ML20153G436
| ML20153G436 | |
| Person / Time | |
|---|---|
| Issue date: | 04/14/1988 |
| From: | Jordan E Committee To Review Generic Requirements |
| To: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20153G441 | List: |
| References | |
| REF-GTECI-A-40, REF-GTECI-SC, RTR-REGGD-01.100 NUDOCS 8805110236 | |
| Download: ML20153G436 (26) | |
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, [ga C8%'e,, , UNITED STATES (W d r ('Etos.54rp y 3 .cq g NUCLEAR REGULATORY COMMISSION l wase.oros. o. c. rosss April 14, 1983 k+..../
MEMOP,ANDUM FOR- Victor Stello, Jr. Executive Director for Operations FROM: Edward L. Jordan, Chairman Comittee to Review Generic Requirements
SUBJECT:
MINUTES OF CRGR MEETING NUMBER 129 The Comittee to Review Generic Requirements (CRGR) met on Tuesday, February 23, 1988, from 1-4 p.m. A list of attendees for this maeting is enclosed (Enclosure 1). The following items were addressed at the meeting:
- 1. G. Arlotto (RES) and S. Aggarval (RES) presented for CRGR review proposed final Revision 2 to Reg. Guide 1.100, "Seismic Qualification of Electric and Mechanical Equipannt for Nuclear Power Plants," endorsing (with two exceptions) existing industry standard IEEE Std. 344-1987. The Committee recomended in favor of issuing proposed Revision 2, containing only one of the two proposed exceptions (Positions) and other minor wording changes, as an effective Reg. Guide for use by licensees / applicants. All the recommended changes are to be coordinated with the CRGR staff. This eatter is discussed in Enclosure 2.
- 2. The Comittee reviewed a proposed NRC Bulletin, "Inadequate Latch Engage-
- ment in GE HFA Type Relays" requesting a one-time inspection of all HFA relays used in Class IE service at affected facilities, and repair or replacement of relays that fail to meet specified criteria provided by the relay vendor. The Comittee recommended in favor of issuing the proposed bulletin, subject to two substantive changes and several minor worm ng modifications (to be coordinated with the CRGR staff). This matta is discussed in Enclosure 3.
- 3. The Comittee reviewed a proposed Generic Letter backfitting a requirement that each PW licensee implement a program to detect, locate, evaluate, and repair borated water leakage that could degrade the reactor coolant boundary. The Committee recomended in favor of issuing the proposed Generic Letter subject to several worcing changes (to be coordinated with the CRGR staff) and notification of INPO in accordance with the NRC/INPO Memorandum of Understanding. This matter is discussed in Enclosure 4.
In accordance with the E00's July 18, 1983 directive concerning "Feedback and Closure on CRGR Reviews," a written response is required from the cognizant office to report agreement or disagreement with CRGR recomendations in these 1 9, 6 IL 0 2 2]o yA zgg3,%
2- , _ t r i minutes. The response, which is required within five working days after ,
! receipt of these meeting minutes, is to be forwarded to the CRGR Chairman and if there is disagreement with the CRGR recommendations, to the EDO for decisionmaking.
Questions concerning these meeting minutes should be referred to Jim Conran (492-9855). ' ensed ap.d er, j , t03rde Edward L. Jordan, Chairman i Committee to Review Generic li j Requirements s i i j Enclosures. As stated 4 , l cc w/ enclosures:
- Commission (5) i SECY j Office 01 rectors j Regional Administrators
] CRGR Members 4 W. Parler . I G. Arlotto S. Aggarwal L. Shao l C. McCracken ; i E. Rossi ' ] C. Berlinger ! Distribution: w/o enc 1. 1 Central File CRGR CF (w/ enc.) ! POR (NRC/CRGR) M. Taylor (w/ enc.) " , S. Treby J. Conran (w/ enc.) i i W. Little J. Heltemes (w/ enc.) l
- M. Lesar E. Jordan (w/ene.) ,
. E. Doolittle (w/ enc.) C. Sakenes (w/ enc.) l CRGR SF (w/ene.) ; I i l OFC :CRGR:AE00 : AE0Q:,00 :C/CR :IE0DD: : : : f
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! DATE$#4/ 8 /88 $ 4/ '/88 - 4/l&88 $ $ I l .
