ML20206U680
| ML20206U680 | |
| Person / Time | |
|---|---|
| Issue date: | 11/04/1997 |
| From: | Holahan G NRC (Affiliation Not Assigned) |
| To: | Lainas G NRC (Affiliation Not Assigned) |
| Shared Package | |
| ML20206U672 | List: |
| References | |
| FOIA-99-82 NUDOCS 9902170262 | |
| Download: ML20206U680 (145) | |
Text
,.
[ h, UNITED STATGS
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) f; NUCLEAR REGULATORY COMMISSION tvAsH NotcN. O.C. 2004H204
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- November 4, 1997 l
{ MEMORANDUM FOR: Gus C. Lainas, Acting Director Olvision of Engineering Office of Nuclear Reactor Regulation FROM: Gary Holahan. Director MJM }f Division of Systems Safety and Anal # is l
Office of Nuclear Reactor Regulation !
SUBJECT:
ENVIRONMENTAL QUAllflCATION TASK ACTION PLAN ITEMS:
- 3. PROGRAMMATIC REVIEW AND 5. RISK ASSESSMENT l
Since you have the responsibility for environmental qualification (EQ)'
function in NRR for operating nuclear power plants and will have full responsibility for EQ with the closure of the Environmental Qualification Task Action Plan (EQ-TAP), this memorandum is to inform you of the results of my ,
review of two specific activities performed as part of the EQ-TAP. The first activity pertains to a programatic review of EQ (Item 3 of the EQ-TAP) and the other pertains to risk assessment activities (item 5). Discussions of these items are provided below with my recomendations for any further actions.
PROGRAMMATIC REVIEW 1he staff's assessment of the NRC fire protection program dated February 27, 1993, identified a number of weakness in the fire protection program and made specific recomendations for programatic improvements, in viaw of the weakness that were identified relative to the program, the staff determined that other programs such as EQ should also be reviewed to identify I any programatic weakness that may exist. Item 3, Programatic Review of the ,
EQ-TAP, was established to determine if there were similar programatic weakness in the EQ program, in order to perform the review, the following specific tasks were defined:
3.a Review License Renewal Background Information [,f Y .
3.b Review fire Protection Reassessment Report 3.c Elicit Opinions from Others (Regions, EQ Experts) 3.d Review Existing EQ Program Requirements j y ,f9;a ./7
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3 .'e Review NRC Audit / Inspection Practices fc .I,r..
. . .. m 3.f Review ticensee implementation Practices 3.g Finalize Review Results
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Gus C. Laina, 2 The objectives of 3 9 was to: (a) consolidate the potential issues that were 1 identified while completing items 3.a through 3.f; (b) validate the issues through a peer review process involving individuals who are experienced and knowledgeable in the area of EQ: and (c) make recomendations for further action. Attachment 1 is a draft of the report which documents the results of ;
3,9. efforts. The report was never formally issued. !
As part of my review of the results of 3.g, draft versions of the report were ,
provided to individuals in AE00, RES, and NRR. Based on coments received and ,
my own review of the report, I have determined that the most significant item identified under the programatic review was the lack of a feedback mechanism in the EQ program as it exists today. The concept of a feedback mechanism (i.e. a condition monitoring or inservice inspection program) was discussed in the November 15.1997 E0-TAP Status Update Report to the Comission. While the NRC and industry have gone to great lengths to establish and document the qual 1fication of electrical equipment over the past 25 or more years, there i has been no requirement within the EQ regulatory framework for licensees to verify that the assumptions and parameters used during the design, qualification. and installation of equipment within the scope of 10 CFR 50.49 continue to be valid as nuclear power plants continue operation. l Based on the above, I recomend that DE follow the RES EQ Program Plan being performed by RES relative to electrical cable testing and condition ;
monitoring. Once RE5 efforts have been completed and if they provide a i technical basis for a feedback system, DE should perform a regulatory analysis to determine if a feedback mechanism can be justified for qualified '
electrical equipment. In the performance of a regulatory analysis, the approach used in the amendment to 10 CFR 50.55a, " Codes and Standards for Nuclear Power Plants: Subsection IWE and Subsection IWL," published in .
August 8, 1996, (61 FR 41303) may be helpful. This amendment promulgated requirements for inservice inspection of containment structures.
With regard to the other recomendations made in the report, I do not feel i that any further action is warranted under item 3 of the EQ-TAP. However, you ;
may want to review the recomendations and consider them in any EQ activities !
l you undertake in the future.
! RISK ASSESSMENT t
f item 5. Risk Assessment, was included in the E0-TAP to ensure that risk l insights were considered in the review of E0 concerns and consisted of the following specific tasks:
l 5,a Perform Preliminary Risk Scoping Study f
l 5.b Perform Final PRA i 5.c incorporate Probabilistic Risk Assessment insights ,
l l
e i
Cun 0, intnas 3 Item f6,a was a preliminary troping Lludp to quantify the impaf' on cura damate f requency (01)f [ of environmentally qualified electrit al eruipment, lhts Ltury ,
was inmpleted in April 1901 anti det ails of the study are rnrumented in altnihmont 7 thn major conclusions of the tiudy woral (li f0 failures roulit i have ilunificant risk Impac t If elec tric component reliabli t t les are reduced
. in the pretenre of a harth environment: (!) Lhe magnllude of the impact on CDI 16 plant sportfloi and 9) lack of rel.Ahllity data hatet and limitations in s urrent probablittlic r lLk astettment models resulted in signl(icant unterlainly in the preliminary retults, llem h.h was establithed to determine whether data spitted that could he u6ed ,
to perform a more accurate PRA. This effort consinted of a staff review of thu findIn05 of the Inllial scoilng study, a follow up Lludy by Argonne Nat ional l aboratory to tearch ()e existin0 literature for reliability data for clertrical component 6, anti a prookhaven National Laboratory literature Havlew all) 1 Ap llem 4,4). llated on the resullt of the staff review, a final draft
! i rpoi i wan 16tue6 in April 1996 (see attachment 3) on liluel re0arding f()
vuuipmot, thi6 report nummarlied previout work performed in the area of pRA ,
and ,0 and concluded that availahis Information and data it not adequate to
- nupport a more det alled pAA of [0 lituell therefore further work on pRA thoulil j not be performed under the IO TAP, j ltem 6.c wan ottahlitherl to enture that risk in6lghtt from the IQ-1Ap were ina nrporat ed in the other activillet of the artlon plan, While the 6taff ionsidprod the resullt of the preliminary trollin0 6tudy durin0 the lirsparatton or thu sitinn plan, other uno6 of rltk IntighLL wat dependent upon the results
.,t liam t.h In innnsition with these risk .related activillet, I have discutted their result 6 with mv 6taff, including the division't tanlor level arivisor on ,
probahilittl< safety ashestment, flated on these dincuttinnt, the arivltor'6 4
review of available 10 and risk information, the f aCl that environm#ntal ,
a inialiti(atton tent 6 were not dettoned to provide reliability data, and that un reliability testin0 has been performed for eruipment in a harth environment,
- I have ton
- Inded that additional risk relater ef forts under the IQ tap are.nnt :
W a rl'a n t elli While I have contluded that no further risk efforts are warranted under the '
aiiton ilan, there are two potential utal of PRA that may be helpful in any future 0 art ivillet that may he performed by DI, lhete potential uses are discussed in altarhment 4 lhe method which ml0ht provirle the most use in-tha near term in the una of pAA to Inrus any feedback system on the equipment with t he mont rink n ion t f ir ance, ;
r November 4, 1997 ,
4 Gus C. Lainas ;
i CONCLUSIONS A
' Dased on my above review and conclusions associated with the Programmatic t I Reelew and Risk Assessment of the EQ-TAP, I have determined that the work performod specific tasks.
under items 3 and 5 of the action plan is adequate to close th
~
those two actions. ,
If you have any questions contact George Hubbard, extension 2870, of the Plant l
j Systems Branch.
I Attachments: As stated f DJSTRIBUTION:
SCollins j FMiragita ,
! IISheron ,
l JCalvo
- JCraig l 01 hatcher
.' CGratton ,
MKnapp l
4 iShan MMayfield ;
l j JVora j SPLD R/F j file Contor i
- DOCUMINT NAMC
G:\SECTIONA\HUBBARO\EQDEMEMO.WPD *See previous concurrence l i ewr. = . me copy l l
an ene bon c.c py w/o aineet nt/enet..wre I with stie hawn l.....,.copyetthisoocuwai, i ndi c .t .
Of f IC{ SPLD:DSSA BC:SPLB:DSSA MA DhY !
NAMI GTHubbard:rmc' LBMarsh* GPak , hlahan DAl[ 10/31/97 10/31/97 10/ /i7s {///97/
OfflCIAL RECORD COPY
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4 Gus C, Lainas ,
CDBCLilS10HS . ..' '
' s, N.Dased on my above review and conclusions associated with the Programmatic .
Revlow and Risk Assessment of the EQ-TAP -I have determined that the' wor !
perfohed s )eci fic%s,ks .
under items 3 and 5 of the action plan is adeq'uate to close t3asetwoactiop4 !
if you have any qu'e}Qons contact George llu)b[rd, extension 2870, of the Plant Systems Branch. , 7
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OlilRIDU110N:
$ Collins fHiraglia '
BSharon '
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CGrattan .
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f iltytenter
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' DOCUMENT NAME: G:\5ECT10NA\lIUBBARD\EQDEMEMO.WPD i no repy j f u < er e i ve a e mpy of t hi s docionant ,
Irwstsete la the ben C Copy w/o attachment /enalesure (*Cepy with attachaent/eestenure a a Off101 SPt0:DSSA (, BC:SPLB:DSSA r
DSSA 0:DSSA in e GParry Gilolahan [
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10/ /97 10/ /97 l DAlf 10/1 ) /97 10/$t/97 i
OfflCIAL RECORD COPY L
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November 4, 1997 if Gus C. Lainas CONC 1US1Qg Based on my above review and conclusions associated with the Programmatic Review and Risk Assessment of the EQ-TAP, I have determined that the work ;
performed under lloms 3 and 5 of the action plan is adequate to close the
- specific tasks. Therefore, the next EQ-TAP update will reflect the closure of these two actions. >
If you have any questions centact Georna Hubbard, extension 2870, of the Plant ;
Systems Granch. ;
Attachments: As stated i
FHiraglia DSharon JCa,vo JCraig ,
01 hatcher :
CGratton ;
MKnapp L5hao l
MHayfield '
JVora SPLD R/f file Cantor r DOCUM[N1 NAME: G \SECil0NA\HUBBARD\[QDEMEMO.WPD *See previous concurrence i...........
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OIrlC[ SPLD:DSSA BC:SPLD:DSSA MA Dhk i NAML Gillubbard: rmc
- LBMarsh* GPak , hlahan DAlf 10/31/97 10/31/97 10/ k {$///97
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Off!CIAL RECORD COPY ,
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JmTED ST ATch ATTACHMENT 1
- NUCLE AR REGUL.ATORY COMMISSION f l. w o n**,n * % o e .-+ w.
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i l H[MORANDUM 10: Ashok C. lhadant. Associate Otrector f for Technical Assessment !
j fROM:
Gary M. Holahan, Director Olvision of Systems Safety and Analysis I l
SUDJECI:
SUMMARY
REPORT ON THE [QUIPMEN !
t (C0- l As discussed in the staff's [nvironmental Qualification Task Ac 3
l J
IAP) of June 16, 1993, we are performing a programmatic review of [Q ;
electrical equipment. l ts: !
, under Action item 3 of the E0 TAP, which includes the following e emen 4
3.a Review License Renewal Background Information j
3.b Review fire Protection Reassessment Report 3.c flicit Opinions from Others (Regions, f0 Experts) 3.d Review [xisting [0 Program Requirements !
l 3.c Review NRC Audit / Inspection Practices l
3.f Review l.icensee implementation Practices l
39 finalize Review Results -
Durob.jectiveincompletingitems3.athrough3,f(above)wastoidentify f consideration.
l potential [0 issues and concerns that may deserve f urther staf l This preliminary part of our programatic review was not Afterintended to reso v 4
or to otherwise address any of the E0 issues that were identified. t j
completing items 3.a through 3.f the next step in the p k under EO-TAP Action item 3.g ' finalize Review Results." atic and to ma ewe recommendations as appropriate.
1 with item 3 9 of the E0-TAP, and our final report on the [0 programm l
review is included as an attachment to this memorandum.
the programatic review that was outlined in the E0 LAP was quite exte
' and consequently, many potential issues were identified for further However, I must emphasize that none of the issues are consideratton.
j considered to be an imediate safety problem and we did not identify any i CONTACT: J. Tatum ,,
415-2805 i l
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' Athok Thadant i
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i In general, the overall l specific equipment items that are not qualified. (a) some adjustments are i results of our [0 programmatic review indicate that:
needed to better assure continued qualification of electrical equipment over l the projected lifetimos of the equipment; (b) some of the past [Q concerns f
require further review to assure that resolution is co d j
ongoing NRC Involvement and oversight is needed.and recomma
- our conclusions are stated in Section 5.0. d We are now proceeding to updatei hour [0-TAP and th
.! industry l
l will place the IQ program review reports in the PDRI will andkeep moetyou wt l
representatives to discuss the staff's recommendatinns, Informed i
Summary Repnrt ({01 AP Action Item 3.9) l
Attachment:
f 0 Programmatic Rovtow I i i ;
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Jr. general, the overal) specific equti t.c' . sms that are not qualified. (a) some adjustments are rtsults of ou Ei 1" %rammatic review indicate that: i ent over needed to bet'er '.ssure contint.ed qualification' of electrical equ pm(b) som 1
I the projecte lif t . Inias of the equipment:further rm ivw to usure th r c Qu i e..
signli .>nt safel, problem does not nist, an Our [0 program assessment
.fght is needed. t and ongoing *lRC invals mont and oveand recommendat tries are discossed in Se .
our conclusion
- ar it st a' d in !vic t ior 5.0. d We are now proci,vding in .lat"<e,,or E0 IAP and the RES [Q program on the recommentiations that reports in the iDP and ment will place the E0 progr am roview I willwith keep Indu>te/
you representatives to discuss the st .f f's recommendations.p'ans as they deve informed of our progress and futurt .
Attachment:
EQ Programmatic Review - Summary Re ort ([Q IAP Actton item i O_l STR10yJJg: ,
Central file SPLB [Q file FHiraglia WRussell Gilolahan/MVirgillo TMarsh GHubbard Jlatum '
JWermlel (Gra11on -
EButcher JCalvo ;
PShemanski '
LOlshan SNowberry Libao SAggarwal AfI-hatston. JVora !
MMayfleld i
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r . c... 3 I DOCUMLNT NAME: G:\EQ\ . w.\ TAP. c3G\
COMPLETE .c MEMO
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[ 1 OfflCE SPLD:DSSA., # E DSSA:DD f MVirgilio GHolahan j NAMI JiaturV M / /96 j __ ^
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/ /96 DAI[ // f)3F' OFFICIAL RECORD COPY
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Summary Rnport
[Q Programmatat Review (TAC M85648) 1.0 INTR 000C110N l in response to issues that were the raised by the an staff completed Office of the assessmen t of.Inspector Gene
- 12. 1992, (OlG) in a report dated August As a result of this review, the staff the NRC fire protection program.
identified a number of weaknesses and made specific recommendations 1993. (or programmatic improvements in a report that vu issued on February 27.
In view of the weaknesses that thatwere identified i ilar protection program, the staff concluded other programsrelative that are sto m the also be reviewed to identify and correct any prog exist.
iils as an area thatAsrequired further review discussed in SEEY-9b049, a major concern as a result related to license renewal.related to [Q was whether the [Q requirement to support license renewal. Consequently, the staff concluded thatolder and ne d t of differences in [Q requirements betweet4 potential generic issue whic license renewal activities.
In support of the license renewal initiative, [Q testing t with the of electric Cable was performed by Sandia National Laboratories (SNL) under contrac NRC.
Some tests were performed to determine the effects of aging on typ electric cable products used in nuclear power plants and other tests f (unrelated to license renewal) were performed to assess the function damaged electric cables during loss-of-coolant accident (LOCA) conditi After accelerated aging, some of the environmenta C While some of the SNL tests may have been more h severe than require regulations, the test results raised questions with respect f certain to t e environmental qualification and accident performance capability o artifictallyagedelectriccables[1-5).
In order to assess the significance of EQ, the NRC staff performed a proltminary risk scoping analysis on the potential impact ith of inadequa equipment qualification on core damage fraquency. l s}was Ilmited to core damage prevention coresideri The major conclusions of the r a'iminary risk scoping risk impact if electric cafiles. (1) [Q f ailures could have sign!(It u ' presence analysis were: I,. et of a harsh einctr' cal component reliabilities are reduced environment; (2) Li,e magnitude of the impact on core damage frequency specific; and (3) the lack of reliability data and limitationsBased in current probabilistle risk assessment models result in significant l d d uncertainty.
that on the results of the preliminary risk sco)ing ao completed.study, the staff conc u e a more detailed [Q risk assessment should Ihus, the current [Q issue is one that pertains to operating reactors, but
Ibe to t % plant lif e outer.> tan init iat ive.
+ a olution is also important ' C.i id t t an T i on i( Q * .* * } on l
tsaff 11 sued an Environmental Qualifh a::o,In order to define and ccordinate the June 16, 1993.
Action item 3 of the E0 IAP lists those necessary to resolve this issue.acttons that pertain to the programmatic review o 3.a Review License Renewa? Background information 3.b Review Itre Protection K9 assessment Report 3.c Elicit Opinions from Others (Regions. [0 Experts) 3.d Review Existing E0 program Requirements 3.e Review NRC Audit / Inspection Practices 3.f Review Licensee implementation Practices 39 Iinalize Review Results j This report is intended to address E0-TAP Action item 3.g. "finaltic Review i Results." and represents the overall results of the Staf f's EQ program rev eW.
Section 2.0 of this report discusses the revtew methnrinlogy, E0- Section 3.0 is a summary of the potential issues that hsve been identi and recommendations, and the conclusions are contained in Secttan 5.0.
2.0 REVl[W HETH000 LOGY The goal of the E0 program revtew was to take a fresh ificant look at what has b done to address E0 issues and concerns and to The identify variouswhether any sign issues or concerns currently exist that need to be resolved. f the elements of the E0 program review are outlined under Action item 3 o E0-TAP (discussed above).
In completing E0-1AP Action items 3.a through 3.(, the they goal was simpl identify potential issues that may exist. i the potential issues that were identified are rather i speculative, d and no s nce were generated based on the specific information that was rev ewe f they attempt was made to pursue any of the postulated issues to determine had somehow been resolved by the staff.E0-TAP Action items 3.a th ith how provinusly associated with E0 and who were therefore not f amiliar w spectite E0 problems were dealt with in the past.
(a)
The objectives of this review (E0 TAP Action item 3.g) are to:
consol.idate the potential issues that were identified while completing Action items 3.a through 3.f; (b) validate the issues through a paar review k
process involving individuals who are experienced an recommendatinnt for further action.
2
- x. - ,-
- i0 '55l'I 5lM1ARY AND CON 50t IDAlloft the programatic review that was outlined in thefurther IQ 1 AP was aliitte astensh*
and consideration.
consequently, many potential issues were h gh identified forApp that have been identified while completing (01 AP Action items 3.4 t rou 3.f, eliminating duplicalton between the various f 01 AP reports that have be The ootential titues are organtled into one of the (nliowing issued l6 11).
seitions of the appendix, depending on the general naturn of the tsgue:
A. Scope /Appilcability (psge A 1)
B. (O Methodology (page A 16)
C.
Current Status and implementation (page A 11)
D.
Assurance of Continued Qualification (page A 01)
[.
[quipment-Reinted issues (page A 93)
I.
HRC Oversight (page A-101)
(page A ll5)
G. Miscellaneous Peer Review Coments lhe consolidated listing of potential IQ lssues was reviewed t by the NRC and others who are experienced and knowledgeable in the appendix in 10. and the comm were received during this peer review process are included ide a along with the listing of potential issues and problem statements to prov Appendix A also includes the staff's assessment of the balanced perspective. The following summary of the f the [0 potent tal (Q issues that have been identified.information contained programatic review:
A. ScoDe/ADDlicability lisues The (Q programmatic review found thatininconsistencies particular: exist relative to the scope and applicability of [Q requirements, a
single failure requirements have not been app
- of cold shutdown equilment, and the staff's resolution of TAP A-21 ,
regarding the " super seat" effects of a main steam line break did not include single failure considerations);
the need for single-failure protection is not clear if the purpose i of [0 15 to protect against the occurrence of " common cause" or
" common mode" (allures; being able to reach hot shutdJwn was a qualification factor for some plants while being able to reach cold shutdown was the <
consideration for other plants;
- Qualification of mechanical equipment has not been addressed in the same f ashion as qualification of electrical equipment; and
.3 u - - - _ - - - _ _ -_ - - - - _ _ _ _ - - _ _ _ - - _ - - _ _
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IOf al#6 out sloe (Dil. . .d '.Mf! '****
d I 8'l l f l( al PQy' pment ' ' '#P e l e s ! ! ' A '. f ou l pftee t iate l{} r(Qnf 4 ',
b- b O d d bESJ htuts; am Many of the poistl tal issues that were identifleul l t d to <1uring th review that has are beenrelatedimposed, to either: or (b) resolution of technical issues re a e With regard to (a). many facets of the l t ical qualification testing.
mothedology for establishing the inillal qualification of e ec r equipment for
- harsh environment" conditioni svidently were not In particular:
,lustified on a rigorous, technical level.
current requircments vs. what is reasonably possible within the state of-the art capabilities; imposition of different qualification standarrtt depending on pl vintage;
- age conditioning / preconditioning requirements.
