ML20197B927

Final Status Rept on Environ Qualification 10CFR50.49 Task Action Plan

ML20197B927
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Issue date:	01/31/1998
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AlTACHMENT FINAL STATUS REPORT ON THE ENVIRONMENTAL QUALIFICATION 10 CFR 50.49 TASK ACTION PLAN January 1998 Office of Nuclear Reactor Regulation Division of Systems Safety and Analysis

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9803130252 980205 RES OND E PDR

FINAL. STATUS REPORT ENVIRONMENTAL QUAllFICATION 10 CFR 50.49 TASK ACTION PLAN Puroose The Environmental Qualification Task Action Plan (EQ TAP) was established to evaluate and resolve known environmental qualification (EO) concems and to identify and resolve any other EQ concems that may exist. The original plan was submitted to the Commission in July 1993.

Since that time, periodic status updates have been submitted to the Commission, most recently on November 15,1996. This report documents specific actions taken on each item of the EQ-TAP by the Offices of Nuclear Reactor Regulation (NRR) and Nuclear Regulatory Research (RES).

. Summam As described in the EQ TAP sut'mitted to the Commission in July 1993, the EQ-TAP was h established to focus on three issues: (1) evaluating the differences in EQ requirements between older and newer plants, (2) assessing the adequacy of accelerated aging practices that are currently used for demonstrating equipment qualification, and (3) performing a programmatic review of EQ requirements to identify and resolve any other EQ concems that may exist. In the November 15,1996, EQ-TAP status update to the Commission, the staff documented the closure of the first issue. The closure was based on the staff's conclusion that actions taken by the Nuclear Regulatory Commission (NRC) and licensees since the implementation of the EQ rule and the margins inherent in the qualification process itself ensured an acceptable level of safety independent of which qualification requircment was implemented.

The cecond issue regarding the adequacy of accelerated aging practices is being investigated by the cable research program that RES is conducting on low-voltage instrumentation and control (l&C) cables. This cable research program is scheduled to be completed by the end of 1999.

For the third issue, the staff completed a comprehensive review of NRC EQ requirements and their implementation and determinri that the most significant programmatic finding was the lack of a

• feedback mechanism" (i.e., progmmmatic requirements to determine the current condition of EQ equipment so that it can be evaluated against the assumptions and parameters used for qualification, requiring that licensees assure the continued qualification of EQ equipment as nuclear power plants continue operation. The concept of a feedback mechanism was discussed in the November 15,1996, EQ-TAP status update to the Commission. The cable research program is currently evaluating promising condition monitoring techniques for low voltage l&C cables (ree item 7.b. below).

While reviewing and evaluating the status of the EQ-TAP (Item 6), the staff determined that those action plan items associated with identifying EQ concerns and gathering and evaluating existing industry reporm and data to address those concerns were essentially complete. The remaining EQ-TAP activities involve evaluating the technical concems through research and performing the necessary regulatory actions to implement options to resolve EQ concerns. These are long-term actions.

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l Since the concems identified by the EQ-TAP have either been resolved by the review of existing EQ-related literature or are being addressed by the cable research program, and since it will take time to resolve the cable research program, the staff has decided to close the EQ-TAP and subsume the remaining activities associated with the EQ-TAP into Generic Safety Issue (GSI) 168, " Environmental Qualification of Electrical Equipment." The responsibility for resolving GSI-168 will be transferred to RES and the work scope for its resolution will be updated in NUREG-0933, *Prioritization of Generic Safety issues."

EO-TAP Accomolishments 1.

Inform the Commission, Senior Nuclear Regulatory Commission (NRC) Managers, and the NuclearIndustry of the Emerging EQ lssue.

Completed. NRR issued two information notices on EQ and issued a memorandum to the Commission conceming the emerging EQ issues. NRR presented a paper on EQ at the 1993 NRC Regulatory Information Conference and made a presentation on EQ to staff members of the House Subcommittee on Mining and Energy.

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Encourage Nuclear industry Participation in Identifying and Resolving Specific EQ Concerns.

Completed. Periodically throughout the performance of the action plan, the staff held meetings and workshops to keep the public informed of the progress of and the findings from various action items within the EQ-TAP and to solicit ideas and feedback regarding the action plan's scope and direction. Since the last action plan update, the staff has made presentations on the status of the EQ-TAP at two industry meetings and has held two RES-sponsored public meetings to discuss, and obtain comments on, the condition monitoring and the LOCA test programs, which are part of the cable research program.

