ML20196D984

Forwards Three Issue Sheets for Listed Review Items for CRGR Meeting 129 on 880223,for Info & Use

ML20196D984
Person / Time
Issue date:	02/19/1988
From:	Conran J Committee To Review Generic Requirements
To:	Bernero R, Jordan E, Ross D Committee To Review Generic Requirements, NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS), NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
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ML20153G441	List: ML20153G436 ML20154D959 ML20154D964 ML20154D983 ML20195F771 ML20196D984 ML20196E024
References
NUDOCS 8802250113
Download: ML20196D984 (7)

Text

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February 19, 1988 l MEMORANDUM FOR: Edward L. Jordan, Chairman, CRGR '

Robert M. Bernero, NMSS i Denwood F. Ross, RES James H. Sniezek, NRR Joseph Scinto, OGC i Phillip Stohr, RII (NRR) )

THRU: C. J. Heltemes, Jr. [

Deputy Director, AEOD i

FROM: James H. Conran  !

Senior Program Manager, AEOD l 3

SUBJECT:

SULARY AND ISSUE IDENTIFICATION I 1 CRGR AG't.NDA 1TE11S, MEETING NO. 129 l 1 i

! i Enclosed for your information and use are three Issue Sheets prepared by l CRGR Staff for the following review items: l

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1. Proposed Final Rev. 2 to Reg. Guide 1.100, "Seismic Qualification of  !

Electric and Mechanical Equipment for Nuclear Power Plants."  !

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i 2. Proposed NRC Bulletin, "Inadequate Latch Engagement in GE HFA Type  !

Latching Relays."  ;

] 3. Proposed Generic letter, "Boric Acid Corrosion of Carbon Steel l i Components in PWR Plants." I l

] These matters are scheduled for CRGR review at Meeting No. 129 on Tuesday, j Feb rua ry 23, 1988 in Room MNBB 6507, 1-4 p.m. .

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i Original Signed 'e i i l 1 James H. Conran  :

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Enclosures:

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SUMMARY

AND ISSUE IDENTIFICATION for CRGR Agenda Item - Meeting No. 129 February 23, 1988 IDENTIFICATION Proposed Final Reg. Guide 1.100, Rev. 2, "Seismic Qualification of Electric and Mechanical Equipment for Nuclear Power Plants."

OBJECTIVE The staff has requested that CRGR re'.lew, and recommend in favor of issuing as an effective Reg. Guide for use by licensees / applicants, proposed Revision 2 to Reg. Guide 1.100. This Reg. Guide revision endorses (with two exceptions) the provisions of existing industry standard IEEE Std. 344-1987 as acceptable for satisfying NRC regulations pertaining to seismic qualification of electric and mechanical equipment.

BACKGROUND The documents submitted for CRGR review by the sponsoring office (RES) in this matter were transaltted 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 Coment" letters on Draf t Reg. Guide 1.100, Rev. 2 from:

a. ASME, Task Committee on Seismic Performance Qualification of Mechanical Equipment (J. D. Ste' son)

b. Duke Power Company (H. B. Tucker)

c. Tennessee Valley Authority (R. Gridley)

d. IEEE, Nuclear Power Engineering Committee, Subcomunittee 2, Working Group 2 (C. D. Shipway and K. M. Skreiner)

e. Wisconsin Electric Power Company (C. W. Fay)

f. Seisnie Qualification Utility Group (N. P. Smith)

g. ASME, Ceemittee on Qualification of Mechanical Equipment Used in Nuclear Power Plants (K. Ennis)

3. Resolution of Public Comments

4. Revision 2 ta Reg. Guide 1.100, dated December 1987

2-DISCUSSION / ISSUES i

CRGR reviewed Draft Rev. 2 to Reg. Guide 1.100 at Meetits No. 37 (see Minutes dated October 15, 1986); the Draft version endorsed by tse Committee was published for comment in August 1987. The staff proposes to impose Rev. 2 on a forward-fit basis only, but would allow licensees of operating reactors to subscribe to it on a voluntary basis (presumably for qualification of replace-ment equipment). Seven sets of public comments were received (see Background Items 2.a thru 2.g); those comments focused principally on (a) the acceptabil-ity of using an IEEE standard to provide guidance for qulification of mechan-ical equipment, and (b) the proper use of experience datz in establishing the 4 seismic qualification of equipment.

CRGR staff preliminary review of this matter identified the following issues /

questions:

1. The Committee may wish to discuse further with the staff the clairs in the comments submitted by a cognizant ASME Task Committee that extending the

applicability of the IEEE Std. 344-1987 to qualification of mechanical equipment would ". . . seriously undermine a major stasdard development effort...which, up to now, has had active NRC parti

ipation and support" (see Background Item 2.a). It is possible that the issue raised in that comment is related to the issue identified in paragraph 2 below.