- use of generic temperature profiles;
- Qualif ication based on bulk vs. Int al t emperat ures; and
- test margin requirements With regard to (b). resolution of me,y technical lisues relative te d follow-up qualification testing were identifisd for further review an action, including:
- certification of testing laborstories:
- definition of " worst cate" electrical condit tons;
- leakago current considerations;
- effects of long term exposure to moisture:
- combustible gas and chlorine formation effects:
- dust effects:
mechanical and flow induces! vibration effects;
- seismic and dynamic effects; and a fire scenario considerations, c ., forrent Status and 1molementation issues: f The staff's review under EQ 'LP Action item 3 e (10] generally found
. 4
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' hat the c urrent st alus aa6 Impleaient at ten '41 10 requirementi 'm 'O 11 ce* W 6f' many of t ee /.de mi<! at 'may not have ticen well uncerttowl While a ctolut h.
issues that were raised with todtvidual luentactf reCDgni?ed the%e at Valid dn(umented. It(ente 8s typicalI meetings nature.
with the NRC staff and agreed to corrett disc considered thli matter to be of minor importante.of the evolving entirely clear on what requirements were being tup confusion in the Industry on this point.
- generic qualtitcation' (as in qualification of a generic ty3e of insulation, f or examplel he case wasfcredited, orfurther which evidently reviewwas and t justificAl10n m some licenseet, thls approach wal Iater found to he unacceptable, d huut Attt_ Qi 10ntinutd. ha l i f IC A11DD :
qualif tcation practices lhe (l.e.,
[0 programmatic review found that currentinttial d equipment qual monitoring and atiessment) may not provide Atsurante oI Continue qualification of electrical equipment over time, recogniting that:
substantial uncertainty exttts in the quallflCatton proCett, especially in the ability to accurately project a " qualified lifet*
installation, maintenance, and surveillance practices can have a degrading ef f ect on equipment qualtitcat ion; and unanticipated conditions and occurrences that take place over the life of the plant can have a negative effect on equipment qualifIcatton.
Alto. " reasons to the contrary" for not upgrading replacement equipm to current requirements appear to be without merit sinceformore than enough time has passed to allow licensees to estabilsh programsIn particul j
)
qualifying equipment to current requirements.
to the contrary" that are suspect include:
an the item is part of a piece of equipment that was qualtitod at assembly; the item was on hand as part of the utility's stock prior to february 22. 1983;
- replacement equipment quallflod in accordance with the provitto of 10 CIR 50.49 does not existt and the use of replacement equipment qualifted in accordance with the provistent of 10 CFR 50.49 would have a %igniftrant probab creating human factors problems.
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1 - _. ' - ' " - - - _ _ , _ _ _ _ _ _ ------'----__m_ . . , _ _ _ _ _ _
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{ items werc I
During the (Q programmatit review, 4 aumber of equipwnt j identified that may deserve further r# view and constrieration by the ,
- staff to assure that the existing level of qualification is adequata, l In particular
l this some electrical components such as penetration
' =
f basis, more attention may be warranted for these componentt; l l
moisture transmission through cracks in cable insulation or into l l the cable core through diffusion may pose significant problems; l l
l solenoid valves, IO barrier elements, equipment seals and vapor l
- i l barriers (especially on plants that are subject to the 00R l Culdelines), and epoxy compound used for pntting electrical l
- penetrations may deserve further scrutiny; and f
\
- the use of polyimide insulation (Kapton), flutyl rubber insulation, l
! mineral wool 1nsulation (espec' ally in wet and humid 4 environments), bonded jackets, coaxial Cable, and terminal blocksl <
j may need to be better defined and/or justified. l l
r
- f. HM Perf ormance and Dversloht 113131 l
. Given the evolving nature of IQ and the uncertaintles that are involv l it appears that NRI efforts to address and resolve this issue have n been altogether sound, for example:
the ability to determine a "quallfled life
- by age conditioning techniques seems highly questionable; the imposition of different, more rigorous standards for the newer plants was not technically justified by the stafft J 1
the prescriptive regulatory posture that the sta innovative approaches for resolving this complex issue;
- the staff failed to include allowances in the f0 rule for t temporary removal of [Q barriers to facilitate maintenance, surveillance, and replacement activities; and no extension period beyond the and of qualtfled life (similar to the 25% extension that is typically allowed for c 1 for equipment replacement during the next scheduled outage, CO- f l
Additionally, based on the information for that was monitor and assure k+9e resolution have not been sufficion),
example-6-
u<, up sslui 8n l 7 *t th activitte* have not been ' M ' f "' t l
us, . . . . g t ra 'O m ues that we r e m 4 ' a ' ' ,
l l
NRL programs and intilatives have notd been establis 1 1
Improve [Q program requirements as apprnpriate-l NRC review and inspection programs have not been maintained in th area of [Q;
- reporting requirements have not been established to assure that l
' emerging [0 related problems are referred to the NRC staff for l consideration and appropriate resolution; and l
Generic letter 88 07 does not require that license ts. l which appears to be inconsistent with 10 CIR 50,12 requiremen innally, that hased on severe accident considerations and b j were identified which were not previously discussed in the [Q- A !
have been issued. specifically:
i g HUMf.Jntedut :
interf ace that exists with the Nuclear [nergy Institute 1he current (NII) often does not allow for theLicensee objectIvo and unbiased exchang representatives, information on a purely technical level.
N[l interface when trying to resolve technical issu manner.
It is important that this problem be resolved to allow for a cooperative effort in addrelling [0 issues and other issues that are important to the staff and the nuclear industry, h, 1, tad Review Resoonsibility:
l Although [0 deals primarily with electrical equipm discipline within the NRC is currently no'. nsigned the leadDesign con responsibility for this area of review.to electrical equipment that are more apt to be overlooked or misunderstood under the current arrangement, and the staf f 15 at a clearaffact disadvantage electrical when interf with Industry experts on important (Q issues thatThis assignmen equipment.
inefficient.
I LQujpmen1 A rvivability:
Iquipment performance requirements for the advanced reactor r0 designs include survivability criteria for severe However, accidents in addition to equipment l requirements for design basis accidents. survivability for sever i reactors.
. 7
1o f 0 PD% RAM AS$[$5M(N1 AND A[COMMf 80Afl0til duttig inr M to a large estent, the potential issues that were ident' f tet, h t erht in the programatic review deal with limitations and uncertainties i eaknesses t a further qualification process, and it appears that there are programmat c w and attention.
Itngering technical and equipment.related concerns tha understand (0, a clear strategy for the long term resolutton o the years not readily apparent and entsting requirements have not evolved the over to account for the uncertainties that are inherent in the [Q process. ihh discussion and specific recomenjations that followitsare intended to estab a strategy f or assuring qualification of electrical equipment are overan inte installed lifetime.
recomended This actions are if desiracle program enhancements while others considered qualification.
necessary in order to assure an adequate level o program enhancements are Itsted in brackets. 11 is presented by this report. ,
In addition to the regulatory perspective thatis important For d d QA to recogni j
possthle and of substantial benefit from an industry perspective. <
example, it may be possible to better focus (Q requirements t single by using gra e requirements and PRA techniques; better i to definition of t l requirements; and stress testing may prove to be a viable alternat ve preaging.
Therefore, in addition to the specific recomendations d t that are '
discussed below, the NRC staff should actively supp 4.1 General Considerations !
In pursuing [0 programatic improvements and addressing l d specific equ concerns, it is important to make use of informationdthat ice ofhas been deve op through research activities, operating plant experience, king full and the qualified experts. d d quality ta addressing current and future [0 issues and equipment concerns, advantage of other initiatives such as the maintenance rule and g assurance as appropriate.
licensees and any changes to entsting program requirements icated. or further expectations of licensees should be well justified and properly tal comun The following recomendations are directed toward satisfying these fundam concepts:
l RECOMMENDATION 1)
[11 may be possible to addrett many of the potential issues that have been identified by reviewing and better understanding past research efforts and (Q information that has been developed over the years, and this approach should be pursued before c other alternatives.
(b) there is a good likelihood that the desired in if:
6-
l l
, .. ,, , , sgr.; *' the **pefl*d l
.s obtaad: and 9 1 'h' I '" ' ',
!**' i I
, f. . f t , s t o putd I: n e a ' t '- e :
RCCOMMENDATION 2 and onceing [0 The NRC staf f should review the results of past research efforts, qualification test results and practices, and other [Q information, and maintain an up.lo.date date base (a) better manage.
containing this inforsation in order.tal catalogue, and share (Q information and advances le technology; (b) identify specific issues that may deserve additional re andresolution;(c)Cstaffandindustryresources.
(d) better focus NR
[RECOMMENOATION 3} .
should be lA functional interface between the NRC ;,nd Indust- t established for addressing (Q istues and cor.cerns in a cooperative and technically sound fashion, Since the eFist109 Interface with N[1 tends to inhibit the exchange of information and either should Ideas between Industry experts and the NRC staff, NRC managementIndustry resolve this problem or establish other participation.
avenues reports that forIn support on the [0 programmatic review, as well as the other have been completed under (0-tap Action item ) l611), should be made available to the general public.) l RECOMMENDATION 4 !
While it is important to alert the Industry of potential generic problems with equipment qualification, NRC exp l Bulletins or Generic Letters,used as a vehicle for implicitly suggesting th take some sort of action.
4.2 f,Lfhd1 The [Q rule (i.e.,10 CFR 50.49) was established for before much of the rel example, .
on C0 was completed and the rule is outdated in this respect, i ent l
the rule requires that a quallfled life be determined as partffects of the of equ pm '
Qualification process, but such a determination is theoretical, ha the e many degrading influences cannot be accelsrated, d d and the ac determinatton is unhnown, to the theoretical nature of [0 and the uncertainties that are involve , anto p would more readily allow the NRC staff and industry expertsAlso, while the [0 t
approaches and methodologies for addressing [0 concerns. r guidance has not been established in this area, (RECOMMENDATION 5) jihe NRC staff should make changes to 10 CfR 50.49 as appropriate
.g.
ielttaltves to improve the
*st6'11418 ed entrurage iriqu a t rj *hs' 4re Specifv men.osc'oa...
- r.hwum no to t a t '.
- in crder lo 10 proce,$.
be provided through Regulatory Guides, as more informationthe Standa and other documents where changes can easily be madestate of IQ technology.
on **si availat,is and advance, are .4e en th, Guidance should also be estaDilshed to address operatto barrier'.)
4.3 [0 Procrumhyuhu The potential issues that were identified during the to prnoranvnatic review indicate that E0 requirements are not commensurate with Itmitations andfor uncertainties that exist in the qualtftcation process, ffects of assignment or determination of a quallited life is theoretical, f such a the e many degrading influences therecannot is also be accelerated, uncertainty as to howandwell thetheinstallation, accuracy o determination is unknown, qualification normal wear and tear, requirements account for such thingsf as equip m tand Another uncertainty factor thatforbears electrical equipment example, on the long term quali imposed over ttme depending on plant vintage. in qualification were not required to prenge electrical equipment priorfor the various limitations and testing. Therefore, in order to account f (0 for uncertatntles that exist and to provide adequate assurante oe RECOMMENDATION 6 in order to compensate for the various limitations and uncertaintles that exist relative to sculpment qualification, to provide assurance of continued qualification over time, and to identify and correct any (0 deftetencies that may exist, addltlonal [0 programmattc requirements are necessary, including:
+ periodic condition and environmental monitoring of electrical equipment, and a
rigorous identification, assessment, resolution, trending and reporting of equipment qualification problems that occur.
With regard to condition monitoring, in concert over the next several years with industry the HRC staff shnuld develop, representatives, guidance for the application of condition monitoring techniques.
RECOMMENDATION 7 The NRL staff should establish a more focused program of [0 oversight by:
a establishing a NRC Headquarters focal point responsible for
- . - . ~ ,
- 1 a.nttiying. men u aring. trending. (atologuins. 46< '
- ont (quina w u .
i c .cl a ng ( 0 c . ns -i.s or. in anntnes.
consistency of regulatton from one licent** 1 maintaining (Q guidance documents (including the SRP) up to l date based on advances that are made through research and 3
industry InttiatIves; 4
- promulgating information and guidance to )trensees and the NRC staff as appropriate; l
establishing specifir reporting requirements for equipment l deficiencies that indicate Qualification expectations have J
not been satisfied for the given environment 50 that the 4
l staf f will be better informed of [Q problems that are b
[Q issues; and i
l better managing and directing [Q researth activities.
1 With regard to the NRC f ocal point, consideration should be given-to assigning the lead responsibility f or [Q of elect.icalAlso, in the area of '
i' equipment to an electrical discipline.research.theexistingNRCplanfo should be adjusted to incorporate the results of this review.
example, in addition to the need to establish condition monitoring methods and techniques (see Recommendation 6, above), further
. is needed for a number of specific technical and assessment l equipment-related [Q concerns (discussed in Section 4.4, below).
,' Also, recognizing that much more emphasis must be placed on l j
periodic condition monitoring to assure continued equipment cualification, extensive efforts and expenditure of resources to correlate artificial aging with natural aging may not be i
warranted.
l RECOMMENDATION 8 ,
Certtitcation of [0 testin9 laboratories in accordance with l generally accepted non-nuclear practices (e.g.. ASTM or ASM[
certification) along with nuclear QA standards is racommended to assure that [Q testing is properly and consistently performed throughout thi industry.
[ RECOMMENDATION 9) the extent that it is truly necessary for licensees to upgrade l10 to the more rigorous EQ requirements contained in the EQ Rule.
more appropriate
- reasons to the contrary' should be established l than those that are currently listed in Regulatory Guide 1.89.
However, resolution of this concern should be coordinated with
, industry initiatives to improve the (Q process.)
l r
i i
11 - l t
.Lt_tpus Schnic al ar.d_i_ qui.pr'; MLt.yL.gerns in addition to the programmatic weaknesses that were idente ified during the programmatic review, a number of technical and equipment related Concern Most of these are not issues in the identified sense forproblems that further consideration.
are known to exist but rather, they are speculative concerns that stem from the early evolution of CD requirements The and the vari uncerta tnties that are associated with the qualification process.
following recommendations are for concerns of this nature:
RECOMMENDATION 10 The NRC staf f should determine and document to what extent single failure considerations are applicable to E0 RECOMMENDATION 11 lhe staff should determins and document to what extent x qualification of equipment for achieving cold shutdown is truly necessary (irrespect sve of licensing bases) to assure that a safety concern does not exist for those plants that were condition.
RECOMMENDATION 12 The NRC staff should assure that identification and resolutinn significant E0 concerns have been addressed within the scope of the IP[ initiative.
RECOMMENDATION 13 The following concerns should be further assessed by qualified ht EQ expert s and the NRC staf f to determine whether or not and to w a extent additional resolution is warranted:
- a. Qualtfication of cold shutdown eculpment and resolution of TAP A 21 may not be suf ficient if single f ailure considerations apply (see Recommenerasinn 10),
b.
The use of " excess margin
- to justify the short-duration LOCA tests that were allowed for the DDR Guidelines plants may not be suf ficient to assure equipment qualification.
c.
Generic temperatura profiles that were allowed for some PWRs and BWRs were not fully justified and may not provide sufficient assurance of qualification.
- d. Resolution of TAP A-21 may not ha,e been entirely appropriate if resolution of the " velocity profile" ls dependent on the resolution of H5tS oualification
f
'. '! ac.cr... sed, and the 'velocitjl profi e represents a dynamh sj n;.s r, ave v udecised m 'cen of E0
..:ert tna: !
a may not provide '
e, lhe use of ' generic qualification sufficient assurance of equipment qualiftcation in those l instances where this approach was used.
- f. The resolution of other issues that were han l as the issues of mechanical and flow induced v f requirements to be compromised. l l
- g. Iquipment survivability for severe accidents (req reactors. !
h, Additional resolution of the following operaling and A
accident consideratl9ns may be needed to assure equipment qualification: f
- leakage currents and momentary elettrical effects; a
hydrogen burn scenarios;radtation and temperature stratifica
- long-term exposure to moisture;
- continuous submergence prior to the LOCA; l
- the effects of fire en EQ: .
j
- combustible gas and chlorine formation effects; l
- use of bulk vs. local temperatures; l
- adequacy of Mst.B qualification for 00R ;
Guidelines plants; and l
- equipment interface problems.
l 1.
Additional assurance of qualification may be needed for the following items: f
- clectrical penetrations and connector assemblics; solenoid valves;
- [0 barrier elements-
- seals and vapor barriers; l
~
- epoxy compounds;
- moisture intrusion through cracks;
- polylmide insulation (Kapton); ;
- Dutyl rubber insulation; l
- mineral wool insulation (especially in wet environments);
a bonded jackets; !
- coaxial cable; and l terminal blocks, l l
' i 4.5 Other Considerations !
A few questions were raised as a result of the IQ programmatic !r :
don't relate specifIcally to IQ, but may warrant clarification or further I 13 i
1 Tlie follocing recommendatinns are for concern 6 w *.c imt n ' ' !
. ao %.. c JRECOMMENDATION 14)
[TheprocessrequiredbyGL8807foraddressingsituationswhere equipment is determined to be unqualified does not require thatThe staff licensees seek an exemption from the [0 rule. j determine whether the GL 88-07 process is appropriate given the exemption requirements stated by 10 CfR 50.12, and provide guidanceasdeemednecessary.]
l RECOMMENDATION 15) f
[Thereisamarkeddifferenceinrequirementsthatwereim !
mechanical equipment, and technical justification should be l established for the different standards and the differentfor example, EQ of approaches that were allowed by the staff, mechanical equipment did not involve prescriptive regulation, a detailed program review, and confirmatory on stte inspection.]
[RECOMMENDAT10N 16) conducive to the cooperative exchange of informat that is needed for the resolution of complex technical issues.
This problem between the NRC and NE) should be c l tooperative efforts to be meaningful and productive.) l
5.0 CONCLUSION
S E The E0 programmatic review identified many potential issues, i nt ranging fl '
uncertainties vulperabilities.
assnciated with the qualificationt process to p of which may be readily dismissed based on more in-depth review or exper j
' judgement.
Also, while it is important to recognize and appreciate h EQ the various potential E0 issues that have been identified during t eis als programmatic review, i' exist in the state of technology and in the ability to address and resolve Consequently, resolution of EQ issues in general requires i a these issues.
good understanding of the overall strategy for addressing EQ on level, an understanding of what can reasonably be achieved, and th good judgement in deciding how to proceed on a given issue.
i from a program perspective, the results of this review indicate l that a strategy does not currently exist Given the for assuring uncertainties qualification that exist, the of electrica equipment on a long-term basis. i ht.
current requirement of inillal EQ certification (a) periodic mus ,
In particular, program enhancements are needed that l include:(b) that rigo condition monitoring of [0 equipment: resolution, trending, and repor and sc'; a structured program of NRC otterstght, by including 'tMv"these as ar. e a .: ic . a: -
t und4menta s elements of Eis program ree:.i9-c<. .the initial qualifica methodologies thr' were used become much less important.
Many of the specific concerns that have been identified d E0can most like addressed by reviewing and better understanding pa be pursued before considering other alternatives.
be performed only if: (a) there is a well defined need for additional be obtained, andAdditionally, (c) the cost is justified f in terms the existing NRC plan for to public health and safety. l performing EQ research L12) should be adjusted to incorporate the resu For example, in addition to the need to establish condition ber this review.
monitoring methods and techniques, further assessment is needed for a numA of specific technical and equipment-related E0 concerns.that m
] assure continued equipment qualification, extensive efforts warranted.
Aside from the recommendations contained in this report. additional l adjustments in existing E0 requirements may be possible i and and of benefit to the nuclear industry.
more emphasis is needed on maintaining equipment Qualiftcation h over some " trade-offs" may be appropriate.
better focus E0 requirements by using PRA techniquesdirected better definition role that single failure plays relative to E0 could result in better-qualification alternative to preaging.
requirements, and stress testing may prove to b industry initiatives to: (a) improve and streamline EQ requirements, last two methods, and practices based on the knowledge that has been developed over the decades; and (b) use PRA and other techniques to better focus E0 and to help place EQ issues in proper perspective.(10 CFR In pursuing the recommendations contained in this report and in a issues in general, the NRC staff should work closely with industry exp taking full advantage of other initiatives such as the maintenanc RC graded quality assurance as appropriate,NEl seemsestoforinhibit th management either resolve this problem with NEl or establish other avenu industry participation.
The programmatic weaknesses and equipment-related concerns that were identified as a result Rather,of the EQ program review do not mean that equip the results of this review indicate that:
currently not qualified. l the projected lifetime of the equipment that is qu lete; past EQ concerns require further review to assure that resolution is is com and (c) a structured program of on-going NRC involvement and oversig needed.
