ML20154H681
| ML20154H681 | |
| Person / Time | |
|---|---|
| Issue date: | 02/24/1986 |
| From: | Eisenhut D Office of Nuclear Reactor Regulation |
| To: | Vollmer R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20154H686 | List: |
| References | |
| NUDOCS 8603100351 | |
| Download: ML20154H681 (6) | |
Text
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FEB 2 41986 MEMORANDUM FOR:
Richard H. Vollmer, Deputy Director Office of Inspection and Enforcement FROM:
Darrell G. Eisenhut, Deputy Director Office of Nuclear Reactor Regulation
SUBJECT:
EQUIPMENT QUALIFICATION ISSUES The purpose of this memo is to respond to your January 22, 1986 request for assistance regarding the questions raised by R. D. Martin on environmental qualification and Technical Specification operability. Our views follow.
We agree that the relationship between the environmental qualification status of equipment, the technical specification operability requirements, and the action period of the LCO, should be clearly presented. We believe that when equipment within the scope of 10 CFR 50.49 is identified in the technical specifications, environment qualification is one consideration in determining operability, i.e., whether the equipment can perform its function during the course of an accident. Surveillance required by technical specifications provides additional input in determining the equipment's ability to perform its intended function.
It is true that the increase in risk caused by unqualified equipment is related to the probability of a harsh environment and the probability that the equipment will be required to operate.
However, to preclude an endless debate about the degree of inoperability and when the inoperability commences, should a harsh environment occur, we have taken the position that systems and components are inoperable if they cannot perform their intended function, as defined by the licensing basis for the plant, because of the undesirable effects of a harsh environment. For inoperable equipment, licensees are required to follow the provisions of the technical specifications.
Equipment believed to be able to perform its intended function, but without being
" environmentally qualified" pursuant to 50.49 (e.g., equipment without adequate documentation) and other equipment whose capability to function in a harsh environment is questionable may be considered operable, under certain circum-stances. Unqualified equipment may be considered operable if in the licensee's best engineering judgment the equipment would actually function properly when needed. The judgment should consider the similarity of the equipment to other qualified equipment as well as any known properties of the materials involved.
In addition, the licensee's analysis should address the potential failure modes and effects; and where possible may include an analytical assessment of the local conditions (i.e., best estimates of the temperature, pressure, etc.).
fy,3g Where there are uncertainties about the equipment operability, licensees should immediately take steps to confirm operability and establish environmental p) r
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9603100351 % M PDn ORG pon
Richard H. Vollmer,
qualification. The promptness of the licensees identifying the suspect equipment and starting to resolve uncertainties as well as the diligence and completeness of the assessment are considerations that affect possible enforcement action or determination of the acceptability of continued operation. An acceptable time 1
to resolve the uncertainties depends upon safety significance and difficulty in completing the assessment. There is not likely to be a single acceptable and fixed grace period for all equipment. Therefore, we do not recomend that the NRC attempt to establish an acceptable time period.
From the previously stated philosophy, it is clear that we do not agree that it would be appropriate to permit a longer grace period (i.e., longer than specified in the Technical Specification Action Statements) under the LC0 if equipment were declared inoperable because of a lack of prior environmental qualification.
I hope the above discussion of our views on your comments is helpful. Should you desire any additional perspective, please contact Martin Virgilio of Operating Reactors Assessment Staff.
/
A Darrell G. Eisenhut, Dep ty Director Office of Nuclear Reactor Regulation
FEB 2 41986 Richard H. Vollmer
- qualification. The promptness of the licensees identifying the suspect equipment and starting to resolve uncertainties as well as the diligence and completeness of the assessment are considerations that affect possible enforcement action or determination of the acceptability of continued operation. An acceptable time.
to resolve the uncertainties depends upon safety significance and difficulty in completing the assessment. There is not likely to be a single acceptable and fixed grace period for all equipment. Therefore, we do not recomend that the NRC attempt to establish an acceptable time period.
From the previously stated philosophy, it is clear that we do not agree that it would be appropriate to permit a longer grace period (i.e., longer than specified in the Technical Specification Action Statements) under the LC0 if equipment were declared inoperable because of a lack of prior environmental qualification.
I hope the above discussion of our views on your comments is helpful.
Should you desire any additional perspective, please contact Martin Virgilio of Operating Reactors Assessment Staff.
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Darrell G. Eisenhut, Deputy Director Office of Nuclear Reactor Regulation DISTRIBUTION YELLOW TICKET 869031 Central File w/ incoming NSIC w/ incoming NRC PDR w/ incoming Denton/Eisenhut PPAS DMossburg w/ yellow folder JCarter MVirgilto GHolahan H wa.tc M
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- Previously concurred
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- ORAS:BC*
WAS:0 NRR:DD JCarter:mk MVirgilio GHolahan DEisenhut 2/06/86 2/18/86 2/gg/86 2/ /86
~ Richard H. Vollmer !
From the previously stated philosophy, it is clear that we do not agree that it would be appropriate to permit a longer grace period (action period) under the LCO if equipment were declared inoperable because of a lack of prior environmental qualification.
I hope the above discussion of our views on your comments is helpful. Should you desire any additional perspective, please contact Martin Virgilio of Operating Reacters Assessment Staff.
l Darrell G. Eisenhut, Deputy Director Office of Nuclear Reactor Regulation DISTRIBUTION YELLOW TICKET 869031 Central File w/ incoming NSIC w/ incoming NRC PDR w/ incoming Denton/Eisenhut PPAS DMossburg w/ yellow folder l
JCarter MVirgilio GHolahan l
- Previously concurred ORAS
- ORAS:BC /4ul ORAS:D NRR:DD JCarter:mk ilio GHolahan DEisenhut MVirp/86 2/06/86 2/ss 2/ /86 2/ /86 l
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Richard H. Vollmer '
From the previously stated philosophy, it is clear that we do not agree that it would be appropriate to permit a longer grace period (action period) under the LC0 if equipment were declared inoperable because of a lack of prior environmental qualification.
I hope the above discussion of our views on your comments is helpful.
Should you desire any additional perspective, please contact Martin Virgilio of Operating Reactors Assessment Staff.
Harold R. Denton, Director Office of Nuclear Reactor Regulation DISTRIBUTION YELLOW TICKET 869031 Central File w/ incoming NSIC w/ incoming NRC PDR w/ incoming Denton/Eisenhut PPAS DMossburg w/ yellow folder JCarter MVirgilio GHolahan
- Previously concurred ORAS
- ORAS:BC ORAS:D NRR:DD
- D JCarter:mk MVirgilio GHolahan DEisenhut H nton 2/06/86 2/ /86 2/ /86 2/ /86 2
86
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Richard H. Vollmer -
From the previously stated philosophy, it is clear that we do not agree that l
it would be appropriate to permit a longer grace period (action period) under the LCO if equipment were declared inoperable because of a lack of prior environmental qualification.
I hope.the above discussion of our views on your comments is helpful. Should L
you desire any additional perspective, please contact Martin Virgilio of l
Operating Reactors Assessment Staff.
I Harold R. Denton, Director Office of Nuclear Reactor Regulation
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DISTRIBUTION YELLOW TICKET 869031 l
Central File w/ incoming l
NSIC w/ incoming NRC POR w/ incoming Denton/Eisenhut PPAS DMossburg w/ yellow folder JCarter MVirgilio GHolahan i
i l
- Previously concurred ORAS
- ORAS:BC ORAS:D NRR:DD NRR:D JCarter:mk MVirgilio GHolahan DEisenhut HDenton 2/06/86 2/ /86 2/ /86 2/ /86 2/ /86
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