- 0FFICIAL REC 0r.0 COPY I I
t t Enclosure 1 1 ATTENDANCE LIST CRGR MEETING NO. 129 l February 23, 1988 : t CRGR E. Jordan R. Bernero D. Ross f j J. Scinto ' J. Sniezek P. Stohr OTHERS j D. Sullivan t R. Bosnak l L N. Anderson T. Marsh t. S. Aggarwal t G. Arlotto l P. T. Kuo M. Vagins C. Berlinger ! J. Stone ! K. R. Naida E. Doolittle E. Rossi ! L. Shao ! C. McCracken t K. Parczewski ; I i I
Enclosure 2 to the Minutes of CRGR Meetina No. 129 Proposed Final Revision 2 to Reg. Guide 1.100 February 23, 1988 TOPIC G. Arlotto (RES) and S. Aggarwal (RES) presented for CRGR review the proposed final Revision 2 to Reg. Guide 1.100, "Seismic Qualification of Electric and Mechanical Equipment for Nuclear Power Plants," which endorses (with two exceptions) existing industry standard IEEE Std. 344-1987 as acceptable for i satisfying NRC regulatinns pertaining to seismic qualification of electric and mechanical equipment. The draft version of this Reg. Guide revision was l reviewerl by CRGR at Meeting No. 97 in October 1986; after evaluating public ) comments received, the staff is now proposing to issue the proposed final Revision 2 as an effective Reg. Guide for use by licensees / applicants. Copies l of briefing slides used by the staff to guide their presentation and i discussions with the Committee at this meeting are enclosed - (see Attachment to this Enclosure). BACKGROUND The documents submitted for CRGR review by the sponsoring office (RES) in this matter were transmitted by memorandum dated January 25, 1988 E. S. Beckjord to E. L. Jordan; the review package included the following documents:
- 1. IEEE Std. 344-1987, "IEEE Recommended Practice for Seismic Qualification of Class IE Equipment for Nuclear Power Generating Stations"
- 2. Seven "Public Comment" letters on Draf t Reg. Guide 1.100, Rev. 2 from:
- a. ASME, Task Committee on Seismic Performance Qualification of Mechanical Equipment (J. D. Stevenson)
- b. Duke Power Company (H. B. Tucker)
- c. TVA (R. Gridley)
- d. IEEE, Nuclear Power Engineering Committee, Subcommittee 2, Working Group 2 (G. D. Shipway and K. M. Skreiner)
- e. Wisconsin Electric Power Company (C. W. Fay)
- f. Seismic Qualification Utility Group (N. P. Smith)
- g. ASME, Committee on Qualification of Mechanical Equipment Used in Nuclear Power Plants (K. Ennis)
- 3. Resolution of Public Comments
- 4. Revision 2 to Reg. Guide 1.100, dated December 1987
i l o I .
- I i
! CONCLUSIONS /RECOMENDATIONS As a result of their review of this matter, including the discussions with the l staff at this meeting, the Committee recommended in favor of issuing the '
! proposed Revision 2 as an effective Reg. Guide, subject to one codification j (to be coordinated with the CRGR staff), as follows: , 1 J Regulatory Position No. 2 at p. 4 of proposed Revision 2 should be , i deleted as a Position; but the wording indicating that the NRC staff will i evaluate proposed use of experience data by licensees for equipment t qualification on a case-by-case basis (at least for the present) should ! j be retained and moved to the "DISCUSSION" section of the Reg. Guide. l l l l l 1 ! l i J i i i i l l } l l l l 1 l
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i t i I r l P.svisiott 2 To REGULATORY GUIDE 1.100 : (EFFEECT!VE GUIDE) [ a : d : SEISMIC OlRLIFICAT!Ctl 0F ELECTPIC NO MECWICAL l i s s EQUIPEhi FOP IklEAP PCNEP PLN.Ts i i t i, ! t PPESEUTED BY i SATIFH K. AcGPWAL
- {
t l CRGR REVIEW PEETIPG 4 i
- FEIWUAPY 23,1988 F 1
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! i l , t t j Attacheent to Enclosure 2 i b i l 1.__,_,_.,..____ _ _ _ _ _ _ . _ , - _ _ , _ _ . _ _ _ _ . _ _ . . . _ _ _ _ _ _ _ _ . _ . _ _ _ . _f
i BACKGR0 LAD CPGR REVIFW: 97m WETING - OCTCEEP 1,1986 , PAlti CONCERN: SECTION 8.3 No SE", TION 9 0F IEE !iTD. 344-1987 APE THESE SECT!Cf'S CONSISTENT WITH TE RESOLUTIMI 0F llSI A-467 STAFF PESPN'!E: "YES' PUBLIC C&tTNTS WERE SPECIFICALLY REQUESTED IN THIS APF). ACES REVIEW: 326TH KET!!!G - JUNE 4-6,1987 ISEVED FOP PUBLIC CCfWJ'T N! AUGUST 26,1987. CCetttIT PEPIOD D'PIRED ON OCTOBER 30,1987.