Until such time that specific equipment qualification deficiencies i are identified, existing qualification is assured by the initial qualificat on
- 'a Alov *.l.;t ma performed, twenty ibne ci Ofive years b
- wr
' h*'of$<,rnic "r Arch, and equipm performance ar.o operating exportance, identified during this review was c problem, Principal Contributor: J. Intum. NRR/SPLB
)
]
E 16 -
_ _ _ _ _ - _ - _ _ _ - _ _ - - _ _ _ _ ' - - - - - ~ - - - - , . _ . , _ _ _ _ _ _ _ _ , _ __
l 1
I REFERENCl5 l
i 1
NUREG/CR 5772, " Aging, Condition Monitoring, and to 1 Polyolefin Cables,* Volume 1. August 1992 2
HUREG/CR-5772,
- Aging. Condition Monitorir.g. and toss-of Coolant Accident (LOCA) Tests of Class lE Electrical Cables - Ethylene ,
Propylene Rubber Cables," Volume 2, November 1992 3
NUREG/CR-5772, " Aging, Condition Monitoring, and toss of-Coolant j Accident Miscellaneous Cable Types " Volume 3. November 1992 (LOCA) Tests of Class lE Electrical Cables --
i i
4 NRC Information Notice (!N) 92-81, " Potential' Deficiency of11, 1992 Electrical Cables with Bonded Hypalon Jackets " December 5
NRC Information Notice 93-33, " Potential Deficiency of Certain 28, 1993 Class lE Instrumentation and Control cables." April i f EQ j
6 tiemorandum from M. J. Virgilio to A. C. Thadant. "Rev ew oin (TAC M85648)," Harch 22, 1994 7
Memorandum from H. J. Virgilio to A. C. thadani "Rovie May 10, 1994 8
Memorandum from H. J. Virgilio to A. C. Thadant, "Results of the Survey of EQ Experts (EQ-TAP Action item 3.c) (TAC M85648)," June 12, 1994 9
Memorandum (-om G. M. Holahan to A. C. Thadant. " Review of Existing Environmental Qualification Progrsm Requirements (EQ-TAP Action item 3.d) (TAC M85648)," December 21, 1994 10 Memorandum from G. H. Holahan to A. C. Thadani "
April 14, 1995 11 Memorandum from G. M. Holahan to A. C. Thadant. " Licensee Implementa Practices Relative to EQ (EQ-TAP Action item 3.f) (TAC M85648),"
October 7, 1994 12 Homorandum from L. C. Shao to A. C. Thadani, "Research Program Plan Environmental Qualification of Electric Equipment," dated July 7.1994
APPENDIX A Potential EQ Issues '
(Consolidated tisting with Peer Review Comments and St.:ff Assessment)
A. Scoce/Aeolicability of E0
- 1. Qualtitcation of components other than cables has not been rigorously i addressed. For example, research is only just beginning to assess the !
adequacy of E0 for RG 1.97 functions and very little E0 research has i
L been performed on pressure switches, RTDs, pressure transmitters. and valve operators.
Peer Review Cements:
- a. Qualification oficom)onents other than cables have been vigorously addressed.i DuringLtie EQ inspections that were conducted in
' Region 3,- all components required to function in a harsh environment were required to be qualified. Qualification testing was noted for. valve: operators, transmitters,gpressure switches, etc. 'However,t wheniconsidering license renewal and the possibility of ixceeding the 40-year qualified'llfe, it does appear that cables have received more revinw/research than other n
U com)onents. As for.-RG 1.97, only certain components are required to >e EQ ' qualified so 'the basis for the concern is not clear, g
- b. i Why, do we#need5sejilichQunitsihave neenl iual.ified, .
- c. 'The",'fVf.fli$tIf)3 T'rously n
M ddressed. By the' late 1980sIsiffi int'erpretationlof go nandardshysf[$CspfyDittofdrfvendor'inipactions.:saw4 licensee?EQ inspec i ns. J If lot'.offiq standards are different' now, this document should clarify --
otherwise you'11'have readers saying that nothing is qualified.
- d. I disagree.DThiitis n6Fediidered an'open EQ issue.
First,'the industry.has,addr'essediqualification in accordance with
~
requirements of:the:!EEE standards and NRC documents, if they were acceptable asirigorous!'for cables, then the other items are in the
'ame : league,tand'.inW opinion,; even better in some cases (e.g.,
transmittersp9batteriesj some Yalves). Remember that the industry standards /on qualification for-various classes of equipment have
- had NRC:in ut,vand that NRC has not thus far (with a few P exceptiens nindicatedcany serious disagreements with these standards; ytissuing Regulatory Guides, as is the common NRC i practice.
Second, if the# con'cern rarate's to the extent' of ~NRC sponsored research on items'other than cables, then we must keep in mind that Sandia, Oakridge, FRC, and if 1 am correct, even Wyle has performed resecrch'en many items other than cables.
I I
- - - - - - . -- - ~ ~ _ _ _ _ , -. .- . _
l i Third and last, it is time to ask if we have not rea Ilme and again research conducted to date have d 1.0CA tests.
l pointed to the crying need for improveMIntechniques nts other in the methods use i for equipment surveillance and condition monitoring. i l words, predictive maintenance and condition monitor ng ;
I should be used to supplement EQ.
l 1 believe that Therefore,derstanding thewe mustoffocus results our already the work scarce tive resources performed towards un them beneficially to develop and implement effec and using l condition monitoring mathods.
- e. The concern ja valid.
What kind of [Q
- f. I am not clear how
- rigorously" is defined.
research needs to be performed?
l
- g. DuringtheNRC[Qresearchperformeda[Sandia,researchwasThis inc performed'en the EQ process. Several equipment types l radiation simulations and LOCA testing; WiftliittdInGlydingconnectors; penetrations,andsolenoid
/ valves, ~
l
- h. Industry responsibility. After"hbout two decades of research (in other countries'as we well as in,the are'still'far USA) and from answering all thethe expenditure of ma i
millions of dollars t i questions about cabie qualification. -It would be futile to
- undertake research on the components 11stedt in this paragraph a l way of learning how, to qualifysthem. . As . indicated in commen s
! that follow on' other issues,*ltols time'to'take ' stock of what we l have learned.andflook for ways to simpilfy qualification without i reducing the assurance of safety.
l 1.
The reqWrements for environmenfal.' qualification dified of electrical
- l I
equipment important to safety rule onforauclear. power 1
'theffinal21,?:1983. environmentalIn acc 10 CFR 50.49, and in qualification), and'is dated'Januarya referenced footnote in pa
- accordance'with:the NRC staff sel findings fled ;
provided by utilities, components 7provided in plants ara qu and. adequate toiprovide Regulatgry1 Guide (RG) 1.97 functions. Remember, j However, additional'research'lf.-thit' area'is welcome.
i licenseet'aretrospensible for qualifying all eq l should be directed to licensees.
Staff Assessmefti: be l
i Research accomplished.
is good to a point. but therei are t limitations to w
- research efforts are understood Any furtherandresearch relatedshould
to spetific equ pmena) be bas l applications, as aporopriate.
l i
l A-2 l
i J
l 1
on a well defined need for additional information, b) be pursued only if there is a good likelihood that the desired information will be obtained, and c) be pursued only if the cost of research is justified in terms of the expected benefit to public health and safety. The staff agrees with the view expressed by Comment 1.h that "...it is time to take stock of what we have learned and look for ways to simplify
' qualification without reducing the assurance of safety" and industry initiatives in this regard should be encouraged. The staff should l
, assure that full advantage is taken of operating plant experience and l PRA information, equipment performance, condition and environment j monitoring, root cause assessment, and trending of information in order to identify and correct EQ deficiencies on an ongoing basis. l
- 2. Even though the Standard Review Plan suggests that NUREG-0588. KG 1.89, and IEEE 323 may be appilcable for qualification of mechanical 4 equipment. specific guidance has not been provided in this regard.
Peer Review Coments:
- a. The need for additional guidance is not clear unless the issue deals with life extension.
- b. I disagree. How about the ASME QME Comittee documents (QR and QV series)? These have been under development over the past seven+
years and were finally issued in 1994. They were specifically written to address Mechanical Equipment Qualification (HEQ). It is my understanding that NRC has participated in their i development, j On a different note, let us recognize'that the industry effort in
~
- astablishing HEQ in' plants 1icensed to operate since 1980 have l conclusively established that'th'a effort boils down to identifying l l
and evaluating (mostly by analysis only)' nonmetallics. The i information from this analysis is used to establish replacement l intervals.for the soft parts. ,.Further, recently the Industry has l J
applied for exemptions from the requirement to treat MEQ as a separate program and integrating.them into the preventive maintenance programs,cApp~arently, the:HRC has acquiesced with i
these exemption requests. 1f so 11'am not sure what the basis is for this issue listing.
i c. This is a valid" issue.
- mechanical equipment.
- e. Several of the NT01. plants were required to have mechanical EQ programs during the.1980's. The basic findings were that the most sensitive aging components were seals (0-Rings, Gaskets, and diaphragms). Seal replacement programs were established.
Mechanical items such as snubbers are required to be periodically tested. Some nachanical actuators have been EQ qualif ted such as pneumatic and hydraulic actuators.- Motor operators, such as A3
= -. ..- . .
P*ays l
Generic tetter 85-03 Limitorque, Rotorque and ITT were quallfled. '
and 89-10 have required a version of quallfica flow, including blowdowr cotiditions.
f f.
Merits analytical resolution (i.e., analysis of existing information is warranted to reach resolution).
g.
As is indicated in your statement, 323-1974) the referenced documentsmay b (NUREG-0588, RG 1.89 and IEEE Nevertheless, the NRC for qualification of mechanical equipment. A copy staff of has provided environmental qualification of mechanical equipment.
that guidance follows:
l
. Although there are no detalled requirements for mschanica equipment, CDC 1, " Quality Standards and Records." and 4 Environmental and Missile Design Bases and Appendix 8 to 10 CFR 50, " Quality Assurance Criterla forl "Nuclear and Power Pla
- and fuel Reprocessing Plants' (Section !!!, " Design Contro .
XVII, " Quality Assurance F;acords"), contain the following requirements related to equipment qualification:
to be compatible with the a ' Com"n'ents[s, hall be designed.ditions, including those f
pos lated environmental con associated with LOCAs.
l i
- Heasures shall be estabitshe'd for the selection for suitability of application of materials, p Deiign' control measures sh'all be established for verifying ,
l the adequacy of design. l j l
- Eq0ip' men'tlualific'attori records shall be j l
For mechanica1' equipment, the staff reviewforwillt concentrate on; l materials which are sensitive to environmental effects, ms,
~
examole, seals, gaskets, lubricants, fluids for hydrauli disparagas, etc.
the applicant that includes the following:
i Identlfii:ation of safety-related mechanical equipment (1)- located .1n' harsh environment. areas,tincluding required operating time.
l Identificatidn of non-metallic subcomponents of this (2) equipment.
' (3) Identification of the environmental conditions this equi 3 ment must be qualified for.in tie electrical equ mechanical equipment.
l A4 1
- . ;4.y '
(4)
Identification of non-metallic material capabilities.
l (5) Evaluation of environmental effects.
Staff Atteitment:
There is a marked difference in the staff's handling of EQ fer electrical eQulpment as compared to mechanical equipment. While the peer review comments indicate thas specific guidance has been ;
established for EQ of mechanical equipment, it was not done in the same ;
prescriptive manner as was thought to be necessary for electrical equipment and it appears that the same level of effort has not been ,
placed on assuring that EQ of mechanical equipment is adequate for operating reactors. It appears that the NRC staff has established a >
less rigorous qualification standard for mechanical equipment and focused staff attention is necessary to assure that mechanical equipment is adequately quallfled. Specific. guidance in this regard should be. ;
established and promulgated to the industry. An approach different from what was required for EQ of electrical equipment (e.g. prescriptive regulation, detailed program review, and confirmatory on-lite l Inspection) should be fully justified. t
- 3. Under the current requirements, active and passive [0 equipment are
- lumped together in the development of performance requirements, design. ,
requirements, maintenalce programs, and safety priorities, which may not be entirely appropriate.
I Peer Review Cn nts:
l
- a. I am not sure of'the basis for'this issue.
l
- h. This was done for' conservatism.
- c. I agree. A few utilitle,s make the distinction. This is a good example of'where'the 'stility must' address required service-function not just point at the' vendor.
T wh safety
- d. No opinion (1 v. net.sure'3an'at?tht9:
~
sue is here),equ pment!1 functional? performance of account its Jnter' faces with' pass ve items such as cables, terminations"etc. 'During the qualification process, this functionalicipability is demonstrated either in a single test program or t'nrough multiple tests and anal sit programs. The concern regarding safety priorities and t e maintenance area needs to be better defined. The'safetypriorityofthe protective / safety function performed by an equ puent item governs the sa fety priorities for its interfaces, be t ey passive or i active, As for maintenance,'to the. extent there are paintenance attribuses for passive itemsi they should have been -(and I know ,
they geMrally are)' addressed in a utility's maintenance program, Active and passive equipment are important *1 umping' tssue is e.
not.
A5
I
- f. I am not clear how safety priorities art an issue. '
l terminal
- g. Successful o3eration ofis passive'equipmentTcables,ing often necessary, permitt the 1 blocks, breitersi etc.)ipment. Thus it seems appropriate for l i
l operation of active eququalification and documentation of 1[a perfo '
and safety priorities.
i Merits analytical resolution (i.e., analysis of existing h.
informationiswarrantedtoreachresolution).
- l. TheEQrequirementisthatcomponents-(l.a.componentswithinthe ,
scopeof10CFR50.49)mustbeabletoperformtheirrequired '
functions when called u)on for as long as required.. Ihts requirement applies s> soth active and passive components.
Licensees have founo ,md the NRC has accepted) various ways to demonstrate that equipment in their EQ programs meets this requirement. There is no spectfic requirement to lump or not lump together performance requirements, design requirements, maintenance program
- or safety priorities. If there are ina)propriate lumping of requirements,-specific identification and ela) oration on such requirements are welcome.
~
Staf f Auenment:
from a safety perspective full advantage should be taken of operating plant experience and PRA information, equipment performance, condition and environment monitoring, root cause assessment, and trending of information in order to identify and correct any [0 deficiencies that implementation of the maintenance rule may exist on an ongoing t,asts,will help to resolve (115 problem for a should initiate action to include electrical equipment within the Also, scope given the ;
of the maintenance rule to better address this concern. i advances that have been made in our understanding of E0 over the past 25 years, cost effective im>rovements may be possible in the application of
[0 requirements and the iRC staff should be (a) receptive to proposed developed as an industry changes in the (Q methodology that are:
initiative, and (b) demonstrated to be technically justified.
4 [0 requirements seem unreasonable for equipment located outside containeent and exposed to short term steam conditions and/or radiation-only harsh environments when considering the low core dama)
PRA implications /[0 screening criteria may located inside containment. ,
be helpful in establishing whether or not and to what extent [0 is truly necessary for a given component. :
I Peer' Review Cneman'til
- a. EQ recuirements for equipment located outside containment that is l rellec upon to function during and/or following a DDE are ;
reasonable since the qualification requirements for those components do not include harsher environments than they will see l A6 1
e --
o- - : _ _ ___ _ _ _
~ ,
l during the event.
if the equipment is not relied upon. then it .
should not be in th9 EQ program. PRA can be used to assess the level of reliance but this should be;done with caution and should :
include a review to ensure that.the plant's safety analysis ,
remains valid. . l In -
- b. Maybe the criteria for master-listing should be re !
Is onerous. -
ThisLis long overdue and a concerted effort has the
- c. I bgree. !
potential to narrow the scope.of equipment included in EQ '
proorams. This is true for both in containment and out-of-containment equipment populationsi Also, note that .just because ;
an equipment item is located in an area outside the containment. ;
and that it may only be exposed to short duration environmental '
extremes. It cannot be automatically concluded that it doesn't have to be qualified. Some equipment / components have the potential to experience common cause f ailures even under these conditions, l
further. I believe that we do now have sufficient real world experience data to permit a meaningful assessment of equipmenl f ailure rates in nucient plant environments.
when performing the PM.
- d. This le a valid issuel PM is ar good' screening tool.
j
- e. The philosophy utiliaed to date:has been'for equ
! to its harsh environment. The qualification almost l environment, even if this environment is relatively low steam
! conditions or radiation only.WHany r types of equipment do have i
l problems with these.less severe 0 bas. The For insta i' problems such as switchgear NMC5s, land hydro cause problems for integrated circuits (ICs).
CMOS RAD..
devices are susceptible to radiation levels
, chips)haveexperiencedfailuresinthe100'sto3000RADsrange.
l
- f. Merits analytical. resolution. 'It will be useful for the NRC to i
establish itsAlso position on the applicability of PRAs to equ qualification.
tojustifyshortLOCdtests. I^
a properly developed EQ program includes gah
- g. l.a. equipment within the scope of First of all,f those items o equipment that are ret (ted upon to remain functional du 10 andCfR 50.49) design basis events.Therefore, since the program following includes only those items that 3 M function. PRA does not seem to A7 4
e4 *-
4 The~[0 requirement for these items of have a rois at this point. be able to perform their required equipment is that they must,for as long as required, it is nt functions when called uponfor example, for appilcations where a c unreasonablebe required to qualified for service inside containment and a similar component.is required to be qualified for service -
conditions outside containment (where the potential if the licensee chooses harsh i environmentissignificantlylesssevere),dinsidecontainment.
to use the same component outside as is use Under these circumstances, licensees are not required to u i however, using the same component m samecomponentIlity.
oestred flexiblicensee's choice and it provides desired flexibility.
4 11.LfLA11111maat: [0 over Given the advances that have been made in iour hts, understanding and '
be 4
plant experience, some The improvements staff should be receptive (a) developed as an in the ( l
' possible and of benefit to the industry. ifled.
l to proposed changes in the (Q methodology d to that are: I i
5.
PAA studies indicate that (Q Haster Lists may need to be update include additional equipment.
Peer Review Commenti a.
If true, the EQ lists should be' Updated, b.
This is valid, but additional equipment to be added is pro non safety'related.
c.
Merits analytical resolution (i.e., analyze existing informa Also see coment 4.f (above). '
to reach resolution).
Please identifyethe indicated studies, and
- d. What PRA studies?
provide copies for NRC staffzinformation. -It la the Itc toupdateEQ%4sterillstsasnewinformation
] responsibility"ble.
- becomes availa ,
Staff Assessment: benefit ,
l Additions to the (Q Master List would only beinappropriate this if the to safety is tipnificant as defined bl/ the IPC initiative. he in fact regard, the sta'f should assure that iQ shortcomings better wouldB addressed under the IPC program.
applications may be of significant value to theThe staff industry in focusing (Q requirements and the expenditure of resources.
should be receptive to proposed uses of PRA licy with on the regard t '
(a) developed as an Industry initiative, and (b) demonstra technically justified and in keeping with the Commission's po uu of PRA. !
j A6
- 6. The single f ailure criteria has not been app) led consistently relative to CQ, for examples l
l Pase'Rav(aw connants l
I don't think that plant design bases are consistent. l
- a. l l
- b. May be true, but'so whatl Each issue should be evaluated l separately.
l
- The single f ailure criteria was not imposed for qualification of cold shutdown equipment (i.e., l[0 79 01, Supplem nt 3, only required one train of cold shutdown equipment to be quellfled). :
! Paar Review Chananti )
a.' The concern regarding LED 79 010 supplement 3 clarification is !
i perhaps a legitimate one in:that'there is no documented basis tha ;
l 1 am aware e' as to.why this exception la acceptable for older ,
)
plants. As one of.the parties to the many HRC and Industry 1
discussions on thisisubject during.the early 1960s, my l
recollectiensis-thats. l l J t
- For some 61deh lants F qualificationfo 'thodo ufrinftheenvironwntal equipmenttpodid' ave beent{popu ation of.th l aslicensed1yskomconfigurationspaad 4 ~ ' Theiint6n'tNasSI,6111milithele6vir'onmntal"q'unlification tthe requiremenis/tobequ:
(complete f. path iredito'ac system / equipment'complem condltionratherhhantapp. lying'hleve'scoldshutd t
for in'th " emergency: procedures:
Perhaps,Tabitt decumstat'linroflthe basis for this will help
! clarify wh !this s! considered,iconsistent appiteation of the single fat bre'd ign>criterit.
hutdown equi l
- b. Qualifyinfonejtrai6ofl single fa luraiwi1,1hotfoccur, cold:s%However,Ibuntwillinsure CFR 50.49 superseded i l
4 IEB7901sandlitsisupplementsH.itrequiresqualifyingapathto i
- safe shutdown;NP,leaseinote 'that' qualification in the context of i 10 CFR 50.49 assuresithat a single'fallure will'not occur, and by 1 doing so the single failure criteria is imposed.
f
- With regard to the "superheat effects" of a MSLB, the staff's resolutio of TAP A 21 failed to include single failure considerations.
Paar Review connents:
a.. Single failure was'conalderedt it was factored into the mass and energy releases from MSLD.oThere is no " additional" single failure considerations from 'superheat etlects."
A9
~~~~
_~
( - - -____ -
I b.
The issue regarding H51.0 superheat effects analysis not including single failure considerations, if true, is an accident analysis issue, NOT an (Q issue. l
- At stated in Regulatory Culde 1.89, the purpose of environmentalOlven this, l ti Qualification is to avoid " common cause" failures.not clear wh single failures.
Paar Review commenttt a.
I agree.. Ilowever, what's the difference in terms of type testing? l The tests'show that a component can perform. l b.
The abilityito' withstand a single f ailure is one ofThethe elements of defense-in depth applied in the design of safety systems.
purpose of CQ may be numed up as preserving the defense-in-d comon cause f ailuresThat that meansmay challenge (Q may not even the d specifically in accident environments.
focus on (i.e., we do not intentionally go looking for) the !
potential for comen cause failuresAsif such the singi equipment i is operated I
only under n^rmal Intoenvironments the category at al) oftimes.
random it failures. Yherefore,E0 f ailure f a111 is not clear why consistent application of single failure la an if ther('is a concern regarding single issue. In'my opinion failure appilcation, It should be treated as a design basis issue.
c.
The purposs'oflEQ is to demonstrate that the sa out. redundant' sets of the same equipment. A random failure, assure thatu's" however, random f atture'wouldinottoccur.
should.have very low p'robsbility of taking out redundant equipmentintf'thes probability kis'high 7then'it t d is es probably not a "comon cause,'a. In , order have a commonreJKthen"all:cause failu;to failures during demonstra e that equ qualification"and in service should be analyzed the cause being random orccomon mode can be made.
Any failure' th" qualification,' or in service, which is comon cause, would render the qualification suspect u not comon cause would seem to provide the best payback for safety, d.