Even though this item is considered completed, the staff will continue to provide open communication with me nuclear industry regarding the resolution GSI-168.

3. Programmatic Review

a. Review license renewal background information.

Completed. The staff collected and reviewed information that was developed for the NRR License Renewal Project Directorate. A summary report on EQ requirements and the bases for any differences was issued on March 22,1994. The staff found no issues that required immediate action, but noted potentialissues and concerns in the summary report issued under EQ-TAP Action item 3.g.

b. Review Fire Protection Reassessment Report for recommendations relevant to the NRC EQ program.

Completed. The staff reviewed the February 27,1993, reassessment of the fire protection program to determine whether issues from that report were applicable to EQ. The staff issued a report on its findings on May 10,1994. The staff found no issues requiring immediate action, but noted potential issues and concerns in the summary report issued under EQ-tai' Action item 3.g.

c. Elicit opinions from others (regions, EQ experts).

Completed. The staff surveyed industry EQ experts and regional and headquarters-based NRC employees familiar with EQ requirements to determine whether potential EQ problems existed that were not included in the staffs review. The staff issue:! a report on the results of the survey on June 12,1994. Technical concems identified by the survey participants were included in the review of technical issues (EQ-TAP ltem 7). Potential programmatic issues regarding the NRC EQ program were also identified. The staff found no issues requiring action, but noted potential issues identified by the survey in the final report under EQ-TAP Action item 3.g.

d. Review existing EQ program requirements.

Completed. The staff compared the existing EQ program requirements documented in 10 CFR 50.49, NUREG-0588, the Division of Operating Reactors Guidelines, Regulatory Guide 1.89, IEEE Standard 323-74, etc., and issued a report on potential programmatic problems. The staff found no it. sues requiring immediate action, but noted poten'.lal issues and concems in the final report under EQ-TAP Action item 3.g.

e. Review audit and inspection practices of the NRC.

Completed. The staff reviewed the EQ inspection guidance for both operating reactors and equipment vendors and issued a report on April 14,1995. The staff found no issues requiring immediate action, but noted potential issues and concems in the final report under EQ-TAP Action item 3.g.

f. Review EQ implementation practices of licensees.

Completed. The staff made four site visits to gather and evaluate information about the implementation of the EQ rule at individual sites. Information regarding a fifth plant's EQ program was also reviewed. The staff issued a report on its findings on October 7,1994. Plant equipment replacement data was also collected for input into EQ-TAP ltem 4.b. The staff found no issues requiring immediate action, but noted potentialissues in the final report L.nder EQ-TAP Action item 3.g.

g. Finalize review results.

Completed. The staff consolidated and documented the potentialissues identified while completing EQ-TAP ltems 3.a. through 3.f. and validated the potentialissues through a peer review, using individuals that are knowledgeable and experienced in EQ.

The most significant finding from the program review was the lack of a programmatic feedback mechanism (i.e., programmatic requirements to determine the current condition of EQ equipment so that it can be evaluated against the assumptions and parameters used for qualification) requiring that licensees assure the continued qualification of EQ equipment as nuclear power plants continue operation. This finding as well as the other findings and recommendations from the program review will be considered as the staff resolves GSI-168.

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4. Data Collection and Analysis

a. Review published documents and industry reports pertaining to EQ.

Completed. RES through Brookhaven National Laboratory (BNL) completed its review of foreign and domestic test reports on EQ and the Electric Power Research Institute \NUS Corporation EQ database, focusing on published qualification and research reports on low-voltage instrumentation and control cables. The initial report on the findings from the BNL literature survey was published as NUREG/CR-6384, Volumes 1 and 2, in April 1990. Of the 43 l EQ related issues considered for resolution under the EQ-TAP,18 issues were resolved using information in existing literature. The staff determined that research on six other issues should not be pursued because their resolution offered only minimal benefits. BNL recommenued that the remaining 19 issues be resolved by the cable condition monitoring research and test program (EQ TAP ltem 7).

RES held a public open meeting with the industry in August 1996 to discuss the findings from NUREG/CR-6384. During the meeting, industry representatives committed to provide additional data and industry reports that they believed addressed several of the ,9 outstanding technicalissues. Over the past year, the staffs contractor has received the reports and in a supplement to the initial report evaluated their contents. The supplemental report is currently under review by the staff. Preliminary indications are that 13 of the 19 outstanding issues could be resolved viithout further research. The staff expects to complete its review in January 1998.