O O 8 PtBlic CMBTTS AfD RESOLUTIONS : SEWN CMBTT LETTEPS IN 4 PAIN AREAS (1) APPLICABILITY OF IEEE STD 3@-1987 To mowl! CAL EQUIPMNT j RESoLUT10ti: [ l STAFF WILL PEV!Ew ASPE STMOAPD UP0fl ITS FUBLICATIOff FOP SUITABILITY FOR EP'DOPSEPBC. ! i j PPOPOSED CWCF (PAGE 3): IN EXTEPO!?)G Tm APPLICATINI 0F IEEE STD. 344-1987 TO wCHMICAL EQUIPmtU, TFE
- M. STAFF PFCOGt!!7FS THAT THFPE APE DIFFEPFP)CFS IN CUALIFICATINI NDS FOP l
ELECTPic mfd MECW'ICAL FOUIPNPIT. SPECIFICALLY, OUALIFICATIN! CF EOW81 CAL i q FCUIPMENT BY 4'ALYSIS IS PFFNITTED wet' SUCH E0VIPP'EPR C#1 BE KDELE' TO ADE0llATELY PPFDICT ITS OFSPMISE. THE AwPics SOCIFTY OF ftCHnf!C/1 EP'GINEEPS ]
; is CupPFtrrtY DEVELOPING A STMDAeD FOR SEISNIC 00ALIFIC/$TIOt( DF TCW'ICAL FQlllPt'EPU UPN' PlH.lCATINI OF THIS STNTWPDg W flRC STAFF WILL REVl91 IT FC# f SUITABil.lTY Fff EPDORSEPSU BY A PEVISIN,' TO THIS REGUL ATORY GUIDE. !
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(2) DIFFEPEtlCES !!! QLVLIFICATitti ttT} cpg p0P ELECTRIC ND MECHhtllCAL EQUlFMEllT, REEDLUTlrt1: (SEE PREV 10U5 V1EhGPAPH),
(3) SCOPE: EXMPLES OF KCHANICAL ECUIPMEtiT SUPPORTS 8 (P!PE SUPPORTS, SUBBERS, PESTPAltfTS Af D HNGEPS) RESOLUTICt': PEFERE?CE DELETED. (FEE PAGE 3)
0 # (4) Ut1PESTPICTED USE OF SIU3 EXPERIENCE DATA 4,Ti GEt!EDIC IPPLENNTAT!rti PROCEDURES (GIP) FOR FtmJPE PLMITS. ESOLUTI0ti: TE STAFF RECOGNIZES TMT A PAPIDLY DETTLC?!NG NT.A IS TE USE CF EXPER!EDCE DATA FOP SEISMIC QUALIFICATION. THE BlLK OF THE GlP HAS BEEN CCMLETED #tD i MS BEEff PEVIEWED BY TE NRC STAFF MID SSRAP. Tm GlP IS STILL LtOER DEVELOPENT , MO, EVEN WHEN CCWLETED WILL POT COVER ALL SAFETY-PELATED EQUIPP91T. USE OF EXPERIENCE DATA IS PEPM11TED, BUT CtJLY /JTEP A CASE-BY-CASE PEVIEW BY W E fEC STAFF. i P t I i a ! ,i t f i i I I l t
8 e ) CPGP PAlti CacEPtJ: CCNTSITUCY SECTICt' 8.3 Atm SECTlal 9 - A46 REscttfria' N0 mERsE CcwE?T.9 PECEIVED. STAFF PO!!TINI IS PEAFFIPPED. i l 1 l 1 1
. COMMITTEE CORRESPONDENC.E .s l } -Keep ASME Codes and Standards Departrnent Informed- r ',,' ., i .' . .