2. Both IEEE Std. 344-1987 and proposed Rev. 2 to Reg. Guide 1.100 include '

pruvision for use of experience data in establishits the seismic qualiff-cation of equipment, consistent with the resolutiot of USI A-46. But the last sentence in Section 8.3 of the Standard appears to require testing and analysis in addition to comparison with experience data for qualifi-cation of equipment s acluding replacement equipmet:) in operating reactors

, included under the USI A-46 resolution. If this is what is intended by the staf f in endorsing the Standard, the staff should explain why; because it would appear to be inconsistent with the intent and rationale of the approved resolution for USI A-46. If allowed to stand uncorrected, this

could be seen as calling into question the adequacy of the approved resolu-tion for that USI (because there appears to be on record a Standard endorsed by the NRC staf f that says that comparisot with experience data 7 alone is not sufficient to establish the seismic qualification of equipment in operating plants).

The staf f should be asked to clarify the intended neaning of the sentence 1 in question (in Section 8.3) in a context where a licensee of an operat-ing reactor covered by the USI A-46 resolution subsequently wishes to  ;

replace a piece of equipment within the scope of tLat USI. The Committee '

may wish to consider recommending that this matter be clarified explicitly (

) in proposed Rev. 2 to Reg. Guide 1.100. l l .

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SUMMARY

AND ISSUE IDENTIFICATION for CRGR Agenda Item - Meeting No. 129 Februa ry 23, 1988 IDENTIFICATION Proposed I?RC Bulletin 88-XX, "Inadequate Latch Engagement in NFA Type Latching Relays Manufactured By General Electric (GE) Company" OBJECTIVE The staff has requested that CRGR review, and recommend in favor of issuing, a proposed "complisace" type bulletin requesting licensees (1) to perforn a one . hot inspection at their facilities to determine that all NFA-type relays used in Class 1E service have an adequate latching function, and (2) to repair or replace those relays that fail to meet specified acceptance criteria provided by the relay vendor.

I BACXGROUND i

The package for ChCR review by NRR in this matter was transmitted by memorandum l dated February 5,1988, T. E. Murley to E. L, Jordan; the review package included the following documents:

1 1. Information Required for CRCR Review (in accordance with Section IV.B of the ;RCR Charter)

2. Proposed NRC Bulletin No. 88-XX (dated February 1988), "Inadequate Latch Engagement in RFA Type Latching Relays Manufactured by General Electric (GE) Company"

3. Part 21 Notification Letter, dated November 12, 1987 J. E. Teague (GE) to ,

J. Taylor (NRC), and attachments

a. Service Advice Letter (SAL) No. 190.1, dated November 1, 1987, subject: "KTA Relays with Latching Mechanisms" DISCUSSION / ISSUES The proposed bulletin is being issued by the staff in response to a Part 21 notification letter received f.>om CE in November 1987, and as a necessary followup to an associated NRC Information Notice (87 66) issued in December 1987. It is intended to reinforce instructions on actions that the relay ven-dor (CE) believes its customers should undertake. The staff states that the actions requested by the bulletin are necessary to ensure continued compliance with CDC 1 and Appendia B requirements. The concern being addrcssed by the bulletin (i.e., potential common mode f ailure of Class 1E systems) is character-i tred as high priority in this case. Total estimated cost of impirmenting the proposed bulletin is $1.5 million.

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Preliminary CRGR staff review of the package submitted by NRR identified the l following potential issues and questions.

1. The need for the proposed bulletin is not unambiguously indicated from the k' j information presented in the package. Licensees have already been noti-1 fied of the potential problem by IN 87-66, and there is no indication .

provided by the staff that licensees have not taken appropriate action.  !

! No relay failures (single or commem-mode) are known to have occurred as a (

j result of the possibie or suspected deficiency. The Committee may wish  !

. to discuss with the staff whether a more appropriate first step might not  :

be a generic information request regarding actions taken by licensees in l j response to GE SAL 190.1, particularly in view of the question raised in ,

2 below, t

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2. The staff analysis does not appear to have taken into account any risk l i associated with the effects of inadvertent actuation of ESF functions I i that might occur if the specified measurements must be made while plants f are operating (ala our previous RTB testing experience). Has this  ;

, potential risk been estimated and balanced against the risk of deferring '

i the specified relay measurements to the next plant shutdown (rather than i 1 within 90 days, as now specified in the proposed bulletin)?  !

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SUMMARY

AND ISSUE IDENTIFICATION for CRGR Agenda Item - Meeting No. 129 Februa ry 23, 1988 IDENTIFICATION i Proposed Generic Letter, "Boric Acid Corrosion of Carbon Steel Reactor Pressure Boundary Components in PWR Plants (Generic Letter 88-XX)"

OBJECTIVE The staff has requested that CRGR review, and recommend in favor of issuing, l a proposed generic letter that (1) would backfit on PWR licensees a require- I ment to implement a program to detect, locate, evaluate, and repair borated l water leakage that could degrade the reactor coolant boundary, and (2) would '

require all PWR licensees within 60 days to provide assurances that such a program is in place at their facilities or provide a schedule for implementing such a program.

l BACKGROUND 1

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:

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1. Proposed Generic Letter, undated, "Boric Acid Corrosion of Carbon Steel Reactor Pressure Boundary Cooponents in PWR Plants," and attachment:

a. "Borie Acid Corrosion of Carbon Steel Reactor Components in PWR Plants"

2. "Information Required for CRGR Review (in accordance with Section IV.B.