While the staff is continuing their review of the supplemental report described above, and the results of that review may resolve soue of the EQ technical concems under evaluation in the cable research program, no further activities are planned for this action plan item.

b. Gather equipment replacement experience.

Completed. The staff issued a final report on September 15,1994, which included information from the site visits made under Task 3.f. Based on the findings from the site visits and the staffs review of existing industry replacement practices, it was recommended that cables, connedors, and penetrations be retained in the NRC's EQ aging reviews.

c. Revlow operating experience data.

Completed. The staff issued the final report on June 30,1994. The staff reviewed licensee event reports (LERs), Institute of Nuchar Power Operations (INPO) reports, and the Nuclear Plant Reliability Data System (NPRDS) data. The staff concluded that the number of EQ-related problems at operating plants has been small relative to the total number of problems reported by plants, and that the majority of the EQ problems are attributable to poor installation, poor maintenance practices, or the equipment's not being qualified for the actual in-plant service.

d. Review information on equipment failures at Three Mile Island (TMI) via the Department of Energy.

Completed. RES through BNL has completed its review of the relevant information regarding equipment failures at TMI. BNL has included the results of the review in the final report for Task 4.a (NUREG/CR-6384).

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e. Develop an EQ database.

Completed. The purpose of the EQ database was to develop a searchable source of EQ-related test reports, research documents, and other data that could be used to resolve existing EQ-related technical concems. The database was developed by RES in December 1995 and has been periodically updated as new reports and industry data became available.

The staff will continue to update the database and use it as a reference throughout the resolution of GSI-168.

5. Risk Assessment

a. Perform preliminary scoping study.

Completed. In a memorandum to T. Murley, A. Thadani detailed the results of the preliminary scoping study. The results indicated that EQ equipment failures in a harsh environment could significantly affect core damage frequency (CDF), though the magnitude of the CDF impact was plant specific. The study also concluded, however, that the lack of reliability data bases resulted in significant uncertainty in the results. The report recommended the staff perform a more detailed EQ risk assessment.

b. Perform final PRA.

Completed. The staff reviewed the findings from the initial scoping study (EQ-TAP ltem 5.a), a followup study by Argonne Naticnal Laboratory to search the existing literature for reliability data for electrical components in harsh environments, and BNL's literature review (EQ-TAP 4.a). Based on the results of the staff review, a draft report was issued in April 1996 on risk issues with regard to environmentally qualified equipment. This report summarized previous work performed in the area of probabilistic risk assessment (PRA) and EQ and concluded that available information and data are not adequate to support a more detailed PRA of EQ issues; therefore, further work on PRA should not be performed under the EQ TAP.

c. Incorporate probabilistic risk assessment insights.

Comp leted. This task wes estal>lished to ensure that risk insights from the EQ-TAP were incorporated in the other activities of the action p;an. Although the staff considered the results cf the preliminary scoping study while the preparing of the action plan, the other uses of risk were dependent on the results of the activities performed under EQ-TAP Item 5.b.

The staff concluded from the activities conducted under EQ-TAP 5.b. that further risk assessment activities were not warranted under the action plan. Notwithstanding this finding, a staff senior level advisor on probabilistic safety assessment reviewed the results of the earlier activities to assess the risk of EQ and identified potential uses for risk assessments that may be helpful as the staff resolves GSI-168.

6. Review and Evaluation of the Status of the EQ-TAP Completed. Because of the breadth of this action plan, the staf,' performed an additional review of the EQ technical concerns to ensure that they warranted further research. The staff reviewed the list of unrer ilved technical concerns currently being evaluated by the cable

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research program against the repo-ts issued for EQ-TAP ltems 1-5 and tne reports and data collected for the literature review. The staff determined that the list of technical concerns under evaluation by the cable research program for low-voltage l&C cables was appropriate.

RES is currently reviewing several technical reports which may reco!ve some of the remaining technical concems (see EQ-TAP ltem 4a.). RES expects to complete the review of these reports by the end of January 1998, t

7. Techniul issues

a. Evaluate uncer'ainties associated with accelerated aging methodology.