c 1 COM M nTTEE: ADDRESS WRITER CARE OF: R. E. }liller SUBJ ECT: " 0 # AS!I QtI Standard *"I Appendix A on Seismic Qualification Charlette, North Carolina 232!.2 NRC Regulatory Guide .. 00-Revision DATE: December 8,19;s7 COPY T01 TO: Kevin Ennis The t'R C received your letter dated 2.'oveeb e r 30, 1987 regarding O!I 's reconmended revision to the draft regulatory guide. On 12/4/87, 1 received a call from one of the t:RC authors of the regu t.a t ory guide who proposed alternate wording to that submitted by Q)2. I am attaching page 3 of the retulatory guide, Q:I's proposed revision and the proposed wording by ! RC for disttibtition to Cl2 connittee nenbers as information. Even though the Nr.C's wording, is brief and addresses only seisnic q ua li fic a t i on , it will suffice in the regulatory guide untti such time our standard is published. The fact that the regulatory guide acknowledges the AS:I Q?I effort vill result in users contacting us on various qualification problees and needs. Best wishes and happy holidays. p
- f. E. Miller, Chairman A5!I QMI RIM /l:p Atttennent
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NovtMeEn 2 ; 1337 37 h5 30 A7 50 ,, g,,3l'<*V If / L-87-441 gg l: l{ 39 7 N The Rules and Procedures Bronch Division of Rules and Records Of fice of Administrollon U.S. Nuclear Regulatory Commisse. Woshington, D.C. 20555 Gentlemen /Lodiest i F lorida Power and Light Company (FPL) is pleased to submit its comments'on the Preposed Revision 2 to Regulatory Guide 1.100 "Seismic Ovalific6 tion of . Electrical and Mechonical Equipment for Nuclear Power Planjs".' We have reviewed proposed Revision 2 to Regulator)4 vide 1.100 together with IEEE 344 87 (wNeh it proposes to endorse) plus IEEE 3405 ondiliivision I to Regulatory Guide t.100. - , FPL'r. comments, in summary, are os follows: (1) IEEE 344-87 locks definitions for many terms used in the stonderd. (2) IEEE 344-87 contains errors in porograph cross references. (3) Proposed Revision 2 to Reg. Guide 1.100 extends the scope of the Clcss IE electrical stoMord to a wide range of mechanical equipment. , (4) It oppears to be the Intention of the NRC to try to use proposed Revision 2 to Reg. Guide 1.100 in the resolution of USl A-46 throup odoption of the new "experience" provisions for quulification and the extension to mechanical equipment. Our detailed comments and recommeMotions are provided in the ottochment. Thonk you for allowing FPL the opportunity to comment on the proposed Regulatory Guide Revision. Very truly yours, 4 g// C. O oody
- Group Vice President Nuclear Energy COW /JPS/gc At tochment / 9 ,
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; Concern 1: Lock of Defintflons in !EEE 344 87 i IEEE 344-87 deleted the definitions in IEEE 344-75 for the following terms yet continued using the terms in the text.
. Class IE (*N.B.')
. ossembly l
. device :
. frogility ;
. frogtlity level
. frogility response spectrum '
. Iow cycle fatigue
. malfunction ;
. octave l Also, IEEE 344-87 uses the following terms in the text but does not provide any (
l, definitions for them. !
. so?ety function f
. octive function l
. non safety related ,
j . safety devlees !
; . spurious function ,
- . safety related devlees l 1 e i Since it is the intent of proposed Revision 2 to Reg. Guide 1.100 to encompass
*sofety related" o .d "important to saf ety" mechanical and electrical equipment, a
'I clear understonding of the NRC's perception concerning all the new terms f j containing the words "safety" is necessary to ovold future confusion, j
-{ Recommerdotion I !
i ! l Proposed Revision 2 to Reg. Gulae 1.100 should contoln definitions for all of the [
- terms on the preceding list and a clorificotton that the new references to "sofety", ;
i and "safety related" are equivalent to the old references to "lE" which itself needs , to be defined as it was in the previous stondord. ( r j Concern 2: Porogroph Cross References 1
, I l IEEE 344-87 contolns errors in poregraph cross references which need to be l Identified and corrected in the interests of clority, j ] Examples (1) Par. 3.4 refers to Section 9 for equ1pment speelficottons but they J ore found in Section 10.
J l (2) Por. 4 refers to Par. 6.5 and Por. 7.l.5.1 for the OBE but it is , found in Por. 6.6 ond Par. 7.l.5.2. l 4 i i ! JRL6/017/2 i - d I