Merits analytical resolution (i.e., analyze existing information Although single f ailures are assumed to to reachindependently occur resolution). of any other faulures, it is possible that the f ailureUnless is the same as a the I misunderstand f ailure statement, thatitscan result from a comon logical cause.
implication might be that qualification is not necessary at all.
A 10
%ed,. ,
a- ,
e.
Perhaps a better choice of words for RQ 1,89 would have been "to insure that common cause failures do not occur".
i Staff Assessment:
Thestaffshouldde}erminetowhatextentsinglefailureconsiderations are applicable to (Q. and assure that qualification of cold shutdown equipment and resolution of TAP A 21 is consistent with the position that is established.
1.
The adequacy of safe shutdown capability with regard to (Q has not been
- rigorously addressed (e.g., hot shutdown vs. cold shutdown capability
' single failure requirements, etc.),
Paar Raview commentit l
- a. I believe that this was addressed. ~
Li
- b. I disagree.. GiYen that the'EQ'masterlist calle accidents, the resulting envirpnments, for sac h of those accidents, I systems and equipment requiredfall to understand the basis f Safe shutdown is evaluated through many paths:
- c. Non issue.
Appendix R; PRA,iFSAR, etc. EQ, master lists take this into i considerationi d.' Herits ansiftEaTresolution'(1',e. analyze existing information toreachresolution).
- e. TheCQrule'(i.e.,10CFR50.49)tementissuggestingthatthisreql l shutdown equipment, if this sta j j .
requirement is not adequate, than this' issue should be discussl in more detail with the NRC staff and management. 1 l
Staff Assessment: f of E0 over !
Utven the advances that have been made in our understandinkA insights, the past 25 years, and based on the THI 2 experience and PThe stal '
some adjustments may be warranted.
extent qualification of equipment for achieving cold shutdown is truly necessary irrespective of Ilcansing basis, to assure that a safety concern does not exist (for those The phnts that are NRC staff document the basis for the position that is established. ;
should also be receptive to proposed changes in this regard that are:
1 (a) developed as an Industry initiative, and (b) demonstrated to be technically justified.
i l l
' This includes equipment required to remain functtonal and thoso l whose failure can affect the safety functional capability of Other ;
safety related equipment.
i A Il l
l 1
c l
fied is 8.
Detter definition of which Instruments are required to be quell ,
needed, with supporting basis.
Peer Ravi,w Connants:
f s.
I agree' to the extenf it'rel'ates;toithe:need for3a PRA bas i
redefinition.'
Intended in this' statement. If theI mustcurrentquestion deterministic Are we then why? evalua l saying If so, it is not an EQ issue, that RG 1.97 is inadequate?but may be an" accident analy f
procedures issue. i that the criteria enumerated ~ln.10 CFR 50.49 forif so, under what
. establishinganEQ11:tisincomplete,
- conditionoraccidentscenarin(s)?
Criticality of instruments is factored into selection
- h. Non-issue.
for HCL.
EQ list should be adequate to determine which equipme
~
- c.
4 quellffed.
f d. b' 'In' response .to 79-018, utt11tteCWereiro ,
i I
was'identifiediand'lt'was determined 5thatsit was lo harth'environmentynordend.altursritsfunction,thatequi wasrequiredtol'bi utlif,le T*ltriessedtthe NRCd$' audit teamfident review of these kn'i yses'durin 'imanfrauditi.WThus,h's i con i
Thedesignbasis>reconstitutionprocessithatm
, unde r took 'was ' partly t involved'4 upgr ading ? the se 'an al y s l
e.
Merits inalftfcil!'res'olutiotiNilUbnalyze existing information i toreachresolution);
- f. includin instrumen'ts,fb3rehutred to be qualified is
. This requirement i A11 squipmentl0 (b2)jan CFR 50.k9~(b!)i~ludes thel flex)ibility that is discussed in t i
is written in ato' necessary manner that'inc recognize the' differences between the many p an that is required to comply with?allithe Commission's regula t what equipment fits into each'of the three Staff Aiseitment:
1 Basedonthestaff'sreytowunderEQ1APActionitem3.e(10'.It l lfled was appears that the instrumentation that was THI-2required to be well defined. i ts may be 4
understanding of [0 over the past 25 years. an possible and beneficial to the industry.
A-12
a9 N (a) developed as an Industry intitative, and (b) comonstrate technically justified.
- 9. Safety-related equipment located in mild environmen
, sel( heating from being continually energized, may not be adequately qualifled.
Paar Review C m antu
- a. May be tr$ but' probably a" rare"occitrrence. Desit:n requirements or assessing .
related equipment include requirements for safetytal effects such as self heating.
environmen
- b. Such equipment should be covered under non-[Q design range
' testing.
- c. I disagree.- 10 CFR 50.49 does not require qualifical ton of nilld-environment equipment. At present, environmental qualification is focussed only on demonstrating .the inherent functional capability of harsh env.tronment aculpment, particularly in implementing accident environments , For milc-environuent equipment i
appropriate surveillance, maintenance, and fallure analysis to
[ address degradation due to normal operational and service :
1 environments is believed to,betadequate.. This position has been accepted by the Nfic in the past in several meetings with the industry.'~ What has changed now?
f ailure eWperience suggests that maintenance programs are issue inadequate h related to4,1then it should be pursued as an oversigh equi ment W Perhapsi a systematic a study of all equipment failures in any event, I in tie industrytcan shed light >on this subject, am not clear why:this is an EQ issue.
Ilowever,7ttb'should:be 'noted!thit'one can make a seismic qualification issue of thisp;iffindeed it can be show functional'cspability.
- d. This is a Valid issue. Focus has been on harsh environment because of 40.'4g.
- e. ' l'am not clear whether this is an E0 issue, I
- f. Safety.related equipment in mild but not benign environments, do not now have to be qualified. . Algorous qualification and maintenance programs to identify and document qualification are probably not cost effective because much time would be s)ent on reviewing paper work. A more cost effective approach, witch would incrasse safety assurances, would be to encourage the utilization of more modern, sophisticated non-intrusive test equipment to monitor the condition of equipment. All electrical l A 13 ,
.I equipment has heat as a by product. In the generation of HPAR Report HUR[G/CR 5762, it was noted that? infrared thermography was l
a new, modern tool for meaturing non intrutively, the temperature ,
i of equipment. Th tool and otters,1such at Vibration signatures,
' have been shown to be sensitivt to age related degradation, The sensitivity to age related degradation and thr. non-intrusive attribute provide a much more economical method of detecting degradation before equipment failure. It is condition mcnitoring, l
which focuses on looking at the hardware in its normal state. T1e proper focus should be at looking at hardware instead of paper.
i Thus, the encouragement of equipment' condition monitoring would seem to have significant cost and safety impact.
I l
More NRC oversight may be needed to assure compliance with EQ j
! g.
- requirements. l 1
l h. In accordance with the Statement of Consideration for the final CQ i
rule dated January 21. 1983: The final rule does not cover the I electric sculpment located in a slid environment. The commission i l
has concluced that the general quality and surveillance j requirements appitenble to electric equi ment as a result of other i
commission regulations including *10 ~CFR' Part 60p Appendix B (see l
for example Re 1
Requirements (gulatory Guidel.13MQJality,-Assurance ProgramO ;
adequate performance of electric equipment important to safety l located in alld environments. ,
Staff Attestment: f from a safety perspective full advantage should be taken of operating plantexpertenceandPRAInformation,equipmentperformance, condition and environment monitoring, root cause assessment, and trending of information in order to ideatify and correct any EQ deficiencies that may exist on an ongoing basis, implementation of the maintenance rule will help to resolve this problem for active components, and the staff should initiate action to includv electrical equipment within the scope of the maintenance rule to better address concerns such as this one, htInan Based on tne staff's review of scope /appitcablitty issues, the following, i recommendations were made.
l
- a. Although E0 research on some components may not have bnen as extensive i as cable ressaich, additional research should not be performed unless: :
(a) it is based on a well defined need for further research. (b) there is a good likelihood that the desired information will be obtained, and (c) the cost of the research is justified in terms of the expected oenefits to pubite health and safety,
- b. Full advantage should be taken of operating plant expertence and PRA Information, equipment performance, condition and environment A-14
l t
l' monitoring, root cause assessment, and trending of Information in order to identify and correct any (0 deficiencist that may exist on an ongoing basis. In order to facilitate this effort, the staff should initiate action to include electrical equipment within the scope of the maintenance rule, c.
There is a marked difference in requirements that were imposed for (Q of electricalequipmentversuswhatwasrequiredfor(Qofmechanical equipment, and technical justification is required for the di For example, C0 of mechanical equipment did not involve prescriptive regulation, a dotatied program review, and confirmatory on site inspection,
- d. The NRC staff should as:,ure that significant (Q shortcomings will be addressed under the IPC initiative, e, lhe NRC staff should determine to what extent single failure considerations are applicable to [Q, and assure that qualification of cold shutdown equipment and resolution of TAP A-21 is consistent with the position that is established. ,
I
- f. The staff should determine to what extent qualification of equipment for l achieving cold shutdown is truly necessary irrespective of licensing l basis to assure that a safety concern does not exist for those plants l that were not required to qualify equtpment necessary to achieve a cold !
shutdown condition, 4
- g. Given the advances that have been made in our understanding of E0 over the past 25 years, and cased on the THI 2 ex)ertence and PRA insights, adjustments in existing (Q requirementsse maypossible and offor example, it may be p substantial benefit to the industry, botter focus [0 requirements by using PRA techniques, and better l definition of the role that single failure plays relative to [Q could The NRC staff l re:, ult in better directed qualification requirements, (a) l should be receptive to proposed changes in this regard that are:
developed as an industry initiative, and (b) demonstrated to be !
technically acceptable, The NRC staff did not consider any of the scope / applicability issues to be an immediate safety problem, l
i A-15
- _ - - - - _ . _ _ . _ - - . - . . _ - . , . . _ . . . . . . . . . . ~ . . . -
~ __ _. - - .- . _ _ _ - _ -
1 l
.l 0, to Methodology f 1.
Many facets of the methodology for establishing initial qualifica I equipment have not been adequately addressed and justified on a rigorous, technical level, including (for example):
i Paar Review Connantat I thought !
- a. The bullets that follow are too general for comment I qualified equipment, l b.
The main consideration is that the methodology selected will l Increase plant safety.
f oxygen diffusion considerations, l
- c. Issues such as! dose rnte sffects,tc., e are EQ issues that are now. !
mandrel bend test requirements andhavebeenforsometime,tbesubjectofmany NRC.
To date; these issues have not prevented We EQshould programs from being developed by industry and approved by the all involved.
use of test data versussoother methods such as well suited for fQ experience, if adequately justified, may applications);
paar Review connantst
- a. I disagree. 1(hp is this an issue since the NRC has already outruled-(defac30panythingbuttestasanacceptablemethodfor demonstratinfoqualification of harsh-environment equipment?
Delete this " rom further conalderation because:
For all practical purposes, establishing qualification is complete for plants that are operit!r,g.
We have very limited expsrience on the performance of equipment under accident conditions to draw from.
It4s'leippacticali if' notLimpos:lble, to analyze equipment perfoNannte capability under accident conditions.
Thus, preference'for test over other methods for environmental qualification is ' justifiable.
For seismic qualification, it is prudent to exami by IEEE.
A number of Ilconsees
- b. The key words are " adequately justified." unsuccessfu A-16
-- . _ _ ~ " -- -- - _ _ _ . _ .
i I
l i qualification where the data presented did not repr J
' data did not identify that it was obtained in a manner that 4
dupitcated the ex ected DBE environe nt." for exam butyl)canusedifferentformulationsofthe i materials material and Sa (s.o.kaformaterialsusedintapedsplicescanlook acce
> table unless.you recognize that the adhesive can if f ail in a har:1 environment that includes submergence in water, adequately justified, the use of such data is acceptable.
- c. This is a valid issue.
I
- d. The 00R Quldelines had some good words How dorequiring tests for harsh you extrapolate a
pressure-temperature steam environments. normal operation (e.g., you can test water forever at 211*f and be ignorant about what happens at 213'f)7 l
- e. Some physical data will always be required. Operating expertence and analysis would, by themselves, not be acceptable.
^
1 4
f.
. IEEE 323-74;a119ws qualification by' type testing. .op 4
1950'ap audite land'correspondenteithattthtl preferred a th was type testi g?&To'qualifyion swing that it has experienced would have to have documenut THI has e merienced a and operated properly in a OM.c3tnce only'lif ted for 1ersh DBA very few equipment <ltens have been qua environment ' based on operating experience. Analyais only is also very difficult to have demonstrated, since there ar d on addressing i environent.
techniquenNhi:Thus, .little effort.should:be placecharen statementithanithe'onetin RQW.8g'may be considered to discourage the other less utilized uthods of qualification, All
- g. Merits analytic'al'resolut'lont'iiidustry reiponsibt)(ty.
three methods and combinations of them are acceptable with IEEE has initiated an effort to consider
- Justification. preparation of a standard that will address the use of ope f experience in qualification.
Other
- h. I think type tests should be the basis for quaiification.
methods of.' qualification such as analysis and. operating experience are' extremely' limited'in application and have little practical value.
- ~
Under what circu'estancesfis/tsst data not, appropriate?
If the 1.
l' intent of this question is'to suggest that test data need not always be required, than I refer you to 10 CFR 50.49 (f)(3) where experience with identical or similar equipment under similar conditlens with a supporting analysis fa show that the equipment A-17 8
- epe _
l to ba qualified la acceptable. In addition. NRC staff experience -
over the years indicates that there is no basis to support analysis only or extrapolation of data, and what can operating ex]erience tell you about the ability of a component to survive a LO;A7 Finally, what is adequate justification?
Staf f Attesment:
Given the advances that have been made in our understanding of [0 over j the past 25 years. and based on the THl-2 experience, PRA insights, and ;
operating plant experience some adjustments in the requirements may be possible and beneficial to the industry. The staff should be receptive to proposed changes in this regard that are: (a)developedasan industry initiative, and (b) demonstrated to be technically justified.
. the environmental conditions (e.g. temperature, pressure, radiation.
l etc.) that are postulated for both inside and outside containment; !
Peer Review Commtn11:
- n. I disagree. I am not clear what the issue is here. Haven't we already established the framework for a consistent set of methods for deriving the environments in both 00R and NUREG documenta? i' What is the laconsistency that still needs better technical justification? If the concern relates to minimtzing the level of conservatism, then it should be a Regulatory Requirements Reduction issue rather than an EQ !ssue.
- b. This is a valid issue. l 1
- c. This is' rio~t 'a miithodology, issue.
- d. The environmental conditions postulated for inside and outside containment during a DBA probably'are conservative. Plants have used computerlied modeling techniques to. predict the heat and mass transfer.1 Thors'have been a:few1 tests'to aid in developing thess such as the FTIR tests'and QE's full scale' torus testing.
models, Some uti lities have done some special: tests to aid in predicting
! l l the environment.~ In many cases,"the postulated DBA is in confilet :
with natural steam phenomenon,oFor instance, most DBA curves show '
l superheated' steam 1.e.t340.'F'and to.psig (at naturated i
conditions'the~ pressure wouldibecover'100 psfg). <Then the curves show chemical spray coming on and the temperature and pressure l would be the same as before,the spray.
l '
16 actual'tetting,'the spray'causes" tho' steam conditions to gu l into' saturation, which immediately drops the temperature. Typical j
postulated curves don't show this phenomenon.
i Additionally, most postulated DBA's outside of containment show '
instantaneous temperatures above 212 *f being distFibuted to m m
' areas in the reactor building which are not pressurized. Natur .
condensation, deflection of steam off of the walls, around corners l A 18
rg and on equipment'Would cause condensation and a reduction in steam
- temperatures.EAdditionall cabinets with louvers or few openings wouldcontaln!trappedair~y,hichwouldhavetobedisplacedbythe w
steam.and.thul t natural khermn) delay results. Research into the steam phenomenon.would most:likely reduce the predicted severity of steam line breaks outside containment and in compartmentalized containments.
Radiation is also predicted to occur instantaneously. The levels of radiation and tie instantaneous release are probably overly predicted,
- s. Industry responsibilityt this is best resolved by the Industry.
Staff Attestment:
In general, the environmental conditions that were required for [Q were based on accident analyses that included additional margin and are believed to be conservative. However. given the advances that have been made in our understanding of EQ over the past 26 years, and based on the THl2experienceandPRAinsightsldassurethatinformationinthissome may be necessary. The staff shou adjustments in the regard is catalogued and well understood, and made available to the industry, it is the licensees' responsibility to make use of new generic information, as well as plant. specific information, and to make
) adjustments to their EQ programs when such action is warranted. This does not necessarily mean that (Q programs must always become more restrictive; new information might very well support a relaxation in program requirements.
- age conditioning; Paar Review Comantit
- a. I agree,. itils'Well known and accepted that the methods established were the "best practical' given the (then) state of the technology.? Holes have been ident' fled in both the technology and its application. 1 am also of-the opinion that eventually we ,
need to get'out of the frame of mind wherein we assign a "quallf ted life" based'on simulated aging tests and than' treat it as sacrosancththd-pencil' whip .it to!. increasingly higher levels of precision depending upon whoidoes the' math using what information.
I bell'evithTFthCtfue'ansWeW11e 9tn verifyino' the ~ correlation between retF World' aging vs.' simulated' aging, In other words, condition ~ monitoring,
- b. This is a valid issue.
I
- c. Considerable rese' arch has been dedicated to age conditioning.
Prior to Sandla's research. NRC was presented with information nn how Arrhenius theory formed the basis of the Underwriter Laboratory Specification UL N6B and IEEE Stds 99 and 101.
A 19
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t Arrhenius theory la the basis for reliability Additionally,in ellitary. NASA and the semiconductor industry.
calculations The level of past and ongoing
- d. Merits analytical resolution.
expertmntal research on ageo u conditionint' )is evaluation is needed consistent wit
' importance of this issue.
to assure that future research is directsd to investigations of the highest priority that have the prospect of success in a reasonable time.
the lessons learned during the last.two decades t 1
a meaningful qualified itfe.
11aff Attettment:
Preconditioning of equipment is neceslary as a fund The amount of preconditioning that is truly necessary be conservative.
to establish qualification is subject to debate, however; and 25 given the
- advances that have been made in our understanding of h E0 over the past
! years, and basedThe onstaf thef should TMl-2beexperience and PRA r6cepthe to proposed insights. some c an changes
- may be appropriate.
in the methodology that are:
(a) developed as an industry initiative.
and (b) demonstrated to be technically ju*tIfted.
d
- margins (in general) and use of "greess margin" to justify shortene i post-accident test duration during 00R LOCA testing; ~
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i Peer Review ceanents: l Margins in general: 1 disagree. I don't think this needs work l
- 4. unless one wants to go after establishing a basis for possible ;
l
- relaxation of current IEEE requirements. The current practice of 1 usingIEEE-323typemarginsfortestparantersisjustifiableand represents a practical engineering approach to accomodate some i '
uncertainties such as manufacturing variations, and should be continued.
this
" Excess margin' hsed for justifying"short" duration tests:
[ issue deserves some attention by performing a set of very focused
- LOCA tests to deterstne if the results support the method in which
- sargins'or' conservatism in the test parameters Manywere typesused to
. justify shorter test durations in some.olde, alants.One sriould examine the of analysis techniques have been used.
validity of the extrapolation of Arrhento: parameters to ,
temperature estabitshed.
ranges far beyond where they were exl b.
This is a valid issue, but it is being addressed via the current NRC research program plans relative to EQ.
- c. Determine whether the test is modeled adequately.
A-20
- d. Margins were required to be documented for all plants, regardless of [Q licensing basis.
The e.' Meritt analytical resolutioni merits experimental research.
correlation between margin and its contribution to safety-assurance is not likely to be established quantitatively with any reasonable amount of researchi and it will therefore remain largely a matter of engineering judgment. However. If there is a serious question concerning the justification fer the use of excess margin to compensate for short 00R toCA tests, I doubt the It might question can be resolved simply by engineering judgment, be necessary to repeat some tests using the current LOCA testing practice and to compara the outcome with that of the 00R tests.
Staff Assessment:
liowever. given the Margins (in general) are thought to be conservative, advances that have been made in our understanding of (Q over the past 25 years, and based on the TMI-2 experience and PRA insights, some adjustments in the requirements may be possible and beneficial to the industry. Also, to the extent that focused attention is placed on operating plant experience and PRA information, equipment performance, condition and environment monitoring, root cause assessment, and trending of information, it may be appropriate to relax sorte requirements. The staff should be receptive to proposed changes in the margin requirements that are: (a) developed as an Industry initiative, and (b) demonstrated to be technically justified.
With regard to the use of " excess margin" to justify the short duration LOCA tests of the 00R Guidelines plants, this may be a valid concern and it should be reviewed further by the staff.
- the test sequence and test duration. including post-accident operating times; Peer Review rn-ants:
- a. This should not be..an issue after all the research that has been conducted to date. The current literature review [being completed undercontracttotheNRC]shouldputanendtothisonceandfor all, i
However, one can make a case for a shortened post-accident A duration for test aurposes, and consistency in this regard.
study focused on tsis narrow question that systematically eva)uates each ae.cident scenario for the time required to achieve cold shutdown (or some other acceptable intermediate plant condition)isdesirable,
- b. This is a valid issue.
/ c. Merits analytical resolution and experimental research. As for test duration, there is a need to evaluate the use of PRAs to justify short LOCA tests.
A-2) 0 .-.