Ongoing. The purpose of this action plan item was to develop and implement a test program to evaluate the use of accelerated cging in the qua"fication of safety-related equipment within the scope of 10 CFR 50A9. Since the last EQ-TAP update on Noverrber 15,1996, progress toward resolution of this action item has been as follows.

Tests to evaluate EQ technical concems and condition monitoring techniques under the cable research program continue to make progress. The cable research program focuses on low-voltage electric cables used in instrumentation and control applications. Six loss-of-coolant-accident (LOCA) test runs are planned to study three types of cables. Each test run will feature one of the three cable types and will involve preaging to simulate 20,40 and 60 years of equivalent operation and LOCA testing. Unaged and naturally aged cables will also be included in the testing. The first LOCA test was completed in 1997 and the interim report describing the test results is being reviewed by the staff. Some anomalies were observed on the artificially preaged cables that were aged to simulate 20 years of service. The neoprene jackets degraded following thermal aging. A complete evaluation of the results from the first test will be completed by the end of February 1998.

Baseline testing for the second test run of cables is now underway. After baselining is complete, aging of thc test samples will begin, followed by LOCA testing, which is scheduled for the second quarter of 1998. The remaining test runs of low voltage cables (sets 3-6) will be tested over the next 18 months, with completion of all testing and evaluation scheduled for the end of 1999.

Although the EQ-TAP is being closed, ongoing research activities will continue through the resolution of GSI-168, as discussed above. RES will be responsible for the cable research program as it evaluates EQ technical concerns related to the qualification testing methodology under GSI-168. Recommendations for further action based on the results of the cable research program will be developed as part of the resolution of GSI-168.

b. Investigate Condition Monitoring (CM) methods.

Ongoing. The purpose of this action item was to develop and implement a test program to investigate methods of monitoring the condition, or performing ir. service inspection, of environmentally qualified cables to determine the degree of degradation over time. To accomplish this task, the staff developed the cable research pregram, which includes provisions for monitoring the condition of the cable test samples throughout the testing, using several CM methodologies.

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Since the last update, the first set of test cables has completed the aging and LOCA test sequence. CM data was taken throughout the cable baselining. aging, and testing programs to evaluate CM methodologies. The data collected for the first set of cables is currently under evaluation by the staffs contractor under the direction of RES.

Although the EQ-TAP is being closed, evaluation of condition monitoring methods will continue as the staff resolves GSI-168. Recommendations based on the results of this evaluation will be developed as part of the resolution of GSI-168.

c. Evaluate the impact of the new source term on EQ.

Completed. The purpose of this action item was to develop a staff position on the use of the new (reviscd) source term described in NUREG-1465, ' Accident Source Terms for Light Water Nuclear Power Plants," February 1995.

The staff performed an interim study of the effects of the revised source term on the qualification of plant equipment. The staff based its study on a draft of NUREG-1465 and issued a draft report on December 30,1994. The staff found that some benefits coald be gained from performing qualification calculations using the revised source term, but that the benefits were highly dependent on plant design.

Since EQ information has been developed that the staff can use in implementing the revised source at operating plants and since EQ is only one part of the staffs and industry's overall efforts to implement the revised source term at operating plants, further action under the EQ-TAP is not warranted. However, RES and NRR will follow the implementation of the revised source term at operation plants and will consider how the information gained about this effort can be used by the staff.

8. Options for Resolutior, Completed. Based on the reviews performed for the EQ-TAP, the staff has identified the

, following options to resolve the concems identified in this action plan. Should the cable research program identify limitations in the original qualification methodology. nractical approaches to condition monitoring currently being evaluated by the cable research pre, ..m can be used to supplement the original EQ requirements and guidance for low voltage I&C cables. Practical condition monitoring techniques for equipment other than low voltage l&C cables are not within the scope of this action plan and would be developed separately. Should the resu'ts of the cable research program indicate that the original qualification methodology was adequate to predict the qualified life of EQ equipment, no further action would be required, although the use of practical condition monitoring techniques could be evaluated on an enhancement basis to supplement EQ requirements or used in the implementation of the Maintenance Rule.

The staff has considered the possibility that the cable research program will identify limitations in the original qualification methodology, and that no practical condition monitoring technique will be identified. Through the extensive investigation of EQ requirements performed as part of this action plan, the staff has gained confidence that the original qualification methodology contains sufficient margin to ensure an acceptable level of safety even if some limitations are identified. The staff will reevaluate their options for resolution as part of the resolution of GSI-168 should this outcome occur.