(3) Par. 8.3.1 refers to Par. 7.l.3 for exploratory tests but they are found in Por. 7.l.4. . (4) Por. 7.6.3.1 refers to Por. 7.6.l.2 for domping volves but they are found in Por 7.6.l.3. (5) Appendix D refers to Par. 6.5 for input woveforms but they are found in Por. 7.6.5. (6) And so forth. Recommendation 2 , Proposed Revision 2 to Reg. Guide 1.100 should identify and correct all cross reference errors in IEEE 344-87. Concern 3: Extension of the Scope to include Mechonteel Equipment Stondord Review Plon (SRP) 3.10 previously extended the scope of IEEE 344 75 in o general way to mechanical equipment (and to nonsofety reloted equipment whose failure cov!d prevent the sot!sfoetory accomplishment of sofe!y fune:' ,.) The proposed Revision oppears to occomplish the SRP objectives ord much more i and at the same time impose additional requirements on mechonical equipment not in the SRP. l The result of this odd-on" process in the proposed Reg. Culde is to take o stondord originolly interded for safety related/ Class IE electrical equipment ! (developed through the ANSl/IEEE consensus process) and transform it into o l stondord for snubbers, restraints, hongers, fuel rod ossemblies, CROMs (and so forth) for mechanical items. The odditional requirements in the proposed Reg. Guide constitute mechonical stonderds writing without a consensus system such as f:M in ANSI /IEEE or ANSI /ASME. This proposed Reg. Guide is philosophicol'y incorrect and also unnecessory because ANSl/ASME is very close to issuing stonderds for the seismic qualificotton of mechonical equipment and these stondords will be saltoble for direct endorsement by o Reg. Guide, without the necessity for ony further mechonical stondords writing in the Reg. Guide by the tPC. Recommendotion 3 Proposed Revision 2 to Reg. Guide 1.100 should delete all references to mechonical equipment and just endorse IEEE 344-87 os o safety related/IE electrical standard, with mechonical equipment and nonsofety related equipment whose failure could prevent the sottsfoetory occomplishment of safety functions being covered by SRP 3.10 os of present. JRL6/017/3 - r L
, s Comment 4: & resolved Sofety issue (USI) A.46 A-46 requests o voluntary review by licensees of their nuclear plants to determine the seismic odevocy of a single path of mechonical and electricoj components '
l required to ochle<e and molntoln hot shutdown conditions, included in the review cre the components, their anchorages, and their possible physical Interactions with i other plant items. l The review is to be done to criterlo contoined in a "new model" (l) les by , comparison to rm.nvel eor plant selsmic experlences or other doto instead of the f basis used for the originol lleensing reviews. As o consequence, the NRC stof f hos determined that the review is o backfit os defined by 10CFR 50.109 and that any plant modificottons based on the "new model" ore also bockfits, t i The "new model" consists of reports and studies comprising verlovs s&ts of t guidelines prep:: ed by various private consultants for the Electric Power , Pescorch Institute (EPRI) and the Selsmic Ovalification Utility Group. (SOUG) l There werr' no mondated 10 CFR 50 Appendix 3 or 10 CFR 21 Quality Assuronce Progroms required of any of the private consultants during the development of the !
"new model" nor have any OA Progroms been required for the implementation l phase which involves plant wolkdowns and evoluotions against the criterlo in the "new model". f If the Individvol villities had contracted with the private consultants to create the !
"new model" one had intended it to contoln new safety related criterio for their l vse in thelt nuclear plants, their own OA Programs would hcrve required the t I
imposition of 10 CFR 50 Appendix B ond 10 CFR 21 in the ecstracts with the private consultc-ts. However, the IMividual villities financed the "new model" l through EPRI eM SOUG ond these groups contracted for the creotion of the "new ; model" without requiring any Q A P. ograms, i 1 The "bottom line" is that "deficiencies" to the "new model" con be identified but i unless they are also deficiencies to the criterio forming the presently licensed l basis for the plonts they do not necessarily have to be "fixed" becovse (o) the "new ! model" is obsent G A Progroms for its creation and implementation, oM/or (b) the "new model" bcs not been mode o part of the licensed basis for the plants, ond/or (c) the "fix" may fell the Valm/im>oct onolysis for "odditions to odequate safety { i levels" required by the Bockfit Rv'e. That is not to soy that tr4ividvol utilities
. may volunteer to wolve their rights in the oreos mentioned and do the reviews and make the "fines
- anyway.
f l Finolly, there is some question as to who is going to molntaln, correct and update the "new model' over time and whether it will be updated using nuclear plant experience or continue to use non. nuclear plant experience with simllority comporisons. Utilities which voluntarily use the "new model" will hove to oddress this issue for tM life of their plonts and may have to turn the "new model" over to o group having continuing existence for ongoing molntenance, corrections, and (I) NUREG 1211 P.16 Pero V. JRL6/017/4
. o e
- vpdating as new experience dato becomes ovollable. Ongoing contracts with the private consulfonts developing and maintolnin bases will also be regstred, and in one case,g the consultant the non. nuclear esperic'ce claims to own the de'r, datobose he developed with the EPRI and SOUG funds, in summary, it is diffievlt to see any opplicotton of proposed RevisJon 2 to Reg.
