc. Dr. Catton suggested the Subcommittee track a piece of equipment through the entire qualification process to obtain a comprehensive understanding.
- Mr. Ray suggested that the Subcommittee interact with relevant Industry groups in this area. Dr. Lipinski said that AIF should be included as well. Dr. Rosztoczy (NRC) noted that EPRI, W, and GE have Equipment Qualification Owners Groups and AIF has a Subcommittee on Equipment Qualification. NRC is actively working with the AIF Subcommittee and to date four AIF Position Papers have been developed.
Mr. Ray said NRC should provide a response oi' some kind to the Position Papers and the Chairman also urged NRC to make maximum use of Industry expertise in a cooperative effort to resolve the whole issue of equip-ment qualification.
- As a result of Subcommittee discussion, Mr. Ray said it will be necessary to coordinate with the Seismic and Fire Protection Subcommittees on the review of seismic and dynamic equipment qualification (EQ) and qualification for a fire environment, respectively. Dr. Rosztoczy said that his Group does not review equipment for fire qualification. Mr.
Ray also said it will be necessary to interact with the Class 9 Subcom-mittee on the issue of hydrogen environment qualification.
- The Subcommittee needs to determine the role of the Committee for Review of Generic Requirements (Stello's Group) in this NRC Program.
' Mr. Ray told NRC that the Subcommittee would like to coordinate its review with the pace of the Equipment Qualification Program Plan activities so the Staff can provide maximum participation.
2.
NRC provided responses to Mr. Bender's questions on IEEE 323-1974 require-ments. The questions and NRC response are noted below:
Q.1 "Does environmental qualification really demonstrate an ability to l
function in the event of conditions such as potential flooding, L
/
Qualification Program Meeting 2/10/82
.g vibratory motion from a seismic event, gamma radiation, high temperature, high humidity, or live steam conditions?"
NRC said the scope of qualification includes environmental, seismic, and dynamic effects for electrical and mechanical equipment. Nine qualifica-tion parameters were cited (temperature, pressure, radiation, etc.).
Qualification must apply to nomal operation, maintenance, test, and accident environments.
IEEE 323-1974 requires sequential testing and the assumption of an accident at the end of " qualified life" where the companent must demonstrate functionability.
During extensive Subcommittee discussion the following points were noted:
- Dr. Lipinski suggested that NRC compare naturally aged equipment with an accelerated aging test in order to verify the Arrhenius relationship and test procedtres. NRC-RES responded that they are attempting to obtain 8-10 year old equipment to verify the accele-rated aging procedure.
- In response to questions from Dr. Lipinski and Mr. Ebersole, NRC said most equipment is seismically qualified by analysis. Dr. Catton
~~
observed that LERs show equipment failure due to flow vibration. NRC i
said RES will be studying vibration loads.
Q.2 "Does " type" testing of selected components and equipment provide a reliabile test for production equipment that will experience a variety of operating and maintenance transients during a 40-year lifetime, including potential abuses from operator / maintenance errors, physical damage, etc.?"
l ~
l NRC indicated that reliance would be placed on the margins inherent in equipment design and a comprehensive maintenance / surveillance program, which includes plant experience data, LERs, and trend analysis to assure operability over the lifetime of the equipment. Mr. Ebersole suggested in-situ testing of vital equipment (spray it down, etc.). NRC said they
ma.
Qualification Program Meeting 2/10/82 would not recommend this, partly out of concern of damaging near-by non-qualified equipment.
Q.3 "Does the specific location of such equipment in the containment build-ing influence the potential for unanticipated or extreme environmental conditions and the potential for interaction with systems not covered by the qualification program such as fire mains, service air, component cooling water systems, etc.?"
Three main points were made by NRC in response. These were:
(1) NRC's job is to " anticipate the unanticipated". This will surface through the LER process.
I&E will review unanticipated EQ events; (2) the Licensee identifies plant zones on an environmental basis.
Extreme local conditions such as containmrit stratification, pipe rupture or radiation are considered, and (3) systems interaction is also considered in the scope of the Qualification Program.
In response to Dr. Catton's question, NRC said C. Michelson oversees all LERs in a watch dog role.
I Q.4 "The value of this massive qualification program could be negated if a weak link exists because some element had not been properly qualified.
The weak link question applies especially to electric circuitry, signal transmission devices, or activation equipment. For example, failure of
~
a fire-damper actuator might negate the value of a qualified fire wall."
The EQ program / criteria establish minimum requirements for demonstrating Class IE equipment and system qualification essential for six major safety functions (scram, containment isolation, intial core cooling, containment haat removal, decay heat removal, and preventing release to the environment.)
An additional class of non safety-grade equipment, whose failure would negate any of the above six functions, is also included in the EQ requirement.
"Please comment on the suggestion of performing a survey (using a NRC Q.5 contractor) of a plant (such as Commanche Peak) to determine if the 323-1974 requirements will achieve the desired high reliability noted above."
e I
Qualification Program Meeting 2/10/82 It was noted that a NRC site audit is usually performed at all plants.