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l e
Staff Assestment: 4
'f Research accomplished.
is good to a point, but there are limitations to l and tie information should be well understooda)and usedonina addressing be based 1ssues such 45 this one. Any further research should) be pursued only if well defined need (or additional information, b there is a good Itkelihood that the desired information willinbe obtained, and c) be pursued only if the cost of research is justified terms of the expected benefit to public health and safety.
With regard to post-accident operating times, 3 ave beenthere made inapgears to beG confusion and inconsistency.our understanding of [0 over be the past 25 experience and PRA insights, some adjustment to the requirements mayTh possible and beneficial to the industry. (a) developed as an ,
to proposed changes in the methodology that are: industry inti I
- mandrel 'ornd test requirements; )
Peer Review Commentat My I agree. The question is whether or not'they are required.
- a. i understanding is that the writers of IEEE-38) intended it to assure that vibratory and shock forces from a seismic event are properly accounted for in the environmental qualification process.
Many in the industry One areshould of thereserve opinion that these judgement on thf s requirements
' may be too consetvative. I issue because, contrary to what many believe, there are many installations (e.g., free hanging cable at termination points such and cables in flex conduits at as those with connectors terminationpoints)indantswhereincableswillbesubjectto forces during a seismic event. In an l
such vibratory and shoc(
aged condition, these Thereinstallations say be are a few enmples of f more ailures vulnerable to a l comon cause failure.
wherein motor lead wires grounded to short caused by wire l l
insulation (in.
motor-starting forces.
aged and brittle condition) falling off fromBu those from'a' seismic event.
Perhaps and insu 4' stud1&tions/?and
- can withstand thesesome forces can tests answerto determine th'ess
. questions 1This should be a low priority ltem practices, b.
This is a valid issue; needs to be addressed, c.
This test bounds the expected worst case dynamic / static forces that a cable may be exposed to in the field yet which are notif reproducible in a test chauber, is avaliable, it should be proposed by IEEE.
A 22
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- d. Merits analytical resolution; msrits experimental resr, arch.
There is substantial agreement that post-LOC /. mandre', band tests are too severs; and in some recent cable (Q programs, these tests have been omitted.
However, if they are omitted, part of their original purpose, l a., to account for vibration and seismic effects, would have to be addressed.
- e. Please provide an acceptable alternative.
$_taff Astettment:
Given the advances that have been made in our understanding of [0 over the past 25 years, and based on the THI-2 expertence and PRA insights, some adjustments in the requirements may be possible and beneficial to the industry. The staff should be receptive to proposed changes in this regard that are: (a) developed as an industry initiative, and (b) demonstrated to be technically justified.
- synergistic effects; Peer Review Coments:
- a. AfterallthetestsbytheIndustryandbySandiaandothers,it an issue.
is hard to believe that this is sil
- b. This is not a valid issuet suffletant research has been done.
- c. The synergistic ef fects of sequence have been addressed for many years with most test programs using the sequenca of radiation i
exposure prior tb thermal aging, j It
- d. 'Heritsanalyt'icnitresolutionVmeritsexperimental.research.
would be useful for the HRCho update its position to account for
~
the research conducted during the last decade. The ressaich results are difficult-to generalize and are somewhat inconclusive. There is some evidence that'the degradation of equipment during : 1.0CA conditions may overshadow sping degradation to such an extent that synergistic aging effects should not be a major concern.
). Staff Attestment: 1 To the extent that focused attentita is placed on operating plant experience and PRA information, equipment performance, condition and environment monitoring, root cause assessment, and trending of However, given !
Information, this issue becomes one of minor importance. l the advances that have been made in our understanding of (Q over the 1 past 25 years, and based on the THI-2 experience and PRA insights, some adjustments industry. in the requirements may be possible and beneficial regard that are: (a) developed as an industry initiative, and (b) demonstrated to be technically justified.
. dose rate effects:
A 23 n __ __ __ _
_ _ __ % .._ g I 1 i
- t Paar Review Coments: 7 and by landla and others, it 1
- n. Afterallthetestsbytheindustryllanissue. r l
1s-hard to believe that this is sti ;
- b. Not valid; sufficient research has been done.
l i c. Dose rate effects are considered to be second order effects, more than adequately accounted for by using the very high radiation total doses typical of qualification. meritt experimental research. It
- d. Merits analytical resolution *ko update its position to account for l would be useful for the NRC The research the research conducted during the last decade.
1 results are difficult to generalize and are somewhat inconclusive. ,
- There is some evidence that the degradation of equipment during 4
LOCA conditions may overshadow aging degradation to such an ext that dose rate effects should not be a major concern. i l 1 Staff Assessment: i synergistic effects (above), See the staff assessment re: l i
'
- oxygen diffusion considerations; and Peer Review Connenti: l J
l a. This is a valid issue. l l
- b. because !) many plants use inerted containment i
credit has not generally been:given, 2) oxygen is shown oxygen di(fusion to be'a source of differences in i anticipated and expected results. It
- c. Merits analytical resolutioni merits The research experimental r I the research conducted during the last~ decade.
- results are difficult to generalize and are somewhat inconclusive. l' l There is some evidence that the degradation o j i that oxygen diffusion effects'should not be a major concern. I insulationmaterialswerenotalwaysevidentinlaterc Also research, It is realistic d.
What realistic assumption are being referred to? assumptions that requires the consid6 ration of oxygen diffus'on.
- The assumptions being alluded to should be provided for revie discussion.
Staff Assessment: A 24 l
See the staff assessment re: synergistic effects (above). I o Cost. Peer Review Comments: ; a. This is truly an issue, especially in the current competitive utility industry environment.x This should be addressed perhaps by i keeping an open mind to review and where practical acc An example of this.already seing i piemonted is the HEQ exemption request. Another, area worth pursu no from a regulatory aspect is l to remove the requirements to estab11sh and track:"Quallfled 1.ife " and substituting it with greater reliance on equipment operational reliability analysis, reliability centered maintenance and condition monitoring / assessment. - From the regulator's perspective, this will require a study to establish a framework I for implementation. Such an approach will also go a long way I toward addressing EQ related license renewal considerations. might also note that this approach will be consistent with those ! of Germany and France.
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Also, the indu'stry needs toldo its' part by doing more jointandgroup work on qualifying.new equipmenti EQ problem resolution lndustry at l standardizing. systems / equipment /foruseinithenuclear least at plant. vintage level.s.dThis'is what the French do and we can learn from their experience.
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- b. This is not' an'EQ' issue; do value liipict.
f
- c. The conc'ern is not clear; the' specific cost problem (s) should be l identified.
l Staff Assessment: j Cost is definitely an issue for the industry when it comes to E0. Whileand there may be acceptable cost-cutting measures that can be taken. l the staff should be receptive to reducing costs that are imposed on the industry, the onus is on the industry to propose and justify lower cost . j alternatives i The following problem statements expand on certain aspects of this issue: l l J Different E0 standards were imposed (i.e., DDR Guidelines, NUREG-0588 , Category 1, and NUREG-0588 Category ll) without support '. Justification as to:and (b) why " progressively less strict standards" were adequ older plants (e.g., older plant equipment qualification is not as rigorous as NUREG-0588 since the components have been qualified without aging, margins, or considering synergistic effects), ] Peer Review Comments: j I a. There may be some instances where equipment quallfled under 00R l A-25
~ ' -- . _ _ __ _ _ _ .
This requirements would not have passed Category I requirements. - 15 an issue that should be evaluated by RES in regards to itfe , extension since the effects of in situ aging past 40 year plant operation must be addra.ssed (particularly for cables). l
- b. Somehow. I thought that there was " supporting technical j justification."
- c. This is being addressed by the current NRC research plan.
- d. Different'EQ standards were applied because of licensing !
l differences between vintages of, plants. The attempt was made ' j When to assure that technically each was effectively the same. the j 10 CFR 50.49 was issued and licensees were required to meet rule, the major impact was to add some iter.s to be quallfled. l ! The EQ contentions at Shoreham (NVREG-0588 Category Il plant) were ' l largely based on the differences in EQ requirements for different vintage plants. The contention was that the EQ program at 4 Shoreham was deficient because of several items including the concern that equipment was cualified by grandf athering to older, less stringent standards anc that there was inadequate demonstration that all safety related equipment was properly $ a quellfled to meet aging and other life requirements'. The testimony of NRC Staff James E. Kenney and Vincent 5. Noonan concledad that "The new legal requirements (10 CTR 50.49) are based in large part on the previous requirements and are not The expected to significantly modify the existing [EQ) program " l ASLB found in favor of LILCO. ! At the time of 00R Guidelines and 10 CFR 50.49 promulgation, it l was the consensus that 1) all plants had equal technical l requirements to demonstrate by testing that equipment could operate properly during and following DBA's and that met equipment such as motors, cables, and HOV actuators were quallfled using pre-aging, regardless of the plant's 00R, NUREG-0588 Cat 1 or Cat !! licensing basis. l My opinion is that the known synergisms, The changes such in as dose rate and properties sequence are second order effects. _ caused by these second order effects are insignificant when compared to the degradation caused by using conservativ conditions. it in NUREG/CP-0135, p. 2 16. < e. Merits analytical resolution; this is a valid concern
$1nce the HRCand one that is already has been recognized by the Commission.
investigating this issue, no further comment is offered.
- f. There are basically two standards, simply because the 00R Guidelines and NUREG-0588 Category II are quite similar.
i A-26
. HUREG-0580 Therefore, we have HUREC-0588 Categories I and 11.
Category eventually reach. I'is the standard which all plants are supposed toTh justification older plants. for the progressively less strict standards forH not been developed. l Staff Assessment: 00R Guidelines, Although u fferent EQ standards were imposed (i.e. NUREG-0588. Cat. I, and NUREG-0588, Cat. II), each was intended to establish a reasonable level of assurance that equipment would function when needed during a postulated event, given that some plants were already operating while others were in various stages of construction. It has been argued that one method is more rigorous than another, but this becomes irrelevant if one accepts that each method is sufficient The to establish qualification for some initial, prolonged period of time. l critical question becomes one of how long the qualification is good for. 1 None of the qualtftcation methods has been successful in establishing A
" qualified life" with any degree of certainty and all must be supplemented with operating plant experience and PRA information, equipment performance, condition and environment monit provide assurance of continued qualification over the life of the plant problem statement concerning " state of the art capab determination of a " qualified life, below).
The current version of IEEE 323 may be better suited for demonstrating E0 than the 1974 version since much more information an Fear Review Comments: Do the 115'or so operating plants, and their vendors, meet the new
~
a. IEEE-323 standard?
- b. This is a valid issue,
- c. The current version of IEEE-323 is not different than the 1974 version with respect to qualification practices and there is not Thus endorsement any further knowledge provided in the standard.
of newer versions of IEEE-323 is unnecessary. i d. Merits anilytTcil resolution; IEEE claims that the two versions ) are equivalent,' but not all parties agree that such is the case. On varlotis cccasions, the NRC has communicated its position on this matter orally; it would be helpful if the position were documented,
- e. This is tot:11y false and would only be made by someone totally unfamiliar with EQ. What is the basis for such a statement? tiow is the current version better suited to accomplish the intended A-27
- __ ~~~-- -___ _
Has the person who posed , goal of environmental qualification?If so, what is the basis for this question read both versions?If not, please read the two documents. this statement?
$taff Assessment: f [0 over Given the advances that have been made d PRA in ourInsights, understanding o the past 25 years, and based on the THI-2 experience ficial an to some the industry.
adjustment in the requirements f may rmance, be possible and b d operating plant experience and i PRA information, equ ous trending of information, some relaxation of the more r gorThe staff should be rec requirements may be warranted. (a) developed as an industry proposed changes in this regard that are: initiative, and (b) demonst ff Given the Regulatory 1(([ Requirements 323-74 requirements Review Comittee would tprovide equipment . . .aand the NRC sta view that backfitting thesmall, unouantifiable increase ld be tly justified in the level of assuran is Qualtfled as compared to the significant costs that wou egardless of involved...." lEEE 323-74 may not be warranted or sufflc I when the Construction Permit Safety [ valuation l Peer Review Comments:
- a. I agree, except in the case of life extension. ,
Cost impact is b. Maybe a new cost benefit analysis is needed.' certainly greater for existing plants. outside the scope of research,
- c. Non-technical issue; in my opinion is unnecessary because Backfitting to IEEE 323-1974
- d. 1)there'islittleequipmentthathas.notaireadybeenupgraded new testing' including aging, 2) as equipment is replaced, new 3) qualification programs areIncreased being. performed to safety rain.rd equipment qualified using aging. d concentration ~on knowing equipment's cond !
corrective actions. t
- e. The constructionThe Permit standard used SER to judgedate thell was simpl amounts equipment at that time.
and is capability of equipment toThat perform its function I supposed to represent minimal safety standards. Comission directed the NRC staff to provide te plants. A-28 c
~ ~ ~ - - - - - - - - - _ _ _ _ _
y I i Staf f Anestrant: See the staff assessment of the previous two problem statements. Current
- state of the art capabilities" may not be sufficien a " qualified life;"
Peer Review Comments:
- a. Unless the issue deals with Ilfe extension,1.believe that quallfled. life has been adequately determined using existing technology.
The concern is not
- b. ...and then again, In many. cases,'they may be.
specific enough:to comment on. : As written, it sounds shallow and superficial, as well as negative.
- c. This is being addressed by the current NRC research plan.
- d. Merits analytical resolution; the concern is valid and a concertedThe exp effort should be made to resolve the issue.
last two decades has demonstrated the difficulty of establishing qualified' life without41arge uncertainty.. One altern to LOCA. testing'and enhanced condition monitoring in service, e.- The stat's off th'eTart "is' the' stat's of the art. iln t',e early 1980s whenithe current EQ rule was codified, it was' concluded that in orderit o bsltssured that <a specific piece of equipment can be relied upon tol perform ~a required function at'a given time, The method that was ; equipment hat to' have. a qualified life.a more To date, acceptable to both indus Methodology of calculating qualifleo life. acceptable method has not been developed, f. Current " state' of the art capabilities' are sufficiently developed f to support the existing qualification requirements,The including first part qualifled life.. This ;is really a two part answer. addresses whether safety related sculpment can operate pr during the DBA.
)
aging. Oper'ation of' safety related equipment during the DBA,1) is the i most~ important part of environmental qualification, 2) was required of all plants (DDR'and HUREG-0588), and 3) is the
~ documented proof, through LOCA simulation tests that safety related equipment can perform its safety related functior. before, during and following a t0CA.
The NRC's and the nuclear industry's reliance on type testing for environmental qualification, rather than the other qualification options, such as analysis or operating experience, provides A-29 l l
I l llflod ' substantial assurance that safety relate:I equipment is qua to the harsh environments. d to Additionally, ths vast majority of equipment was i g itstesteThe sign i enveloping, worst case accident profiles. this is that equipment may Itbe subject to a line bre does not have to installed life. major double ended guillotine type break.The qualification prac survive more potential all of the. than one. line breaks for equipment in then a l the plant.c An enveloping temperature / pressure profile developed. ' Additionally, when equipment again was beinl > multiple plants, the worst case enveloping profiles i nt. enveloped. actual DBA was less in severity to the enveloping requ reme' l Thus, additional conservatism was added t to The the temperature pressure, chemical spray, and radiation requiremen s. successful completion of a DBA simulationl test. d t willof a f representative sample, tested to this wors operate as'needed. t Additionall ,'fbr {tems'such as cables,'more than one tel was most likely performed. ' page E-21, it was noted that one manufacturer's test c to over 11 OBAs. I Temperature / Pressure / Steam profiles is a4quate since facilities in the US and throughout the world have this capability; pressure max imums durLng DBA simulatio
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Table 1 l Typical Maxisten Typical Maximum Plant Type Temperature of Pressure of DBA DBA 50 psig j 308 'F DDR Guidelines BWR 35 psig } di, ' F I DDR Guidelines'PWR 50 psIg _ 340 *F NUREG'05BB Cat I BWR 60 psig 400 to"500 'F lNUREG'0588 Cat ! PWR i nt l l Additionally, Fort St. Vrain, a HTGR, had Its muchcable ofwas its equ b qualified by type tests for temperatures of 900 'f. e the same as many other plants. HRC I: L All plants were required to document the qualification a reviewed and tudited these results. L A-30 l jj l; I
(----- - i Thus, the capability of safety related equipment to operate in a-DSA has been adequately demonstrated using the state of the art of type testing. Strong support for testing comes from the theorem ;
- ' that one test is worth a thousand expert opinions. !
l The second part of the issue, simulating the deleterious affects in the ! j of aging, has been performed using the state of the art, ! late 70's several studies were performed to determine the methods to be used to" simulate aging.- l There were many who cited the lack ! of complete understanding of.the aging process as an excuse to not
^ ,
i move forward. .However, many tn the nuclear Industry and the NRC ' l saw the need to consider what was known about aging and how other l industries had addressed the problem. Three stjor industries had been uttilzing techniques for many l years to address aging and all~ three had basically been using Arrhenius Theory. These were: 1) Underwriters Laboratories for
- electrical insulation and plastics, using UL 746B; 2) the cable +
' industry using IEEE 99 and 101, formerly ANSI A57; and 3) the military, NASA, and the semiconductor industry using reliability ; l theory for 1tfe testing, which uses the Arrhenius equation to I calculate life and failure rates. Other aging theories had been proposed. The main reason that the i nuclear industry.. accepted.Arrhenius theory as an acceptable form : of accelerated aging >was 1) Arrhenius Theory had the most data behind it, 2)'Arrhenius para' meters'for the most part had been developed by testing, and 3) Arrhenius Theory had been successfully used in military and NASA reliablitty efforts. t Arrhenius theory was the best theory available at the time when it was found to be acceptable in NUREG-0588. It continues to be the best and state of the art. The accuracy of' the 'qualifiid life determined by the Arrhenius equation has been a historic,.arpment. . In order to satisfy industry concerns on accuracy, several conservatisms are used in The most important are: qualified life calculation assumptions. 2 assumed material function,
- 1) assumed operating temperature and3)assumedinteractionofmultilematerials.
These conservatisms and assumptions were addressed as follows. The calculation for qualified life usually assumed that the materials of the safety-related equipment were at the maximum of the assumed, temperature range and.then heat rise and hot spot Over the temperatures were added to this maximum temperature. years, lessons leat..ed. like determining the actual temperature
~
rises of items cot..alning significant heat sources, Ilke solenoid valves, motors and transformers, were-incorporated into the qualified life calculations. Materials typically showed different rates of deterioration as to whether electrical or mechanical properties were being evaluated. A-31 L- _ _ __ _ _ ___
Thus the assumption as to whether the materials had an electr function, mechanical function, or both, was an important assumption. h Lastly, few safety related pieces of equipment are simple enou3 to be com rised of only one material, such as most terminal Aan multiple materials are present, the material with blocks. the lowest activation energy was chosen for the quallfled life calculatlon, -This assures that all materitis with a higher . activation energy are a0ed t0 a longer qualified life. Additionally, wSth multSple anterials, an implicit assumption is that the materials are compatible with each other and that new, synergistic reactions don't form. Since much safety related equipment was quellfled by accelerate aging, material incompatibility was discovered when it wasRedesign present, because these items failed aging tests. [ retesting were required in order to achieve qualtitcation. The results of such research in the 1980's has generated a lot evidence that qualiffed lives may be conservative and little evidence exists that they may be overstated. In y opinion the accuracy of the qualified life calculation hingesdramatIcallyontheunderlyingassumption there is not an inherent flaw in the assumptions. The most' dramatic impact on quallfled life would arise if the underlying assumptions were grossly different in actual service. Thus, new and continued focus should be on the s underlying assumption was flawed. Equipment's condition can be' ascertained with intrusive periodic testing, but this may cause more failures than leaving the equipment preferred. Installed.. Non-intrusive condition monitorin to monitor the temperature of individual pieces of equipment, non-
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c_ intrusively. Thus,'in addition to ambient temperatures, it is s possible to obtain temperatures actually at an temperature exposure to be verified. an equipmentipopulation which for the most part is operating at significantly lower tenneratures than were origi This corrective than assumed,-corrective action can be taken. action includes recalculation of qualified life and loweringIt is I-temperatures when possible.the condition of each safety relate 2= evidence of the conservatism in the qualif ted life. {(( In NUREC/CR-5762, infrared thermo raphy was shown to be to age related degradation.
.. n
[
- - - - - _ ~ ~_ _ -
I overheating results from poor connections anu less efficient heat transfer occurs. The assumptions that form the basis of quallfled life that involve material functions and material a few refinements of existing practice, first, existing . interactions can be add operation, maintenance and surveillance practices provideAnytim safet information on equipment operational state, related equipment f alls to operate pro)erly, a component CRCFA's root cause failure analysis (CRCFA? should de performed.should lf thebe' rootscrutinized cause finds evidence to see of material function capabilities and/or material interaction ora a otherwise'. indicates;fqualification,' eThis direct feedback to the EQ for in the~ original process based on the knowledge gained in CRCFA's is very impo and necessary to assure that the state of the art in the original aging program was adequate. Several examples exist where the CRCFA identified a flaw in the NUREC/CP 0134 pages C5 to C 19 provide some assumed conditions. Additionally, a few recent f ailures of penetrations examples. showed that the environment was more humid than originally assumed. Staff Attattment: , Based on the information that has been reviewed item 3, the term 'qualifted life" appears to be a misnomer. There areunder (Q-TAP assembly, installation,sim>1y too many unknowns and uncertainties rel metsodology (e.g., formulation of compounds' operation and upkeep of equipment) to be able to make While a specific it determination of quali(led life with any degree of accuracy. , is not possible to establish a specific quallfled life, the initial qualification testing methodology (i.e., DDR Guidelines, NUR[G-0588, Cat 1, and NUREG-0588 Cat. II) does establish equipment qualification for some prolonged, but indeterminate, period of time, in order to address concerns such as this one, the NRC staff should assure that full advantage is taken of operating plant expertence and PRA information, equipment performance, condition and environment monitoring, root cause assessment, and trending of Information, so that to deficiencies can be identified and resolved on an ongoing basis. Implementatten of the maintenance rule will help to resolve this issue for active components, and the staff should intilate action to includn electrical equipment within the scope of the maintenance rule to fully - address this concern. The staff's assessment does nos mean that equipment is no longer qualtfled; it simply recognizes some limitations that exist in the state of E0 technology that need to be addressed in a more focused fashion. Untti such time that specific equipment qualification deftciencies are idontif1ed by enhanced monitoring methods, existing qualif(cation 15 assured by the Inillal [0 testing that was performed, twentv-five years of research, and equipment performance and opersting experience. A 33
nave Ween made in our understanding of i PRA rinally, given the advance. ibn in the exper ence,
'n nvar tne past 25 years, and based on thet TMl-2 oignts, and operating plant expertence, someThe industry. staff adjustmen e: s reou h-vements may be possible) demonstrated and beneficial to be to thec rece veloped as an Industry initiative, and (b hnically justified.
tificial and natural ( - A correlation has not been estabilshed between ar I aging. Ep r Review C a tgj Lit Instances, natural aging can be more severe than
'e . True . In som. has been comonstrated for cables, I
j artificial. 1 8: ntver be established for all components and
- b. A correlatlet, me i
materials.