Guide 1.100 to the resolution of A46. First, per Recommwuletlon 3, oil references to mechanical eqvlpment should be deleted, which will prevent its opplicotton to mechanical equipment in A46. Secord, for the electrical equipment, it is inherent in the Reg. Guide that G A Progroms must opph to any onolysis, test, similarity or experience progrom octivities If the results are to be used in nuclear plants. Of porticular importonce is the bosts used to estobilsh simllority between the non-noclear datobose maintained by the privete consultants and nuclear opplicottons by licensees. The "new model" kes not meet the QA Progrom requirements of the proposed Reg. . Guide and consequently con not be odopted offer the fact by the Reg. Guide and thus become current licensing criterlo sultoble for voluntory commitment by licensees. Third, the proposed Reg. Guide Is of no help in resolving the onchorage end possible physical Interaction concerns in A46. These are the moln creos in which "deficiencies," If any se likely to be Identified, and this identificotton depends on on implementation progrom outside of the proposed Reg. Guide based on "holfboked wolkdowns" (2), in other words the potential "deficiencies" ore expected to be construction deficiencies, principolly onchorages, indeperdent of whether the present thensing criterlo or the criterio in the "new medel" were to be chosen, and oli that could be required would be to "fix" the "deficiencier," to present licensing criterio. To do more would constitute bockfits each of which would have to be justif:ed by o Volve/impoet onalysis and since the Volve in A46 is essentiolly a constow, the more egensive the "fixes," the less they could be
)vstified.
(2) ACRS Meeting September 30,1937 Statement by C. Seiss, Choirmon, Subcommitsee on Generic 11 ems JRL6/017/5
. o i
Enclosure 3 to the Minutes of CRGR Meeting No. 129 NRC Bulletin on inadequate Latch Engagement in HFA Relays February 23, 1988 TOPIC E. Rossi (NRR) and C. Gerlinger (NRR) presented for CRGR review a proposed NRC Bulletin, "Inadequate Latch Engagement in HFA Type Latching Relays Manufactured by General Electric (GE) Company " requesting licensees (1) to perform a one-shot inspection at their facilities to determine that all HFA-type relays used in Class IE service have an adequate latching function, and (2) to repair or r0 place those relays that fail to meet specified acceptance criteria provided by the relay vendor. Copies of the briefing slides used by the s" 'f to guide their presentation and discussions with the Committee at this meeting are enclosed - (see Attachment to this Enclosure). BACKGROUND The review package for CRGR review by NRR in this matter was transmitted by memors.ndum dated February 5,1988, T. E. Murley to E. L. Jordan; the review package incluued the following documents: l
- 1. Information Required for CRGR Review (in accordance with Section IV.B of the CRGR Charter) l 2. Proposed NRC Bulletin No. 88-XX (dated February 1988), "Inadequate Latch Engageeent in NFA Type Latching Relays Manufactured by 6eneral Electric (GE) Company"
- 3. Part 21 Notification Letter, dated Noveeber 12, 1987 J. E. Teague (GE) to J. Taylor (Nnt), and attachment:
- a. Osrvice Advice Letter (SAL) No.190.1, dated November 1,1987, subject: "HFA Relays with Latching Mechanisms" CONCLUSIONS /RFCC+NENDATIONS As a result of their review of this matter, including the discussions with the staff at this meeting, the Committee recoseended that the proposed bulletin be i issued, subject to the following recommendations (to be closely caordinated with the CRGR staff): '
- 1. The staff should attempt to obtain additional failure data (e.g., through contact with AE00, the NRC Regional Of fices and thPO) to evaluate the urgency of licensees completing the requested inspections within 90 days as specified in the preposed bulletin. Requiring completion of the bul-letin actions on this schedule could require some licensees to perform the relay measurements specified in the proposed bulletin while the af fected
. . .g.
reactors are operating at power; and the Committee questioned the prudence of such a requirement. If the survey for additional experience data on these relays does not indicate a high failure rate, the schedule for completion of such measurements / inspections should be changed to the next planned shutdown at the affected facilities. If the survey indicates a high failure rate that would justify an accelerated completion schedule for the proposed bulletin actions, the staff should meet again with the Committee to discuss in greater detail the risk associated with online relay measurement / inspection (discussion to include licensee input regarding practical difficulties and risk involved).
- 2. M:dify the wording of Action No. 3 (at the top of p. 3 of the proposed bulletin) to indicate that all spares now at the plant sites should bt.
tested against the vendor's criteria referenced in the bulletin before use as replaceeents. Require similar testing prior to installation for future spares if they were manufactured before Novenber 1, 1987.
- 3. Change the wording of the last line on p. 1 of the propored to read as follows:
"...into question and, tnerefore, the relays should be inspected."
- 4. Change the wording of the first paragraph under "Reporting Requitar,ents" (at p. 3 of the proposed bulletin) to read as follows:
"Addressees who do have HFA type latching relays subject to this
{ bulletin, including those who have previously responded to the GE J SAL, shall provide letters of confirmation of completion of the j requested inspections. These letters shall include..." 1 i ) J I { i j
, s .
1 ,' . l . l 9 l CRGR BRIEFING ON PROPOSED BULLETIN REGARDING INADEQUATE LATCH F,NGAGEMENT 1.N HFA TYPE LATCHING RELAYS MANUFACTURED BY GENERAL ELECTRIC 1 l l FEBRUARY 23, 1988 CARL H. BERLINGER 492-1168 Attachment to Eaclosure 3
EHOBLEM: . CERTAIN GE HFA LATCHING TYPE RELAYS IN CLASS 1E SYSTEMS MAY
- MALFUNCTION: UNAVAILABILITY OF SAFEGUARDS WHEN NEEDED .