Selected electrical and mechanical equipment is reviewed which includes inspection of on-site installation and a documentation review to establish whether the particular equipment design meets qualification requirements.
For a new plant, equipment reliability can only be determined through a challenge because there is no history of operability. NRC recommends a study of select equipment types including a review of manufacturer and vendor tests and development of an equipment performance data base to assure equipment relability vis-a-vis 323-1974 requirements.
In response to Subcommittee questions, NRC said all operating reactors were reviewed last year and equipment audits were conducted at some pl ants.
Dr. Catton cited a test in Gemany where a primary system blowdown into containment caused extensive equipment damage and mis-location at a considerable distance from the energy source. NRC agreed that influence on equipment from such sources should be examined.
3.
Dr. Z. Rosztoczy presented an overview of the NRC Equipment Qualification Program. The 8-year program includes the following objectives: (1) review safety-related equipment in operating plants - identify shortcomings -
enforce corrective action; (2) develop a standard review procedure; (3) develop analyses and experiments in support of reviews and rules; and (4) test selected components. Figure 1 is a organization chart of the EQ Program that details the five main program elements detailed below.
NRC discussed the plan for development and implementation of the Rule and Regulatory Guide for seismic and dynamic qualification of equipment (Fig 2). Dr. Rosztoczy said that full implementation will not be complete for operating plants until 1989. Mr. Ebersele expressed concern on the length of time required noting that the SEP Program has uncovered many deficiencies in the older plants.
NRC said the main reasons for the
~
stretch out are: (1) there will be no enforcement action until the Rule is in effect; and (2) corrective actions required will be held to refueling outages.
l e
i
~
Qualification Program Meeting 2/10/82 4.
Mr. P. Shemanski discussed the Program Subelement dealing with environ-mental qualification of electrical and mechanical equipment in both mild and harsh environments.
Key points of the presentation included:
' Environmental Qualification criteria for electrical equipment will be included in the proposed rule (50.49) now out for public comment. An associated Regulatory Guide (1.89) will be issued in the immediate future. All ope:ating plants have been reviewed for exposure of electrical equipment to harsh environments and SERs have been issued. The eqilipment must conform to qualification requirements by November 30, 1985.
- An equipment qualification data system is being established. This system will eventually include all licensee submittals on electrical, seismic, and dynamic qualification of both electrical and mechanical equipment.
- The proposed electrical equipment Rule (50.49) may require qualifi-cation of equipment essential for cold shutdown.
- Resources 'or FY-82 include 7 staff years in the EQ branch, 3 staff years in ISE, plus aid from Franklin Research Center and INEL.
5.
Mr. G. Bagchi discussed the Program Subelement addressing seismic / dynamic qualification of electrical and mechanical equipment. NRC will codify explicit rules for equipment qualification through industry standards and l
regulatory guides. The staff will upgrade both voluntary industry qualifi-cation programs and testing laboratory accreditation. Equipment qualification will be established by generic envelopes. New plants will be subjected to the revised Standard Review Plan (SRP) and the new Rule that should be effective in 1984.
NT0L Plants will also be subjected to the revised SRP and Reg. Guide 1.89 and 1.100 requirements. There will also be an on-site audit of selected equipment. Operating plants will be subjected to a cost /
benefit study as well as the requirements of the Task Action Plan A-46 t
Qualification Program Meeting 2/10/82 g
(" Seismic Qualification of Equipment in Operating Plants") before any further rule requirements are imposed. As noted above, completion of corrective action for operating plants would not be complete before 1989.
Problem areas noted included:
' seismic anchorage found deficient in all SEP plants as well as auxiliary feedwater systems in some newer plants.
- Because of problems encountered in testing and associated documentation, installation schedules for qualified equipment are slipping in NT0L plants.
It was also noted that the ACRS review is conducted well before the 1ssociated site audit.
6.
The status of NRC rulemaking efforts associated with equipment qualification were discussed. Highlights included:
' The proposed Rule on electrical equipment qualification is out for l
public comment. The comment period closes on March 22, 1982. NRC wants to meet with this Subcommittee and the ACRS in May to discuss the final rule before meeting with the Commission in June 1982.
- An Advance Notice of Rulemaking covering seismic and dynamic l
qualification of electric equipment and environmental, seismic, and dynamic qualification of mechanical equipment will be published in I
l the Federal Register in May 1982.
A proposed Rule for public comment should be issued in October 1983, with a final rule in August 1984.
- A proposed rule on testing laboratory accreditation will be discussed with the ACRS Regulatory Activities Subcommittee in early March.
A proposed rule will be published for comment in April 1982 with a final rule due in August 1982.
Associated Regulatory Guides 1.89 (Environmental Qualification of Electric Equipment) and 1.1000 (Seismic Qualification of Electric Equipment) l will be issued for public comment in March, and are being revised l
by the staff, respectively.
Qualification Program Meeting 2/10/82
?
7.
Dr. Rosztoczy discussed the Equipment Qualification Test Program Subelement.