I of the CRGR Charter)"

DISCUSSION / ISSUES The proposed action is taken by the staff in view of significant operating experience with boric acid corrosion at a number of plants, and the failure of licensees in such instances to properly evaluate the safety significance of such occurrences to their plants and to take prompt appropr..te corrective actica, even following the issuance cf Information Notice 82-02. The staff believes that boric acid leakage potentially af fecting the integrity of the reactor coolant pressure boundary must be better controlled procedurally to ensure continued coepliance with the existing licensing basis for the affected f acilities, specifically GDC 14, 30, and 31. To accomplish this, the staff is imposing a new requirement that PVR licensees implement a program that includes the following principal elements:

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1. Determination of the principal locations where boric acid leaks smaller than Tech Spec limite can occur and cause pressure boundary corrosion;

2. Procedures for locating boric acid leakage smaller than Tech Spec limits (when such leaks actually occur);

3. Methods for conducting examinations and evaluation of effects of boric acid leaks when they occur; and

4. Corrective actions to prevent recurrence of boric acid leaks that occur.

It should be noted that the staff intends to direct licensees who do not have such a program in place within 60 days (i.e., by the time that responses to this Generic Letter are due) will be directed to do so by confirmatory order.

(See Background Item 2, p. 2, Sec. IV.)

The staff's proposed action seems justified in view of the operating exper-tence cited, and it appears to be an appropriately measured regulatory response (e.g., effective procedural controls are specified for detection of istic acid leakage, rather than a requirement for installation of new, more sensitive leakage detection equipment). The Committee may, however, wish to pursue the following specifies of this proposed action with the staff:

1. Licensees should be informed in the GL that confirmatory orders will be l issued if the specified programs are not in place within 60 days. That statement of staff intent now only appears in Background Item 2.

2. The first sentence in the middle paragraph on page 3 of the Generic Letter should clarified to read as follows:

"The position that licensees should implement a program to address the corrosive effects of boric acid leakage as specified above is imposed in accordance with the provisions of 10CFR50.109 (a)(4)."

The last sentence of that paragraph should then be deleted.

3. In Background Item 2, the wording of the last sentence in Section ~ 'II.

A.2 should indicate that "...the Generic letter will result (or is expected to result) in a substantial increase in the overall protection of <

public health and safety. . . ." Also the wording of Section VIII.B should be revised to reflect that, in accordance with the provisions of 10CTR50.109 (a)(4), the staff is not required to estimate the costs associated with a measure considered necessary for adequate safety or compliance with the Commission's regulations; such estimates are pro-vided for information only. Alternatively, delete Section VIII.B altogether, or indicate "NA".

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% ,] , , , February 9, 1988 MEMORANDUM FOR: Robert M. Bernero, NMSS Thomas T. Martin, RI Denwood F. Ross, RES Joseph Scinto, OGC James H. Sniezek, riRR FROM: Edward L. Jordan, Chairman Committee to Review Genoric Requirements

SUBJECT:

CRGR MEETING NO. 129 The Committee to Review Generic Requirements (CRGR) will meet in the afternoon on Tuesday, Fabruary 23, 1988, in Room 6507 MNBB. The agenda is as follows:

1-2 p.m. G. Arlotto will present for CRGR review proposed final Regulatory Guide 1.100, Revision 2, "Seismic Qualification of Electric and Mechanical Equipment for Nuclear Power Plants." (Review package is enclosed.)

2-3 p.m. G. Arlotto will present for CRGR review the proposed resolution for USI A-40, "Seismic Design." (Review package is enclosed.)

If a CRGR member cannot attend the meeting, it is nis responsibility to assure that an alternate, who it approved by the CRGR Chairman, attends the meeting.

Persons making presentations to the CRGR are responsible for (1) assuring that the information required for CRGR review is provider 1 to the Committee (CRGR Charter - IV.B), (2) coordinating and presenting views of other offices, (3) as appropriate, assuring that other offices are represented during the presenta-tion, and (4) assuring that agenda modifications are coordinated with the CRGR contact (J. Conran X29855) and others involved with the presentation. Division Directors or higher management should attend meetings addressing agenda items under their purview.

In accordance with the E00's March 29, 1984 memorandum to the Commission con-cerning "Forwarding of CRGR Documents to the Public Document Room (POR)," the enclosure, which contains predecisional information, will not be released to the POR until the NRC has considered (in a public forum) or decided the matter addressed by the information.

/

War ( Jordan, p Chairman CocijtetoReviewGenericRequirements

Enclosure:

As stated cc: See next page CC _m a r Ae es

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SECY V. Stello, Jr.

cc w/o enclosure:

Commission (5)

J. Lieberman l S. Ebneter W. Mcdonald Regional Administrators i W. Parler  !

G. Arlotto Distribution:

E. Jordan .

J. Heltemes '

J. Conrao C;;$ akenes x  !

R. Fraley B. Doolittle (w/o enc.)

CRGR CF (w/o enc.)

CRGR SF S. Treby (w/o ene.)

T. Rehm (w/o enc.)

J. Johnson, OEDO

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