4 i
)_C_TIQEi:
1 - INSPECT (90 DAYS) FOR INADEQUATE LATCH ENGAGEMENT (CLEARANCE AND ROTATION: AS PER GE) 2 - REPA!R/ REPLACE RELAYS THAT Fall INSPECTION (AS PER GE) 3 - PREPARE / MAINTAIN DOCUMENTATION 4 - SUBMIT LETTER OF EITHER INAPPLICABILITY (120 DAYS) OR ! CONF!RMATION OF COMPLETION OF INSPECTION (30 DAYS) i j COPPARISON WITH GE RECOMMENDATIONS: ! GE DID NOT APPLY REQUIREMENTS TO ALL HFA LATCHING TYPE RELAYS ! ONLY TO THOSE SOLD FOR APPLICATION IN lE SYSTEMS I I i i . e
e Enclosure 4 to the Minutes of CRGR Meeting No. 129 Proposed Generic Letter on tsoric Acid Corrosion in RRs February 23, 1998 TOPIC L. Shao (NRR) and C. McCracken (NRR) presenteu for CRGR review a proposed Generic Letter, ' Boric Acid Corrosion of Carbon Steel Reactor Pressure Boundary Coepenents in PWR Plants" that would (1) backfit a requirement for each PWR licenue te ieptement a program to detect, locate, evaluate, and repair borated water leakage tha*. could degrade the reactor coolant boundary, and (2) require all PWR licensees within 60 day to provide assurancer that such a program is in place at their facilities or provide a schedule for implementing such a program. Copies of the briefing used by the staff to guide their presentation and the discussions with the Corwittee at this meeting are enclosed - (see Attacheent to this Enclosure). BACKGROUND The review package submitted for CRGR review in this matter was transmitted by memorandum dated February 5,1988 T. E. Murley to E. L. Jordan; the review package included the following documents:
- 1. Proposed Generic Letter, undated, "Boric Acid Corrosion of Carbon Steel Reactor Pressure Boundary Coements in PWR Plants," and attachm2nt;
- a. "Buric Acid Corrosion of Carbon Steel Reactor Components in PWR Plants" '
- 2. "Infornation Required for CRGR Review (in accordance with Section IV.S. l of the CRGR Charter)" l CONCLUSIONS /RECO*ENDATIONS As a result of their review of this r.atter, including the discussions with the ;
staf f at this teeting, the Committee made the folicwing recommendations: l
- 1. On p. 3 of the proposed Generic Letter, delete the last sentence of the i middle paragraph that refers to 10CFR50.109(a)(4), i i
l 2. On p. 3 of the proposed Generic Letter, change the second sentence of the ! last full paragraph to read as follows:
"The staf f does not request submittal of your program."
- 3. The staff should notify INPO of the impending Generic Letter issuance consistent with the NRC/INP0 Memorandum of Understanding, and should urge INPO to hold workshops for licensee guidance to expedite and assist its implementation.
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1 As a final point, in the discussions that gave rise to Ret.ommendation No. 2 above, the Committee expressed some concern regarding the change in NRR approach and procedure indicated in the subject sentence, i.e. , NRR is not l requiring licensee submittals for staff review of the programs required by the Generic 1.etter and does not contemplate the "usual" NRC verification inspection to assure completion and adequacy of the required programs. NRR defended this i approach as a conscious decision driven by resource limitations, and noted that such an approach is consi 1 tent with the current direction of Agency policy in emphasizing the licensees' primary re:ponsibility for ef fective conduct of safe operations at their facilities without the need for pervasive NRC presence and oversight in matters that af fect safety at the facilities. It was also pointtd out that, in this particular case, NRR plans te send NRC contractors to ten t selected facilitleh in FY 1989 to review the licensees' programs in place by l l then, and to assess the industry practices at that tire. Significant deficien-i cies fnund then will invite very strict enforcement action. There was no