- c. This is a valid issue.
d. Several attempts have been made and UL and are in progress tow I correlating artificial aging with acetlerated aging. l reliebt11ty testing have established l that the same failure t d tests. l mechanisms were developed in artificial his question. l piant The and ac l materials is a long term attempt at answering t t ity to use of Component Root Cause Failure Analys j correlate the artificial and natural aging, itshed j Merits analytical resolutioni correlation has l been estab f
- e. between accelerated thermal and radiationdaging for and natura l thermal and radiation aging under restricted However, it is true that the correlation is conditions an I
' selected between materials. accelerated and natural aging of equipment ass modest at best. This concern is one of the factors to to be taken l The following additional views were also
- other related issues and problem statements:
The experience of the last two decades has demons difficulty ofOne establishing qualified life without large alternative to the requirement for LOCA uncertainty. i qualified life is the use of stress testing pr l stateoftheartcapabilities). More effort should be directed toward ap requirements to resolve the problem of demonstrating a meaningful qualifted life [re: ageconditioning). A.H f.
1
- f. The idea behind artificial aging is to Both put the equip:ent NRC andin an end of Industry j
I ilfe condition before accident testing. l have agreed that artificial aging is the best way to accomplish ; this. If there is a better way of accomplishing this goal, we would all like to here it. , I ! ! Etaff Assessment: This is one of the uncertainties inherent in the CQ methodology that was , referred to in the staff's assessment of the previous problem statement, i To the extent that focused attention is placed on operating plant j experience and PRA information, equipment performance, condition and 4 environment monitoring. root cause assessment, and trending of information, this issue becomes one of minor importance. Some aging
- Some significant aging mechanisms cannot be accelerated. !
mechanisms required to be simulated may not be significant for all samples. l Peer Review tonnents, f l i a, Probably true, i
- b. This is a valid issue.
l
- c. Some aging mechanisms may not be idecuately simulated because 1) l the environment was not adequately Icentified and 2) ion. daughter This is
- standards have attempted to define the aging simulat an issue in two treas.. First, failures within the last 6 years
! have identified higher than anticipated humidity conditions j several heat plants.Also, IEEE-3 D for penetrations, specifles dry heat aging. J aging. Given recent experience that humidity is higher than ssumed, this standard should probably be modified and the state l of the art in aging under higher humidity conditions may need to be improved. Other industries,Jfor; instance Navy and other 4 i military, de have standard humidity. . salt spray, fungus, etc., test methods which eculd be employed. The first i ' d. Industry responsibilit/I'b'est r'esolved by the industry. sentence identifles a valid concerni the fact that some
! significant aging mechanisms cannot be accelerated is one of the l f actors to be considered in re-evaluating the qualified life The second sentence appears to be inconsistent.
requirement.because there is no requirement to simulate aging mechanisms are not significant. The following additional views were also expressed in response to other related istues and problem l statements: l The experience of the last two decades has demonstrated the difficulty of establishing quellfied life without large uncertainty. One alternative to the requirement for qualified life is the use of stress testing prior to LOCA s A 35
i (res - testing and enhanced condition monitoring in serv ce stateoftheartcapabilities). More efteri, shouhi be directec toward a requirements to resolve'the problem ) of demonstrating meaningful quellf f ed life [ ret age conditioning . if one aspect of If something cannot be done, it cannot be done, il reason
- s. a policy cannot be accomplished, In cases'such as'this, that examplesis notshould necessarbe y a to scrap the policy.Anyone can make negative statements a provided.
that they dissgree with. (taff Attinggg: See the staff assessment of the previous probism h ' may statement. Excessive reliance is placed on analytical l nts. aging calculations not be as reliable as testing. especially in older p a Peer Review Cementi: a. Could be true, but the significance may be small.
- b. Maybe. Cost is a factor.
Industry responsibilityt mort NRC. oversightlt may be need
- c. Neither accelerated aging nor.isging antlyses are very r methods' of estimating qualified ,IlfabtIn the case of labo the problems include'the uncertainties introduced by aging,ive extens extrapolation of experimental-data in the app the Arrhenius method to thermal aging, lated to the laboratory e extensive aging time, contraction and theoffact the life simuis not practical that-it it to simu stgnlficant aging mechanisms @ !n'the case i t of aging a i the is difficult to estabitsh a rathematical model of equ pm Basically, it is regulatory not feasible to account for aging oversight can at best rule out any in a tech taking into cally rigorous wayexcesses in the ag Thengfo1 component ofdqualificatio account the limita lons of the process. views were al problem statements:
The expertence of'the last two decades has demon difficulty of One estabitshing quallfled life without large alternative to the requirement for uncertainty. to LOCA quallfled life is the use of stress(re:testing p stateoftheartcapabilities). Hore effort should be directed toward A- H
I. requirements to resolve the problem of demonstrating a 1 l meaningful quillfled life (ret age conditioning). '
- 1he fact that some significant' aging mechanisms cannot be '
accelerated is one of the factors to be considered in re-acce evaluatingthequaltfledliferequirement(re: ' of aging mechanisms).
- 11 is true that the correlation between accelerated and natural aging of equipment assemblies is modest in a re-evaluation of the qualified life requirement (re:
i correlation between natural and artificial aging). l Analytical aging
- d. The intent of this statement is not clear. The l calculations are (or should always be) based on testing.
problem in older plants is that there were neither artificialN
- aging nor testing.and testing In addition,.if this statement-is is synonymous.
suggesting that equipment in older plants should be tested to , determine its capability after having been in service for some period of time, than I say that a test such as that is fine forHowever, s
- il 9etting some appreciation for past performance. test does nl performance of the equipment-in question. equipment in older pla l condition and then tested, then some useful information may be obtained,
{ itaff Assessment: See the staff assessment of the three previous problem statements. l (quipment " aging" has typically not been performed in the s _ energized). Peer Review Comments:
- a. If true, the significance may be small,
)
- b. THay behrue~1n'~ some cases',
l
- c. 'Typi'c ally?
- d. Non-issue; addressed by IEEE standard.
l o, in most cases in the plant, safety related equipment is not continuously energized and thus aging simulations utilizing However when devices are i unenergized specimens la appropriate. , energized, such as solenoid valves and motors, the aging in many cases did utiliza energized devices. A.37
l When it I
- f. Industry responsibility; best resolved by the Industry.
l 1s feasible to energize equipment during accelerated aging, doin l so may contribute to the simulation of some significant aging effects better than would be the case without energizing. However, it is not always feasible to energize the equipment, e.g. energizing at elevated temperature may introduce aging In such cases. An mgehenismi that do not exist in real Service. ef fort to account for the erfests er enereipation tan be ma(e by treating the temperature rise'at part of the service conditions, i.e., by calculating the operating ~ temperature of a component by adding the temperature rise due to energizing to the environment Research on this topiciis;not Ilkely to be temperature. The 6ehearn emphasizes'the po'nt made in earlier procustive. paragraphs that an effort la nesses to replano quattr.sa tire as a major element of EQ. It should have been. g. Staff Assestment: See the staff assessment of the four previous problem statements. In lieu of att emn'ir.g ta 4 fine a ' qualified Itfe, It service degradation. ' Peer Review Commentit
- a. I disagite. Qualified life means the time that a component can function in its installed environment and still be expected to withstand'the effects of a DBE. how can modes induced in the test specimen by the DBE environment, periodic degradation monitoring accurately reflect how the component would react in the' harsher environ DBE?
function in a DBE on the first day it was installed?
- b. Both are probably needed,
- c. This is a valid issue.
Qualified life as currently used is normally in d. ~ . As long as' tie condition of the equipment has be considered within its quallfled ) ifs. q.:allfled life time does establish good controls on maintenance and replacement, but it is possible that $n equipment's conditio could deteriorau prior to the attainment of its qualified life. When this is the case. only t;ie concept of condition monitoring would allow the identtfication of this degradation. The following
- e. Good point; earlts anal.'llcal resolution.
A 38 l
l additional views were also expressed in response to other related lanues and problem statements: V ' The' espe /istici'of'thEla'st#two decades has demonstrated the
~
establishing quaitfled 11fe without large difficulty of,One uncertainty. alternative to the requirement for qualif ted. life is the use of stress testing prior to t0CA testingandenhancedconditionmonitoring'nservice[ ret state of the art capabilities). Hore'e'ffort'should be'. directed.toward applying the requirements to resolve the pt:blem of demonstrating a meaningful quellfled life [rell age conditioning). IEEE has initiated an effort to consider preparation of a standard that will address the d:e of operating experience inqualification(re:useoftestdata),
- f. It may very well be; this suggestion has been made previously but no one seemed to want to, or was willing to, develop an acceptable way of monitoring in-service degradation.
$taff Atiettment:
See the staff assessment of the fourth problem statement (above).
- Margin requirements for demonstrating [Q (e.g., one hour minimum operating time, thermal aging, etc.) may be too' severs definedwithsupportingtechnicaljustification.
Paar Rev{aw co ntat I cannot respond'without" knowing the basis for the term 'too I severe."
- b. This was done for conservatism.
specifically,
- c. De careful - margin can cover a lot of sins, margin can address unknown and unquantified concerns,
- d. This is a valid issue,
- s. I haven't espertenced the situation where the margins have.been too severo and thus jeopardized the safety reinted equipment's performance, The use of-margins does simpilfy the enncerns about test equipmer.t accuracy and seems-appropriate considering the uncertainties in predicting DBA environments, Industry responsibilityt I am not aware of any specific required Therefore, f.
values of margin. There are only " suggested values." E0 requirements do permit the adjustment of margins to avoid any A-39
\
-- a ,.x. . - -.:n m - s +
The values that are too severe or ;that cannot be juttified. , greblemisthatithasbeenmacommonpracticet. j burden of just fylng the margins chosen, states that marcin does not apply to the aging component o l The following additional view was also expressed in response another related issue or problem statement: l in and its contributten to Thecorrelat'lonbetweenmar!1ytobeestablished safety assurance is not itk and quantitatively with any reasonable amount of researchi it will therefore remain largely a matter of engineer 1ng judgment-[ ret margins in general), 2 l
- g. The technical juttifiution l's the lack of preciseness .
accident scenariosandvariatlonsinmanufacturingtechnthues.
.f a goo technical tested Justif\cationfornothavingmargin?
justification can be presented for not having But the current m
- requirements, purhaps margin. requirement is not justification. l l
Staff Assetiment: of C0 over i hts, Given the advances that the past 25 years, and based on the THI-2 experience have been made in ourand l to understa P A ins some the industry. adjustment in the requirements may be possib operating plant experience and PAAassessment, r6ct cause information, and equipment perf condition and environment monitoring, ion of the more rigorous trending of information, some .414 a tThe staff should be raceptive to ' requirements may be warranted (a) developed as an industry , proposed changes in this regard that are: int *lat've, and (b) de The need and/or ability to establish post accident qualification a two to four week period is questionable. Peer Review Commenti:
- a. 71' dontMdkftisd tho' l'ssui.
- b. >' Dayond EQ'acope, I interprat thn
- c. This"is*not'clia'r; meriti analytical resolution.
statement to mean that operability does not need to be demonstrated for periods exceeding two to four weeks, l.a.,
)eriods of 100 days to a year. (1 assume it does not instead of mean that tie LOCA test need~not be longer than two to four weeks.) If the withcuestion very littleis basedAsoperating equipment on PRA studies after to the " ability a* few tha can be contro11ec days, the NRC should document its position.
A-40
.m to establish post-accident qualification for period The following additional views were also duration of the period.
in response to other related issues and problem ya l There ls a need to evaluate the use of PRAs to .iustiry short
~
t0CA tests (ret.. test duration}.
* 'ItNil1'Wuisful[for thiHRC to establish its position on the'applicabilithof PRAssto equipment qualification (re:
PRA implicattons),
- d. A'significant riuinbar of plants _and all of the most recently i licensed plants "have establisb post-accident q qualification for one year (Seabrook, for unmple, One year estabilshed is not a a
>ost-accident qualification time of one year).it is not even a staff su
<RC staff requirementi in facti TH1 is an example where post accident qualification and monitoring i provided.ir. formation far beyond the 100 days that the NRC s requires. What support is there for the supposition that two to four weeks is sufficient?
Staff Attestment: Civen the advances that have been made in our understanding of C0 over , the past 25 years, and based on the TMI-2 experience and PRA insights, l l some the industry. adjustment to the requirements may be possible ai methodology that aret (a)developedasanindustryinitiative,and(b) demonstrated to be technically justified. Time and dose rate testing requirements suggest that equipment quaitfication extends beyond the DBA and into severe accident space, which may not be entirely appropriate. Peer Review commentit must be
- 4. Equipment needed to mitigate an accident, such as a LOCAInsome demunstrated to be capable of performing its function. This cases, this function occurs after the initiating event.
equipment has'to withstand the environment created by until calladsu)on to perform. align R}lRitoltie, containment sump or AG 1.97 indication nee assist operaters in assuring the plant is/ remains stable,
- b. Done for conservatism,
- c. I don't un'derstand " Time and dose rate requirements suggest that...." Documents Itke NUREG-0508 address only DBAs and the required post accident service, and component qualification What's the test reports are very specific about test conditions.
A-41
- __ a*aa problem?
If severe accidents must be addressed, 1 think there's no doubt that much presently. Qualified equipment pnnot ha < quallfled for much service.; . ,%. Iagree.Mit'is'truethat'theidosesusedln(Qthusfarmaybe
~
- d. very conservative, but I am convinced that this a m does merit additiona, research work'becauset The current accumulated dose, dosetherate Through severeand time are on releases calculated using fl0 13444.
accident studies, it has been shown thtt for EQ purposes. Dut,if and t ven that the qualification effort is m , these levels. what is the issue here? is it that by recogniting thett shculd levelsbe oftaken conservatism, up under we can l relax the requirements? If so the systematic regulatory regulromants review program.
- Also, thl issue does not m rit any additional research effort under the EQ TAP.because plants operating today are not likely to derive significant benefits from suc relaxation.
the new reduced dose Will be more tian any potential benefit. Theongoingliteraturereview[beingconductedundercont
'should provide confirmation that the materials used in theNRC)dsculamentdoindeedhavemorethansufficientcapabil '
cualifie tie doses = currently used, and that the life Ilmits to withstanc are governed by thermal degradation. MostequipentisquailfiedforsomeperiodoftimeafteraDBA
- e. This varies depending on the operational function 2 of the sai related equipment and typically varies from I hour post DBA years post OBA.
I am not aware of i i
- f. The issue is not clearl what Lim is intended 7an I of LOCAs, MSt.Ds, and other HELN f 10 CfR 50.49, including time All requirements within the scop 9 and dose rate testing, are limited to design basis accidents Staff Assessment:
Given the advances that have been made in our Instehts, understandin the past 25 years, and based on the TMl-2 expertence lhe and PA ht some relaxatton in time and dose rate requ i A 42 m m -- - mmm_._--_-__.
are: (a)developedasanIndustryInitiative,and(b)demonstratedtobe l technicallyjustified. The " double peak" requirement (i.e., exposure to two cyclst of maximum temperature and pressure) is not representative of design basis conditions and may be too severe. Peer Review rnnnantst i l A. This was done for conservati.;m. 1 l
- b. Are we planning'to develop new equipment (and manufacturers) that l will benefit from a single peak requirement?
- c. Valtd, but<the'HRC has adopted,a. conservative opinion.
d. I have not"ix'perienced that double peak testing It was during changed DDA to one simulations was too severe on equipment. peak testing,because no credit was given for the assumed margin; that it was supposed to represent. i'
- s. Merits analytical resolution'(i.e., analyze existing information ;
Introduction of the
- double peak" in LOCA to react) resolution).
testingwasbasedoncengineeringjudgment,withtheobjectiveof : achieving reasonable' assurance of equipment operability by the E0 1 process. ' For example,!!it introduces conservatism that helps ; counter the concern that.only'ont specimen is tested to establish l qualification. ..While it may not be representative of.designThe conditions,1po such claim was intended.it is too'severei ' areadequatelyconservative,'maymer.ltmoreengineeringjudgment in based on the extensive accumulated data bar,e of LOCA testing (h I: . the USA and in other countries)! however, experimental researc not a priority. I
- f. The bounding" qualification profiles in Appendh ". (NUREG 05885 were generated based on a wide spectrum of postulated acciden;s.
In some'catesiithese proflies can be considered to be overly 1 conservativeihoweverhin'theiabsence of an approved plant-
- ecificiprolle 7this' profile may be used and is considered;the m nimum"bc@ ding profilei%!n'generslethis profilt:may represent 6 hours offsuper eat conditions'followed by 18 heurt of saturated l
l2 conditions.o The actual degree of superheat is left as an opent 1: parameter'for, >ecified and lhe test pressure as'a minimumfor the timersis to be equal to or Obviously the greater than* tie' containment design pressure. higher ! temperature. See NUREG 0588 Rev. 1, Part II, comment and One resolution no. 91 for additional discussion on this issue. should recognize that the curve in Figure C-1 of HUREG 05BB is
'I provided for those BWR and PWR ice condenser factittles which do i not have plant-specific accident profiles available I must for use be clear here,inthe their equipment-qualification program.
i A 43 ;
*dotble peaka is not an absolute requirement, but rather, it is to ,
be used in lieu oflie usint a plant (see NUkEG 0588 specific Rcv. 1, SectContainment i ons tes and pressure design prc' 1.1 O) and 1.2(2). 7 Staff Assestment: f [Q over l Given the advances that have been made d PRA insights, in our-understanding o the past 26 years, and based on the THI ! experience d benaficial an to some the industry. adjustments in the requirements may be possible t performance. 7 operating plant expertence and PRA information, equipmenroot condition and environment monitoring, ion of the more rigorous
- l trending of information, some relaxat The staff should be receptive to requirements may be warranted. (a) developed as an industry proposed changes in this regard that tresinitiative, idelines and (b)
The generte temperature profile that su was allowed by the 00 for PWRs and and NUREG 0508 for equipment qualtitcation (i.e.. T , T n
- 20'f for DWRs) was not fully justified.
i Peer Review Comment 1: information was used as a - a. It was smy understanding that the T tool for screening when judging fication inIITyldu all potential line breaks and these were used in the qu process, f.e., analyze existino information b. Merits analytical resolutioC(d be helpful if the NAC documented It woul to reach resolution). its rationale. c. You are stating that the 00R Guidelinns and NUR[0-058 l poneric' temperature profiler the in thisword here key ftis, d hose documents also allow a plant specific analysis, Rev.1. h case, a plant specific analysis ensans a p Part 11, comments and resolutions not. 57 and 97.
$taff Asses ment: tative of l 10 the extent that the generic criteria ares reasonably part of the represe the postulated accident environment, this simply becomet of the four unrartainty that is discussed in the staff's assessmenHowever, h in prClemstatement(above). significance of this issue furthe to determine why the generic profiles could not befiles were used.
this relates to the plants where the generic pro d C0 1.tcensees typically do not evaluate thelkambient temperatures temperatul equipment, basing equipment qualification on average bu Instead of local ambient temperatures. A 44 l i
\ _
I I
1
- paar Review caments:
~
- s. 'Probably itrue, but ln most cases this'should be acceptable and 3 normal plant monitorino should identify instances where i significant discrepancies exist. I
- b. EPRI held's workshop on "Honitoring Equipment Environments During Nuclear Plant Operation' in April- 10,11,1990. Many plants l
)
discussed their monitoring methods and many plants continue to add monitoring. it is- 1 I e
- c. Industry resgonsibility more,NRC. oversight may be needed, theindustrysresponsib'ilitytoaccountforsignificant
' deviations'from bulk temperatures where equipment is installed, and more NRC oversight might help assure that this is done. . 4 i d. This is generally true, especially for equipment inside containment; although licensees should (and do) take into consideration local hot spots. In addition, most EQ programs separate the :lants into EQ zones, and qualification is of ten i Zone temperature data based on the sulk temperature in each zone. is used in aging calculationsito determine the calculated Itfe of equipment. Staff Assestment: The concern is two fold: (a) the amount of thermal preconditioning prior to E0 testing may not have been sufficient given the local ambient temperature, and likewise. (b) the peak accident temperature that the equipment was quallfled for may not be sufficient. To the extent that focused attention is placed on operating plant experience and PRA information, equipment performance, condition and environment monitoring, root cause assessment, and trending of information, the aspect of this concern that deals with the adequacy of thermal aging becomes one of minor importance. However, the aspect of this concern that questions the adequacy of the assumed peak accident temperature (as compared to the local ambient temperature) should be addressed by the NRC staff.