There are five main efforts here. These are: (1) accrediation of test facilities (IEEE will conduct accreditation program - NRC will review the IEEE program requirements and manual); (2) NRC review of Industry test programs (NRC will inspect selected test programs - in the future the Region IV Office will assume lead responsibility in this area; (3) NRC review of test reports (a fraction of reports referenced in OL applications as well as NSSS suppliers generic equipment qualification reports); (5) development of equipment qualification technology (study of failure modes, establish margins to failure, etc.).
8.
The Program Subelement addressing equipment survivability in hydrogen environment was discussed by Mr. H. Garg. NRC has met with the ACRS on the topic of hydrogen control for ice condenser plants in 1981. There have been two hydrogen - related rules issued. A final rule on hydrgen control in Mark I & II plants was issued on December 4,1981, and a proposed rule for Mark III and ice condenser plants was issued for public comment on December 24, 1981.
Mr. Garg showed some test results of hydrogen burns done in support of the igniters installed in the TVA ice-condenser plants. The results indicated that the relevent equipment could survive and function in an
'~
expected hydrogen environment. However, there are a number of uncertainties l
in the hydrogen test results to date due to scaling effects, accident scenarios, test parameter sensitivities (the flame speed etc.) such that additional work is required.
9.
Dr. Rosztoczy noted the following near-term activities of the qualification Program.
- Final version of the electrical equipment qualification rule to be issued in June 1982 (ACRS review scheduled for May 1982).
1
- A laboratory accreditation rule will be issued for public comment in April 1982 (discussion with the Regulatory Activities Subcommittee scheduled for March 1982).
\\
T 3
Qualification Program Meeting 2/10/82
~
- A revised version of the NRC Equipment Qualification Program Plan (SECY-81-504) should be issued next month.
' NRC would apreciate the Subcommittee's comments on the hydrogen Rules noted above from the standpoint of input on equipment quali fication.
The meeting was adjourned at 5:10 p.m.
NOTE: Additional Meeting details can be obtained from a transcript of this meeting available in the NRC Public Document Room,1717 H Street, N.W.,
Washington, D.C., or the transcript can be purchased from Alderson Re-porting Company, Inc., 400 Virginia Avenue, S.W., Washington, D.C. 20024, (202) 554-2345.
l l
l l
I I
I I
i 8
- x-t
=.
=
3 2
e en 9
2 3
-.g a} e
[b'.
e as
=
~>
p-e1s[.!ite e
[ sa 1
al s al:.
ma I
s.
v.
E...
- k. w,.
5.u.
s e
E' 1
I dy !e a
I t
- y D g.
5 s
j-T:
gg%
-; a; 5 *2 E
~2>I
~ I-1 :tI
.5-s
^z Ia5:
ta e-s g
e b >.
u g
g p--
em ct 8 n:R-
.g--
4 u-E 2
ig i q&=
.it E$w;e gg s m
wn A x: a J
Li i ns
-s I
i 1
1 3
Id 2
3b
- 5 g
- 5 I
x la g s =:,
g s. g sg f
~
Ag_%
e
-tes me
-s
-.E:
b3ys kiEj h2R3 g
- T 1g E
I
-3 2.wr a-pa p--r y
=7s
!=.
s C e as i au.
as 2
aa
- 5 E
I I
I I
1
=
.4 1
a It am
- 3 g g
E2 3k
". g 3
t eIm a st g
s=E.
seu El te s l
gE.
E
.; m 2
=
l z:
S-3a w <
a En p
m=
a
=
l 1s i-i-
i n
.!g ag!
h 3
I I
- i. }>Es 27ss
. Es
=
s ml=,
- s esa:
n x_e]
- nv 4-E p
gasj i
3,=
een vv -
re--
vs 3a 3
4 C2 4 CE 4 d6 i wain C
f/4 1)
. w..
~.+.-.
n..,
'l- - - -
/Y/illi,,- (t W M. ' N u
SEISMIC & DYNAMIC QUALIFICATION l
ys;!t D'
/(@v (1771MS '
7 h d.g,tm M I V:
I
,jp,h /f
?
l REQUIREMENTS ADVANCED PUBLIC DEVELOPMENT FOR PLANTS NOTICE OF C
TS OF RULE '&.
LICENSED AFTER RULEMAKING REG. GUIDE 1975 5-1-82 7-1-82 8-1-83 l
'/ /
/)ft
'1*' #
EXPERIENCE REQUIREMENTS COST-BENEFIT GAINED FROM
& PROCEDURES ANALYSIS SEP & NTOL
~
FOR OR-s REVIEWS A-46
. d' -
1
/
s ISSUANCE OF PUBLIC RULE &
LICENSEE'S NRC CORRECT!Y e
10-1-8k (EPLACEM
=
S COMMENTS REG. GUIDE REVIEW r
REVIEW 10-1-83 3-1-84 10-1-85 R
10-1-M I
Ng e
s S
- - ~ ~ * " " "
~~~
^*
I,
~v J
a e
-