- definitive CRGR conclusion resulting f rom the discussion of this point at this j meeting; but it will te a matter of continuing interest to the Comittee in the '
a future. 1 1 l l l i l I 4 l s i l l i i
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CAGR PfESTATICri l FEENARY 23, IE' l l PRFSOSED GUERIC LETTER (50.5V) - EORlC AtlD COPJOS!CE CF CAREC6 STER PEACTOR CCCUM FFESSUE BOLICAFY EXTEffAL SURFATS l l AttachTent to Enclosure 4
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O-l i i 1 EXATLES CF BORIC ACID CORRDSION OF REACTOR O'OLM MESSUE 10UNDARY . OMON9(TS: (ABOUT 20 CASES WERE REPORTG S!KE 1980) l I
- 1. PLANT: TUPEY P"~ UNIT 4 0 ATE OF 0 3 r &j; WJi 1937 ;
I l MTURE CF D A!C ACID FRCid. A LEALY LOWER IETPJfBT TUBE 1 1 C0f$0D0 VARIOUS ONChSTS ON EACTOR WSSEL HEAD ! l ! i PAX. DEPTW & EETRATIOfh 0.25 !cEs t
! l l 2. PLAAT: SALDl, UNIT 2 )
i DATE OF 0:CURFSE: AUGUST 1987 l MTUE OF EWNT: BORIC ACID FKt4 A LEAY SEAL WEG CA TE INSTFUfhT l PDETPATICN CORJ000 TE REACTOR ESSEL EAD SUWACE l EsX. DEPTH & POETPATIC6: 0.36 IDES ( t l l ,
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PtAhT: SAN OKFE, UN!T 2 ; 3. DATE 7 OCClG D G AUGUST 1987 l 1 NATUE OF EWhT: BOR!C ACID CORROSION CAUSD FAILURE OF TE SRMON j i CCOLIN3 SYSTU'. ISOLATICE VALW AO RELEASE OF 18000 j i ! GALLONS OF EACTOR COOLE. J i 4 4 I t 2
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- 4. PLAhT: ARKANSAS NUCLEAR OF., UNIT 1 i QLTE& OCQARENCEt OCTWER 1988 MTURE OF EM: BORIC ACID O XRODED SEVEN STUDS IN THE REACTOR O'OLAYT PLW M. DEPm 0F PDETRATION: 0.5 INCHES
- 5. PJWT: FORTCADOLN DATE OF OCQRREME: PAY 1980 MTL'RE OF EM: 3MIC ACID Cr/EEI) SEVEN STUDS IN TE PEACTOR
- 3. 5~ ipen :rWZ PAX, DEPTH & PEMTEATICt_it?'1.25 INDES (2.5 INCES R DIATTER)
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f PASTREGL0TORYACTION: OtE BULLETIN #0 FlW IWOWAT!CH NOTICES: ! IC BLLLETIN NO 82-C2 J.tf 2, 1962
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IE IWC&ATION NOTICE PC. 80-27 J,ff 11, 1900 IE IV0WATICN !0TICE NO 82-C6 FARoi 12,1982 IE IWOWATION t!CE NO 86-106 CECOSER29,1986 SUPPLCS.1 april 20,1%7 SLfftBE 2 T.TTER 19,1967 [ [, l e 1 l
A % g-BASIS FOR EGULATORY ACTION: GDC-14 - EACTOR COOLANT PRESSURE BOLNDARY SHALL HAVE AN EXiPDELY LOW PROBABILITY OF ABNOWAL LEAXAGE, CF PAPIDLY PRCPAGATING FAILURE, AND CF GROSS RUPTUE. GDC-30 - QUALITY OF REACTOR COOLANT PRESSUE BOUNDARY; IDENTIFYING TE LOCATION OF TE SOURCE OF REACTOR COOLANTLEAVAGE. GDC-31 - FPACTURE PREVENT 10N OF EACTOR CCG.Atfi PRESSURE FCUBARY REACTOR C00LAfT PRESSUPE ECGCARY SFALL HAVE AN EXIFDELY LOW PROEABilliY CF ABtOWAL LEAKAGE, OF RAPIDLY PROPAGATING FAILUPE, AND OF GPOSS P1JPTbE.
ACTIONS REQUESTED BY LETTER: LICENSEES / APPLICANTS PEQUIRED 'JNDER 50.51F 4 TO PROVIDE ASSUPANCES THAT THEY HAVE INENTED A PROGRAM TO ADDRESS BORIC ACID CORf0S!0N AREAS CF VULNERABILIT/ PROCEUPES FOR LCCATING Sl9LL LEAVS
- EW,! NATIONS /EVALUATICt;S CORRECTIVE ACTIONS f
I MAINTAIN ffCORDS AVAILABLE l I f i i b
4 .O O 6, g STAFF EFFORTS: PM'S TPACK LETTER COh!TMNTS, TO VERIFY ItPLBOTATION STAFF TECHNICAL EVIEW WILL NOT BE CONDUCTED CONTRACTOR WILL BE BUDGETED Ifl FY 1989 TO VISIT 10 PLANTS, REVI&' TIEIR PROGF#3 At0 PREPAPE A NUREG CN "INDUSTRY PRACTICES" 3}}