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9. Implementation Transferred to GSI-168. The purpose of this action item is to decide on the appropriate regulatory option, plan and take the action, and document the basis for the action. With the closing of the EQ-TAP, activities associated implementing selected options for resolution will be subsumed into GSI-168.

Conclusions Through the EQ-TAP, the staff has gained extensive knowledge about the implementation of the EQ program by the NRC and licensees and about significant EQ-related concems. Although a some activities continue, the EQ-TAP has been instrumentalin resolving many concems and identifying the course of action needed to resolve the remaining concems.

In particular, the staff resolved the questions about the differences in EQ requirements between older and newer plants. The staff also completed a comprehensive programmatic review of the NRC EQ program and found that the significant progran.matic issue was the lack of a feedback mechanism requiring that licensees assure the continued qualification of EQ equipment as nuclear power plants continue operation.

Additionally, the staff determined which technical concems should be included in a cable research program to assess the adequacy of accelerated aging practices used for demonstrating qualification. Through this effort, RES has implemented a program to evaluate the original qualification methodology and promising condition monitoring methods. This program which uses low voltage I/C cables is scheduled for completion in late 1999 and will provide the technical basis 4

' for resolvin;; the remaining EQ technical concems, which will be included in the resolution of GSI-168.

In addition, the EQ-TAP gathered information that can be used in future activities regarding EQ.

This information includes a database of EQ-related reports and data, reports summarizing the results of cable research and qualification e6erts,information on equipment replacement and operating experience, approaches for using risk assessment in EQ, and insights into the use of the reviseJ source term on EQ at operating plants.

iJ The staff has determined that the EQ-TAP has accomplished its intended purpose, first through the identification of EQ concems, then, by resolving most of the EQ concems through a thorough review of existing EQ-related literature, and finally, by developing a cable research program to resolve the remaining technicalissues and evaluate promising condition monitoring techniques.

As discussed above, all concems have not been resolved; however, clear paths toward resolution of the concerns have been established Since the bulk of the work has been completed under the action plan, and since it will take time to resolve remaining technical concerns through the cable research program, the staff has determined that it is appropriate to close the EQ-TAP and the resolve the remaining concerns through GSI-168.

On the basis of staff reviews in accordance with the EQ-TAP, the staff has not identified any significant safety concern that requires immediate regulatory action.

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The Commissioners 4 On the basis of staff reviews in accordance with the EQ TAP, the staff has not identified any significant safety concern that requires immediate regulatory action.

Attachment:

Final Staus Report on the Environmental Qualification 10 CFR 50.49 Task Action Plan cc: SECY OGC OCA OPA CFO CIO DISTRIBUTIQR See next sheet DOCUMENTNAME: A:EQTAPCP.R15

• See Previous Concurrence SPLB' SPLB:BC* Tech Ed.' AD:DE D;DSSA* AADT:NRR*

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The Commissioners 4 On the basis of staff reviews in accordance with the EQ TAP, the staff has not identified any significant safety concern that requires immediate regula'ory action.

Attachment:

Final Status Report on the Environmental Qualification 10 CFR 50.49 Task Actic ' Plan cc: SECY OGC OCA OPA CFO ClO DISTRIBUTION: See next sheet DOCUMENT NAME: A:EQTAPCP.R15

• See Previous Concurrenc(

SPLB* SPLB:BC* Tech Ed.' AD:DE D:DSSA* AADT:NRR*

CGratton LBMarsh Kleene Glainas GHolahan DSheron 11/12/97 11/12/97 11/14/97 12/ /97 11/21/97 1/9/98 I I 19 i RE

• hD:NRR* R* O k (Miraglia lins JCa n, iP 11/26]97 ytf4'W 3/98 p 98 "1/12/97 t p,- , ) y\ ?,

DISTRIBUTION:

File Center EDO rf DEDRrf JCallan AThadani SCollins FMiraglia GHolahan SNewberry TMarsh GHubbard JTatum CGratton LOlshan LShao KBohrer (WITS 9300107) MMayfield JVora SAggarwal PShemanski 6PLB R/F AEl-Bassioni NS tos BSheron Glainas JCalvo EWeiss FBurrows JKnox JWermiel AMarinos HGarg PMagnanelli(WITS 9300107) MKnapp SPLB Correspondence File HThompson PDR OFFICIAL RECORD COPY l 1

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