- The regulations do not state the acceptance criteria for qualifying 1 equipment based on operating experience.
l Peer Review Cemmentit
~
- a. Probably/true,althoughitisdifficulttodemonstrate ;
qualification of components that will see a harsh environment ; using operating experience since that experience will not j duplicate a I.0CA or HILB, l
- b. This is s' valid point.
- c. To my knowledge, the use of operating expertence to qualify equipment has not been practiced and is frowned upon. Thus. It is l
A-45 i i, I
U. i ~ t
- j iteria for ,l
! probably unnecessary to try to establish acceptance cr ! , l lts use as an EQ method. d. Merits analytical resolution; existing standards h and RGs pl the use of operating experience essentially al ; l that it is rarely a practical' approach. l criterion is-the provision ofdreasonable issues and as i service conditions, including accidents. ! views were also expressed in response to other relate problem statementst f l IEEE'has"1nitiated an effdrt to consider sireparation of a f f standard that will address.the use of opel l l i Hore.ef fort should be directed toward app l l requirements (re: ageconditioning). l The experience of the last-two decades has demonstrai ! difficulty of establishing quallfled life without large uncertainty. One alternative to the requirement for OCA l qualified life is the use of stress testing prior (re: to L testing and enhanced condition monitoring in service state of the art capabilities). Staff Assessment: f [Q over Given the advances that have been made indour PRAunderstanding insights. o . the past 25 years, and based on the TMI-2 experience ani i l to ' . some adjustments The staffinshould the requirements be receptivemay be possible to proposed and benef changes in thi, j the industry. (a) developed as an industry initiative, and (b) l regard that are:
'f amanttrated to be technically justified. l
, ii i Given more realistic assumptions the chemical for theand form of the release, release accidentfractions, the t m ng ! M the releage. en immediate and
)
i mitigation effects resulting from equipment ro6panse.lar l _ Peer Review Connantst
- a. Could be true,
- b. True, i l
4
- c. This is a val 1J issue, /
d. The large radiation dose used in EQ programs in the US d to be overly conservative. . Modern sophisticated electronics are more susceptible to 1 A-46 i l
l radiation doses and thus the use of this equipment is. jeopardized by having everly ConserVallVe radiation requirement $. The alternative to'new equipmentkis . reliance on'old.11ess..ef ficient and less reliable technologyL .
~ ~
- e. -Another source term (Draft NUREG 1465 so'urce ters) has now been ,
approve by ths flRC staff for use in the CE-System 80+ plant ' design. There is no reci91rement'to switch to the new approved contact hYN a an o u the N lens. I n the staff is also in the process of reviewing an additional source > term for'the' AP-600 design.t. Consequently;- there are currently two ' staff approved? source tems available (TIO 14844 and Draft NOREG-1465, source terms) for, use in EQ; and von completion of the NRC staff review'of the source term proposed >y the AP-600 design, there could be a third . Staff Assessment: Given the advances that have been made in our understanding of E0 over I the past 25 years, and based on the THI 2 expertence and PRA insights. ' some adjustments in the requirements may be possible and beneficial to the industry Tim staff should be receptive to proposed changes in this regard that arc. p) developed as an industry initiative, and (b) l demonstrattd to be technically justified.
- A general exemption for radiation ' qualification testing of equipment exposed to low-level radiation may be well suited for .Q purposes under ;
certain defined circumstances. Peer Review Comentsi
- 4. Could be true, 5
- b. I thought thit We'had's gentr'la exemption at 10'-(or 10 ) Rads except for solid state electronics, if not, I agree there should j
be one.
- c. This is not valid. We still'do not understand long-term, low-dose l ef fects,
- d. Merits analytical resolution '(i.e., analyze existing information to reach resolution). This point has been discussed at length by the EQ cowounityl and relevant information exists in the literature. It should be feasible using existing information for the NRC to document its position.
- e. The NRC staff position on this issue is that electronic equipment withinthescopeoftheEQrulsthatwillyeexposed'tototal l
integrated doses of radiation less than 10 rads 10 for other l t equipment) is considered to be in a slid environm(ent. Therefore, environmental qualification in accordance with 10 CFR 50.49 is not required. This position is based on literature searches, comments i A-47
- i
'If-new or additions) data is from industry, and.NRC expeHance.fferent1from this, that data -
available to support ~a position di should be presented to the NRC for review. Staff Attettment: See the staff assessment of the previous problem statsunt. ; i in areas designated as radiation harsh only environments or high e > o itne break (HELB) areas, the conservative assumptions used in l calculating radiation levels make it difficult (if not impossible) to upgrade to the more modern and efficient digital equipM nt. > Paar Review Comaants: can be adversely affected by
- a. Digital equipment (and analog) issue should remain on ensuring safe radiation so the focus of the If licensees can justify a lower operation of such equipment. level of radiation exposure than orig value should be allowed.
U
- b. If this comment'is' directed at the potential radiation environment.:it should be discussed methods?
h sed witht Radiation' Protection Branch. -Ncvartheless, it is known and7, ' that electronic equipment' nt digital acceptedinindustryfthemremodernandefficie(whichinc significant amount is moreosusceptible' to ndlation damage' at lower. , equipment)than.otherequipent.JJfthecurrentmethodsof thresholds calculating the amount of radiation in' a given environment is inaccurate or incorrect. then perhaps n' fresh look it'this However, evidence to support a new situation is warranted. investigation should be presented to the Branch. l l Staff Assettmant: See the staff assessments of the two previous problem statements. It may not be appropriate for theAllowing NRC i t to requi of allcwing Ilcansees to use the new source term initial'y for d scre e applications (such as in [0 radiation harsh environmentsp. some flexibility in applying the new source term would allow license
- to recalculate the exposure levels of some E0 c procedures and celculations relative to E0. source term c ,
requirsments of 10 CTR 50,49. EnarReviewCommantit The focus of ths issue'should remain on ensuring safe ope a. equipment. If Ilconsees can justify a lower level of radiation A 4B
; + .1 ,
4 i exposure than originally determined, this new value should be i allowed. I
- b. This is not valid, You can not have it both ways; you either use the new source term or you do not.
l j It seem as if it is
- c. The intent'of.this comment is not clear.
i being suggested .that the NRCeshould' permit partial use of the old , and partial /use;of the new sourc67 terms for EQpblfsthis~lsIf someone the ! { i case, then'we~would be" creating'a' third' source term Otherwise this be presenteddo3the NRC'for revl6W: and comment. comment seems technically disoriented.- j I Staff Attetsment: i See the staff assessments of the three previous problem statements. l < The cost of qualification testing is a bstrier to the introduction or adaptation of new products into the nuclear industry. Paar Review Commentit a. TM1 demonstrated the need for EQ. While cost is a factor, safety - ) aust be maintained. l
- b. No doubt'about it,
] The current'NRC~research program may ' result in reduction of some j c. requirements, l
- d. I do'notUgrea'.2 Cost <periseUhould.not' be' a basis for modifying EQ requirements.fireducing the costican be justified only by .
- changes thattdo;not comprcmise reasonable assurance
' While ths.stitement: itself suggest a~ course of.act, ton.
- e. Qualificationittstinfis'schs'stry because it provides infonnation It
{ i about equipment-that is' unattainable in any ot3er manne l al).it provides and demonstrates safety. Staff Attattment: Given the advances that have been made in our understanding of [Q over the past 25 years, and based on the THl 2 experience, PRA insights, plant operating experience, some adjustments in the requirements m , possible and beneficial to the industry. (a) developed as an to proposed changes in this regard that are: industry initiative, a 2 Additional technical issues and other considerations that were Identified as " potential issues" related to the [0 methodology include: 1 A-49
j
~ ;
4 General peer Review commanit: . . 3;.: ,
)
a.
'The following Sechnical issues".highilght the^need for the margii that has been built into the process. .
' the effects of hot, humid l
- b. While several of these issues (e, .saks'and inadvertent spray i
conditionst actuationthe effectsnormal during of steamoperation; deformation of cat,la jacket and I during EQ testing, they are not'issuaa'that'can i resolve withinithe context of the requirements or the'EQ rule, i i Rather,Sthestfarenormaloperating; conditions' ? l existed before there were EQ requirements When they and art they would still . j exist even if there were no EQ requirements. resolved for i concern for EQ. c. The following additional technical issues should be added to the list: 1 Fireretardantinsulationandjacketmaterialscontain i halogen. thermal exposure. compounds that are Isleased-duringbirradi ' i between the jacket and~ snsulation,' can enhance the degradation of the insulation.aAfling cables life. l I It has been establishe'd
~
thatLlow dose rate has a greater 1 impact on degradation than hich dose fate.* A dose rate
; valueshouldbeestablishadithatwiWprovideaconservative j estimate of'degradationNThis value would then be used to irradiate materials' to ' simulate? field ' service aging.
! the leakage For the majority of instrumentation cablescurrents h
- currents should be determined for the whole cable system f including splices, penetrations and end connections.
l i Staff Assessment: ) f d l To the extent root that focused attention is placed on cause assessment, and trending of environment monitoring, information, the cable degradation concerns are of minor importance. l With regard to the third concern pertaining to leakage currents, act ! is required by the NRC staff to better understand and resolve this issue. a qualification / certification of testing laboratories: Peer Review Comments: 4 ~ A 50 l
- s py' T h. 6, ~
- a. This was a big issue around the 1983'ttme frame at the EDO level.
It fell through because it was impractical.
- b. I disagree. As one of those l'nvolved in the long and arduous ef fort on this topic during the early 1980s. It is still fresh in my memory, and every one involved agreed that this is not destrable. If it wa: considered then to~be unfeasible economically, and undesirable.technica))y, what.has changed now to warrant its racqnsideration? 'Do we really want to be lulled into a false sense or security provided by this " accreditation" <
)rocess. Even its big proponent, IEEE, which published IEEE-650 l' 1as withdrawn the standard for lack of interest and acceptance by the labs and the ' Industry.
- c. This is a valid issue,
- d. Qualification and'cartification of testing laboratories should be performed using common non-nuclear.tndustry processes and imposing nuclear QA requirements,
- e. I do not' agree.' Considerable effort was expended on this to)1c about ten years ago. It was concluded that, while there migst be some benefits to certification,Jthe level of EQ business was too small for to:Claboratories to absorbrits costs. Since the level of EQ business la much smaller now than it was ten years ago, the prospect of implementing a certification program now appears to be negilgible. !
l
- f. Examples should be cited when statements such as this are made. l Staff Assessment:
The staff agrees with the view (stated above) that qualification and certification of testing laboratories should be established using common non-nuclear industry processes and imposing nuclear QA requirements. While it is the responsibility of the industry to ensure that testing laboratories are adequately quallfled to perform EQ testing, the NRC i staff should assure that qualification testing is being properly and I consistently performed through development and implementation of ongoing EQ audit and inspection activities.
. determination and resolution of worst-case electrical conditions; l
i Peer Ra' view' Conr6ents a. Ydifa#e'4770Tth(best 'of" knowl'ad' ',1to the extant practical, suchcondit' Tons'havebeenin uded th Me'gualification programs. 1 It is true there'have been a few. lapses.. This is an education
~
l 1 problem but not a problem of lack of, or clarity of requirements. EQ was a rapidly evolving technology when much of the work was
- done. Survalliance, maintenance and condition monitoring, if '
properly implemented, should take care of any past lapses. Training and education of engineers involved in specification of EQ requirements should minimize, if not prevent recurrence, r A 51 l
l b. The statement is too non-specific. c. The electrical extremes of most equipment is known and demonstrated during qualification programs. d.
' Industry"riifoliilbility; merits analyt'ica11 resolution. l in A valid concern current'EQ'since worst practice.' case conditions
. Howeverl? this;does not are absolve sometimes the nuc eal industry. frok. identifyino and reso1Ving worst! case i conditions as part of itt responsibill[y to operate requirements plants safely.
can. help assure A tighten ng survalliance' .and maintenance.3 of thatEQ,dequate a attenkton is given to'. worst: case conditions. St a f f As s e s ma.nt: licensees While the staff agrees with the view (stated above)ffthat theIdentifyin are responsible for that were not assels theeinformation calned over the past 25 yearsprop should: (a) pertaining to [Q and worst-case conditions fic and (b) assess concerns exist. l past qualification practices, to determine if any speci The NRC staff should assure that plant-specific EQ conditions audit are prope accounted for through development and implementation of ongoing r f and inspection activities, d I I a resolution of radiation and temperature stratification effects an \ r hydrogen burn scenarios; l peer Review t6anent'at 3 I agreeIthaf:sschTatratificatten.e'ffects< may not'h'aYe' been.
- s. addressed'in the qualification;estabitshment phase.~ Indeed',
could not ,havetbeen becaussithes arefalte and,configurat specific'probless;'that could not developed! Program.lsyAand chasEQFf rootfc.0 y; review of op I f ailure'.experlence, familiar,With',some.. instances:of such conditions I effectively.) L am l havingbeenjidentifiedandcorrectedthroughvig it merits
- conclude that valid as this may be as an EQ issue l research attention only to periodically review failures causes and notify licensees. performed through the existin My recolledticiFis,that the EPRI test program perforned d mid-Ig80s,!did/show4thathydrogen* burn'isnotastgnificant s concern for harsh' environment quallflad equipment, ,
f l I l b'. ' ' This 1s nValid:Iss'ue. How will you address
~
- c. Theyprobablydo'(atleasthydrogenburn).
hydrogen burns 7 s l l A-52 ) i l - _ - _ _ _ _ _ - _ - _ _ _ - _ _ _ _ _ _ _ _ - . _ _ _ _ _ _ _ _
1 wasdonebpIPRllin'the;1980'stoestabitsh - l d. H drogen burn testint at the impact on o herwise harsh quallfled equipme l 4 insignificant. . 7he i
- e. Indutty raponsibility; merits analytical resolution. Industr
! stratificationeffectsinpartbymonitoringenvironmental , i conditions in appropriate parts of the plants. ! The NRC conducted It.isan extensive not clear whether theinvei.tigation concern of hyd j is due .tollack"of knowledge of the:NRC's' resolution orIf existing informa j disagreement with the resolution. topic is~ inadequate or not adequ , lt t:(e corrective action.
- f. Hydrogen burn scenarios are outside the scope of the EQ rule.
Temperature and radiation stratification that result from a design basis accident are within the scope of the E0 rule, and equipment i within the scope of the rule should be qualif ted to withstand l these conditions. i Eli fD uessment: , The NRC staff should assess tne information gained over the past 25 years pertatning to E0, hydrogen burn, and stratification effects, and determine if a significant safety problem exists. l
- resolution of MSLB vs. LOCA environmental conditions; i
l Peer Review Commentst l l
- a. This il not'an issue.
l
- b. I don't appreciate the HSLB vs..LOCA" consideration ~because E0 l testing usesionveloping techniques to establish worst caseWhen requirements.
HSLB and LOCA conditions, both profiles are enveloped by one test, which is inherently more severe than either one alone.
- c. The issue li'not clear.
l Slid Assessment: i This concern was identified by the staff because HSLB conditions (which l could be more severe than LOCA conditions) were not recognized
>ractice of during i
initial qualification efforts, further, the subsequent sulk LOCA l comparing the MSLB equipment surface temperature to the Action by i temperature as a basis for HSLB qualification was questioned. j the NRC staff is necessary to determine, based on the past qualification practices, whether this concern represents a signtficant safety probism, and whether additional measures are warranted. l A 53
I , l'
' k u
..; % 9n'+v;,
. ) ?5; .
- sg i
\ l x; 3 . .,;. . \ \ e self henting effects of cablest ! Peer Raview Coments: This has been addressed by assuming if a cable opera a, Itemperature disagree. is at rated conditions or very close therste, anything,to it needs be given the dorating ofJcenle:1n .
- b. 'I This is a 'validilasus, '
idered.
- c. ' ; SelfLh'eRi6fe'ffe'ets' in cables: has/beenltypically cons l This nomalltwoulds-effect only. power.;{ cable r 5
i l
,0 Cable qualificifiedractids"do account!for'the
- d. Iself doheating not TgW'effict of cabia energlittlonitin fact.;the industry. ,
claims that this was'done'too conservatinlylin some [Q pr I 4 ' ^ i Staff Assessment: i l
- Dased onseen theconsidered leer review comments (above),
Also, at least to some degree. plant expericace to the it appears th > l effects ti mer,t extenthave that focused attention is placed on opera ng i ation, this i f i monitoring, root cause assessment, and trendin issue becomes one of minor importance. ay, difficulties in simulating accident' conditions (e.g., containme ; humidity,etc.); J l Peer Ravlaw Comentit i i a, ~ This is not a valid issue. ! b. 9,ro ai er)i.'equfppsd commercialhb's/atsel~es ha
*diatng?eccidentecondttiens/ ,
.+ s, ,
a
- c. ' The 'lssuiTs~fn60 cle'ar, I i
Staff Attattmant: ditions There may be some variations and uncertainties h ld be minimal in the actual that are established in the EQ test chamber, lytical but these s ouRecog if the chamber is properly instrumented.
, postulated accider,t conditier.i were determined ern seems to through ana methods that also contained inherent uncertainties, t ies will the concH be of little significance.
an ongoing audit and inspectlen program for EQ testing lab help to address this issue. certification of E0 testing laboratories (a
'
- the effects of hot, humid conditionti 8*54 l
Paar Review ramentti a, ~1 agreef. humidity to cannot be accelerated,w spectficalocationsiin some Heat plants'. . In' combination w Generic hus'dity may appl i programs such as Q cannot address this effectively.'-But properly , analysis programs can be effective.- Additiona).re satisfactorily address thisi
- b. This is not' a valid issue, '
l
- c. The long term exposure of materials.to heat and humidity, if not .
identified as part of the. assumed ez i differences in performance,J Iomel(environment '
'wlli i
identify the environment properly and~research sim analyn existing information
- d. Merits analytical resolution (l.a., lid concern in accounting for l This is a va l to reach resolution).because there is no practical method nf aging degradation,ity effects that can be correlated to a l acceletaling humidHowever, there are humidity stress tests that can qualified life.at least provide some Indication of the endurance of equipm Humidity stress testing has been under humid conditions. 1 incorporated.into at least one -standard, IEEE $(d 650 for battery
' chargers and inverters. staff Attettment: U.' (_- i To the extent thst focused attention is placed on operating plant ' experience and PRA information, equipment performance, condition and l environment nonitoring, root cause assessment, and trending ofHowever, given information. this issue becomes one of minor importance. the advances that have been made in our understanding of EQ over the' past 25 years, and based on the THI 2 experience and PRA insights, so adjustments Industry. in the requirements may be possible and b ; l regard that are (a) developed as an industry inillative, and (b) l demonstratedtobetechnicallyjustified,
- the effects of steam leaks and inadvertent spray actuations during l normal operation; Peer Review Cnmmental Dut it is one where only
- a. I agree, this is a valid concern.the. plant can guide the d,etermination experience vulnerability>in!E !t may applyito', specific locations in some plants.
Dut, Generic programs'such as EQ cannot address this effectively. properly impimnted surveillance, inspection, maintenance, and Additional 4 rout cause analysis programs"can be effective. research cannot satisfactorily address this. A-55 l
~~_
e I t vi * , b, This is a valid issuel what abold(operajing.expertence towaddre this? c. Equipment qualified to harsh environments should not expe problems when exposed to steam leaks and inadverte actuations. the issue is resolved, This is a d, Indestry responsibilityt Where expertencemerits analytical predicts thatresolution. certain equipment valid concern, in certain~ locations is expected to be subject to $ team leak inadvertent spray actuations,' the EQ p ogram should incorporat testing (such as humidity stress testsin to anticipated the simulate EQ l these service condittons. Where such events were no program..the existing program should be supplemented by testing or enhanced condition monitoring to as required during a DBA, Staff Assettment; y d j Thestaffagreeswiththeview(statidabove)thatpro Therefore, to the extent d PRA l can be effective in addressing this problem, ' that focused attention is placed on operating plant experience a this environment an information, equipment performance, condition i and ire on, monitoring, root cause assessment, and trending of informat issue becomes one of minor importance, -;
+
deformation of cable jacket and insulation at high stressl pointst Peer Review rammantal I disagree. I recall that some work was done by Sandla and TVA to a. answer this concern.. concern generically. Still,, thk concern That should will remain because- be sufficient to a ll , generic programs But, proprlysuch implementedas EQ.cannot surveillance, address s this comple inspection, variations. f tive. ld maintenance, and root cause' analysis p program, fully. I b. This is a valid concernt what'~about operating experience to l i address this issue? ~ c. Sandia did perfors some testsOlven of cables standard cable hungt over sharp ut cut through did not occur. concluded t pulling practices and cable routing practices, sharp edge Ilkely a rare event and not considered a common mode failure d. Industry responsibility best resolved by the industry. Staf f Attesment: A 56
.g. .
See the staff assessment ret the effects of steam lesks (abov
+ dust effects; Paar Review Cements:
a.?TI agree.'#6thedc N programs suchiat:EQ cannot address.this effectively,P 8ut properly implemented surveillance, inspection, maintenance; and' root cause analysis programs can be effective. Addittenti resear.ch.cannot; satisfactorily. address this, b.
' This isL av ' alidlissuspwntfabiu't opN& ting experience to address this 1:4V87 c.
> Hist ~ harsh *$ilillfJWitimf Erdualified' assuming' exposure to sprays a inteamier,.otherwise?are protected by seals and sealants Wich: ave documented: effectiveness in.their ow tests. . hus~ d0 t? particles, which are assumed to be larger, wouldhavellttleeffectn' Additionally,mostI.0CAsimulation chambers would 'contain' considerable contamination as sprays are recirculated, thus' simulating dust and other centaminatton conditions, d.' Industry. responsibility; best resolved by the industry.
Staff Attattman_t See the staff assessment ret the effects of steam leaks (above).
+ long-term exposure to moisture Paar Review Cn== ants:
a.J. This may'be~ the'mostl significanticoncern. this b.WI agreet@Ge6eVliiTp7opan's/sichfis1EQ'cannut' f maintenance /'and~ root ccustianalysit; programs can be effective. Additionalitetetrchrc6nnot'satisfactorliy address this, cMThis'isft'ValidMaust what aboutiocerating experience to address this' concern? The
- d. W!ndustrPrjiponsibilityt merits. analytical reso!utio other related<lssues and problem statements: '
- Whereeip'eriencepredicts'thatequipmentincertain locations is expected to be subject to steam leaks and inadvertent spray actuations, the EQ program should incorporate testing (such as humidity stress tests) to simulate these service conditions. Where such events were not anticipated in the EQ program, the existing program
- A57; s
^ " ' " - - - - - - - - - - . _ . _ _
-~ _
should be supplemented by sdditional testing or enhanced ~ conditionmonitoringtoassurethat'iequipmentisrefurbished~ ' or replaced when it is no longer?tb e to'operata 'as requir I duringaDBA(re: the effects of steam len(s). l' Humidity represents a valid concern in' accounting for aging degradatlan, because there is:no practica) method of accelerating humidity effects'that"can be correlated to a qualified life, that can at least provide.some' indication of the endurance
~
of equipment under1andinverters(re: humid conditionsip the Humidity , IEEE Std 650 for battery charger: . effectsofhot,humidconditions). l Etaf f Attesment: i 1; focused attention on operating plant experience itoring, root cause and PRA informat on, equipment and performance, trending ofcondition and environment information, will help to mon address d onthis assessment,However, NRC staff action is necessary to determine, st 25 Dase h concern. the additional information that has been obtained over t e pa i ificant j years, whether long-term exposure to moisture d represents a s gn ) safety problem and whether additional measures fighting are warrante . l tings andfire the impact of fire scenarios, protective features, and king i activities, including (for example) smoke, fire retarda I flammable gas lines; ; l l Peer Review Commenti: . l I agree, this is probably n/ valid' concern'and may not have be f a. ' fully addressed in existing qualifications'." Ahistudy t of the l I expected effects, the methods for factoring ! may exist in current' aging programs it' appropriate. b. This is a valid issue; needs to be addressed. l Industry responsibility; merits 'analytica1' resolution. l c. 1.taf f Assesserent: f fire l t safety
- Action is required by the NRC staff to assess the imp problem and whether additional measures are requirtd, i
+
the consequences of combustible gas and chlorine formation; i Peer Review Commenti: f i a, I disagree, this is plant design and physical f acility l ! A 58 4
i 1Mg.<.ec . - l
. 2sf~i.QQsg,,
l , 1 m \ It'thould. net bc treated 41 an CQ configuration control issue. , 4 l Issue. l b, this is a valid concern; needs to be addressed. - } 1 Staf f Assetimentf 1 Action is required by the NRC staff to assess the consequences of l combustible gas and chlorine formation and to determine if this l represents a significant safety problem and whether additional measures l j are required.
=
interface effects between components that are tested separately; ' Peer Raview Commentst f .
- 4. I agreet with~ tome exceptions,itWheti pro! rams c be note ( that they have been addressed in the context of the overall qualification of the equiment-item to assure that the i
! safety functional capability'of tit equipment in harsh ! environments are not compromised.; We may argue about the j acceptability of some of the evaluation practices employed.. ! Darring a detailed evaluation of the various configurations of , interfaces, and determining sn acceptable mothed for eachw l configuration (cf. course
- be impractical to determine wheWar or not *nere is an EQ iss.le t'
- here that could'potentially cS tieng d.st has been l
i design installation, maintenance and testing aspects o classes of equipment ! costeffective,'Indkvidua evaluations'on a case basis. particularly based on failure experience review (whic e
/
l I f effective. '
- b. This 13 a valid concern; needs'.t'o,be addressed.
c. Interf aces of equipment are qdalifted along with the equipment. ! The test laboratories have to interface to the equipment inside l chambers'and thus this knowledge was passed a l l
- d. Industry responsibility; more' NRC* oversight may be needed. :
f t l Staff Assessment: l The staff agrees with the view (stated above) that licensees are l f responsible qualifted. to ensure that equipment interfaces are ade informatton, equipment performance, conditlon.and environment ll monitoring, root cause assessment, and trending of information help to address this concern. l A-59
, ,. i btained -
det errine, based on the addit tonal information f problems that has been o over the i.ast 25 years, whetner specific touipment inter ace ' have been identified that thould de addressed, o EQ boundary restrictions (e.g., the compensato t during ; excessive when compared with the , 4 probabilit'y e of;a.LOCA/HELB even a maintenance evolution);
.j.
Peer Review Commentit ~ u a. I agree, this is~ a valid concern i
~It should be but it'iinotthrough addressed ene that could b '
resolved by additional research. plant configuration control programs. b. This is a valid issue; needs to be addressed. ,
- c. The issue is not' clear.
d. Engineering judgement and common, sense should resolve Staff Attetiggg : E0 Lteensees occastonally find is desirable to remove or disable hnundaries (e.g., flood walls, concrete plugs, etc.) in order toHowever, removine~ 'th ' fact 11 tate maintenance settvities. cause otherwise operable safety-related equipmentllfled to be exposed to harsh-environment conditions that this equipment has not been quaTh , for untti best addressed the barrierby is reestablished. industry, and the(a)NRC staffas should be receptiv developed an proposed resolutions of this problem that are: industry initia ) EQ scheduling constraints on performing periodic maintenance i alified (i.e., !
+ _]
components are considered to be inoperable at th ,. manyassumptionsandconservatisms)... l I Peer Review Commenti- l
- a. TagreefMThis: concern arises because of our treatment of l j
qualifieOlife as cast-in concrete number,,despite all of its l l uncertainties.' :This concern will be moot if we can agree tha l l given the nature' Asofan the uncertainties behinl interis solution, the NRC id
'an absolute do-or-die number. l might consider allowing the utilities to use the 25% grace pe ;
that is now a110wed for Tech. Spec, surveillance, f 1 maintenance also.
- b. This is a non-EQ issue, c.
Great care should be taken in considering the granting of A 60; ,, I __m__. . ._._----- - _ _ _ _ _ - . _ _ _ _ _ _ _ _ _ _ _ . _
.o <
n ., ,,
' flexibility for end of life determinations. The reason ,
assumptions and conservatisms are used is to deal with a enmplex process for determining and of life. .These assump ; they are removed or altered.. w;
.rn
- .c led"11fe Ts-st best anIs.- >
- d. Meri ts anal'yt ica17re solution.TQia1 { {festimate' of the '
l reasonably ' assured.HThe_ uncertaintihD.in qualif. led life determinations are not~ consisteht%ith.considering equipment l inoperable 'at th6' end of qualified life.i There is now a need to l evalukte' alternatives to .the;qualif. led life. requirement. Operating experience and enhanced. condition. monitoring are among the alternatives that should be' considered.: The foll l issues and problem statements: Helther accelerated aging nor aging analyses are very reliable as methods of estimating qualified life. . !' Basically, it is not feasible to account for aging in aRegula technically rigorous way. rule out any excesses in the aging component of gnalification, taking into account the limitations of the process (re: reliance on analytical aging calculations). l The experience of the lastualified two decades.has demonstrated the 1.ife' without large difficulty of establishing . uncert ainty.- 40ne ;al ternag. elt)fthelrequirementi 5* ' for ' .stres'ih
' l'" ~
l 1 qualifiedilifelistthelusetesting and' enhanced condition' moni't l stateof'th'eartcapabillties)'.',
~
~
- e. Indus try' res'ponsibil ity;ibe s tif561ved' by the indus t ry.
l ! f. At the end of'qdalified life'EQ components are/or should beTherefore, it l ' capable of withstanding a.destgrt', basis accident. If a may appear to be capable of~.proVidingtadditional service. l j l plant wants,to c6ntinue to'useja; component,? of.oroviding additional servicehin addition to being capable of wit 1 standing'a design basis accident. The method ete is developed, it is the best available. Staff Assessment: The staff agrees with the view (stated above) that this problem is best addressed by industry, and the NRC staff should be receptive (a) developed to a as an- j proposed resolution of this problem that is: industry initiative,
- the accuracy of test instrumentation;
'A-61 !
--. _ _ _ -+ -. , ,_g
. . r. . ,
. 'y%'
,. ^
Peer Review Comments: a, This has been sufficiently dealtSith through industry review and NRC, audits.ifItistruethat.anioccasionallapsehe W must1 recognize that'in any human in the future itasiswell. endeavor, impractical to eliminate such lapses. especially , The when it involves exacting attention to numerous details. answer lies in our QA/QC systems, not additional research.
- b. .This is not an EQ issue; this is'QA.
c. Industry responsibility; I am nit ' aware of any deficiency If in the requirements.for testkinstrumentiaccuracy and1 calibration. there is any' deficiency with: compliance,1 ft%Is primarily the-industry'siresponsibility to correct?the situation'. Staff Assessment: Based on the staff's review Instrument under accuracyEO-TAP Action item 3 was specifically ' not appear to be a valid concern. reviewed by the staff during the on-site performed at each plant. l
- documentation requirements; and Peer-Review Commenti:
No further work.sh'ould be required onithis. The standards and N
- a. .
This'is an education l regtiirements .are sufficiently . clear. problem, not a research issue. b. This is not an' issue; esfablish~ed by IEEE Standards. c. The concern is'not' clear;t
~
t he"ssiecific' documentation problem (s) should be identified. ften
- d. . Based on my expeilencesin reJf.eidnglEQ documentation, I.o wished for more' relevant 'information;-
e. Documentation' is required One of bythe the' Codepurposes primary of federal for Regulations l (i .ei, .10 CFR 50','49 .(J)) . l
. documentation istto insure quality.and f traceability of comp m nts. ;
Changing, the? Code l,offederal' Regulations requires rule making The NRC has no basis nor inclination'to. pursue such a change. Staff Assessment: A certain level of documentation must be . maintained The staff's , to demonstrate that qualification does in fact exist. revie ! documentation requirements were imposed. Thebut staffperhaps should beit could be that the requirements are too strict and unfounded. A-62
(a) receptive to proposed changes in the-requirements that a , technically justified. . other considerations relative to E0. such as mechanical an vibration, seismic effects, dynamic ef,fects, etc. _ Peer Review Conynents: I disagree. These are not within the scope of environmental
- a. They should be' addressed separately.
qualification.
- b. This is a valid issue. l
- c. The issue is not clear.
Staff Assessment: The resolution of other issues that were handled separately from E0 but that could have a degrading influence on equipment dynamic effects, etc., should be reviewed to assure that E0 has not be compromised by the resolution of these other issues. The following problem statements expand on certain aspects of this issue: Continuous submergence prior to harsh exposure has not been addr(.*ed Peer Review Comments: a. 1 am not aware of any areas ihere EQ equipment is normally submerged. If it's part of. the norn.d environment,
- b. Need it be addressed? But does it really \apsn for electrical aging should address it.
equipment?
- c. This is a valid issue.
The NRC staff.positim % 'gence is straight forward and
- d. is submerged during norraal clear. If'triite,.'. w.i. 6 operation and/or durfos accident conditions, The thenstaff that item shou be' tested for,EQ purposes in the submerged To date, condi extent aracticable.4representathe.. installed conditions.
no' one 1astp're'serited'an'acceptableialternative to the NRC staff position o'n.fs'ubmergence Staff Assessment: Focused attention on operating plant experience and PRA information, equipment performance, condition and environmen A-63
4 s However. NRC staff action is necessary toi lly for plants to address thisto determine concern. what extent this is a valid concern; espec alines and that came under the EQ criteria of the.00R Guide Category II. i l peak The momentary electrical effects of the postulated init a ddressed. temperature and radiation stresses have not been a Peer Review Comme'nti: gg j Why not? Test' specimens sh5uldThaN bee'n energized a
- a. the event's simulation so why.is Jhis an, issue?
b. This is not a valid issue; this'Js checked during LOCA.
- c. The issue is not clear.
This coment needs clarification. d.
}1aff Assessment: be a valid i that has ,
Based on the peer review coments, this doas not a l trical i concern. been gained over the past 25 years relative to E0 and e ecarios to phenomena that are likely to occur during event sr.enddress this con whether further action is warranted to a h LOCA bulk Comparison of the calculated MSLB surface temperature to t l temperature may not assure that the equipment wil , I environment. '., Peer Review Coments:
- a. I am not aware of this issue.
- b. Needs to be considered. Although ffects,
- c. Industry responsibility; . merits analytical re additlonal~ guidance >from.the. NRC.would be helpful.
i nts of 10 CFR
' Equipment qualified in accordance with the requ reme tirin of
- d. 50.49 will"l withstand the worst-case design basis accid conditions.# 0ften'.the worst case conditions i for a are a co LOCA and MSLB! scenarios.
conditions and a' HSLB will likely produce k LOCA harsh- co longer period of' time. composite profile for testing. purpos conditions'with the duratian ofca MSLB. equipm Staff Assessment: l and The concern is that the bulk LOCA temperature is an avera A-64 L
M J - 1. P Mg~ .; j* .;. [ t J. ) . temperatures near specific components may be more or less than
~
value, depending on plant-specific conditions such(a)
~
as qualification temperature , stratification effects. So. the concern ls two-fold: ! of equipment for LOCA conditions based strictly on the containmen LOCA temperature may not be sufficient, and (b) use of the bulk LOC , temperature as a basis for qualification of equipment for MSLB conditions may not be sufficient. ' Action by the NRC staff isif.ecessary d ' to determine, based on the additional information that has been obta ne over the past 25 years and based on past qualification practices, whether the temperatures that were required for LOCA and MSLB , qualification were appropriate and whether additional measures are warranted.
- Environmental conditions'for accidents otherThe thanstaff for LOCA (sl for HSLB) were not defined for at?1 east 65 power reacto '
item A-21. Peer Review Comments: a. In the early '80s, HRR formed an EQ Branch to resolve issues su as this one.wThe,ContainmentVSystuns Branch provided input of containmentotemperatureip'rofjlesfofgboth MSLB and LOCA to ths Branch. Thetissue sh'ould have'been resolved more than ten years ago by the EQ. Branch,>but thevresolution may not have been characterized; properly.by RES. recognized-and/ orc
- b. I am not aware of this issue, c.
Based on a:value/ impact assessment, the NRC However staff concluded that Task Action Plan Iter A-21 has~a. low priority ranking. the accidentianalyses~ for plants do consider a MSLB accident, a licensees"deYelo'p brissure and; temperature profiles based on thos
~
considerations.NEQ test profiles are subsequently developed from those accident analyses, Staff Assessment-See the staff assessment for the previous problem statement. i The staff's " final position" regarding the velocity profile in containment during blowdown was pending completion of Task A-21. e However, the staff's resolution of' Task A-21 was incomplete (see the previous problem statement) and this issue may need to be revisi Peer Review Comments: ,
- a. A " final position".on this issue is not apparent, but there is no e need for such a generic resolution .needed in very few case detailed analysis should be performed. '
- b. I am not aware of this is' sue.
l A-65
Staff Assessment: ~ (a) resolution"of the " velocity proflie" is The concern is two-fold: aspect of TAP A-21 may not be appropriate if the velocity profile dependent on the resolution of MSLB vs. LOCA conditions ts a (see the previous problem statement), and (b)-the " velocity proflie" represen dynamic effect that may not have been Action'is adequately required by the addressed in EQ (see the last bullet under B.2, above)..' NRC staff to address this concern, i i - For plants qualified under the DOR Guidelines and up to the mid-19 . vendor specifications for E0 equipment contained few under harsh conditions. 1 Peer Review Coments: Is there a problem? Separ6 ting the shortcomings of the 00R a. approach, each cable qualification test demons environment,
- b. Given the;charige: rate of equ_lpment/ cables, performaniinventoryoflthematepla) sin.the. plant.
c. Industryfesponsibt.11ty;1morDRCISverfight%afbe neededa It is the industry's; responsibility?tohevifylthatithe qualification documentation provides: reasonable 4 original If.the assurance:that. cable safety functions can'se' performed asireg'utredl: qualificationnistfound:.to beidsfjcienti 4dditional testing More or other approachassto assuringeop'erability this rega'rd. may'be n
~
qualificatio.n programs are adequate it! f~ d. This may beitrue, however
~
in accordance'with 10 CFR 50.49 (k)
" Applicants Tor'and holders of. operati,ng' li with the provi'sions of thisisect' ion ifvthe Comission has previously# required qualification of the equipment in accordan with " Guidelines for Evaluating tEnvironmental Qualification of Class IE' Electrical Equipmentdn operating Re ,
"Interth. Staff c Positlon on Environmental -Qualification Related' Electrical Equipment'.'Allowever, repla 50.49. . t
_St af f Assesstnent: The performance requirements of equipment are determined by However, vendor l of accident analyses, not vendor specifications. specifi A-66
I I g F [- j; ire suited for their specific assurance that installed equipmenTherefore,thestafff,agreeswiththeview(state applications. that it is the licensee *s respons,bjltytoensurethatthe i t qualification documentation providei reasonable assurance that equ pme safety functions will be performed jiven plant-specific considerations. oup guidelines do not recognize the
- The Seismic Qualification Utilit t.during a design basis event (DBE), .
performance requirements of equi suitsifrom a 0BE. .More specific only the damage to equipment:tha nay be needed. seismic qualification requiremen
,,r . .
c Peer Review Comments: n..
. n I disagree. In the areaT f[elay performance (contact a.
chatter / bounce), SQUG does consider equipment performance duri
.c the event.
Merits analytical resolut)
~
IThisissuemerits'studybecauseof
- b. ng the applicability of earthquake the lack of consensus cone.e cat.lon. Lack of damage during an damagedatatoseismicqua))
earthquake does not, per'se' assure operability during an' ems that ear earthquake. Therefore, i' 'some testing (less than a complete : supplemanted with analysi. fadequate technical basis for seismic i seismic tsst) to provide"anThe concitisfpns of such a study should not be l qualification.inconsistant with ' ent what whered Tacceptable testing is notprocedures feasible. for seismic l qualification of large;ett . hismic qualifi~catio~ndi , Jiht.n theiscope: of;the EQ' rule. c.
~
Staff Assessment: [ st' bullet under B.2, above. see the staff assessment of.th erfrequency conditions (i.e., The limiting undervoltage and postulated electrical conditionff may or seismic as compared not have been assumed forto other l hostile environmental conditio . ally for plants subject to the 00R establishing qualification,.e_s .- m Guidelines. m 3., Peer Review Comme'ntsi e,
- a. I am not aware of this>i Seismic ti not included 310'CFR 50.49 and was not addressed in
- b. ; reactor EQ inspections.
the (NRC staff's) operat ly" clear. If the limiting undervoltage
- c. Thisstatementis~not?e'x ns; result from a seismic event, then and underfrequency'cond qualification' for thes'e" ditions should be covered under.the seismic qualification'c ria'(i.e., Section 3.10 of the standard review plan). The DOR . elines does not cover seismic qualification. .
o s s 67 a
[G y Staff Assessment: ( See the staf f assessment of the last. bullet under. B.2, above. Nf?f4l[ , . Sumary Based on the staff's review of EQ methodology issues, the following recommendations were made:
- a. In order toaualification, to equipment account for the numerous to provide assurance i thatof uncertainties may continued th of qualification over time, and to identify any EQ deficienc t es exist, the NRC staff shot,1d assure that 11ceas d _
condition and ewrironment monitoring, root cause assessment, anTo faci l equipment trending of information on an ongoing basis.the staff should within the scope of the maintenance-rule -;r h b. The NRC staff should review the results of past EQ and ongoing EQ re ef forts, qualification test results and practices, and other information, and maintain an up-to-date data base contai 7 information infcrmation in order and to: advances in technology; (b) . identify d basisspecific issue that may deserve additional research and resolution; (c) provi e a for resolving EQ concerns; and (d) better focus NRC staff and in For example, this data base should be used di as an initial resources. step in addressing the specific EQ issues listed in f, g, h, an (below). d if:
- c. Any further EQ research by the NRC staff should i (b)only be perform (a) it is based on a well defined need for specific ill be informat on, ;
there is a good likelihood that the desired information w obtained, and (c) the cost of the proposed res lly Certification of EQ testing laboratories in.accordance with genera is needed l
- d. d Also, accepted non-nuclear practices along EQ testing with nuclel l the NRC staff should periodically monitor the pe !
inspection activities. l f e. The NRC staff should assure that plant-specific d conditions are p h accounted for by licensee EQ programs through development an implementation of ongoing EQ audit and inspection activitiesl issuance of generic communications when appropriate. The use of " excess margin" to justify short-duration i d to assure LOCA tests f. were allowed for the 00R Guidelines plants should be rev ewe i that a significant safety problem does not exist. , f g. Further review is needed to determine why the generic temperature ; l l A-68 , I
~
- a. .w.m profilesforPWRsandBWRswerenotfullyfjustifiedandhuwthisrelates, to those situations where the generic temperature profiles were used.
h. Further review is needed to assure that the'* velocity profile" aspect of TAP A-21 was adequately addressed.: F.irst..the, staff's resolution may not have been entirely appropriate if'resoliition'of the " velocity-profile" is dependent on the resolution of HSLB qualification for 00R Guidelines plants (since the M5LB qualification issue was not fully I addressed); and second, the " velocity proflie" represents a dynamic effect that may not have been addressed in term of'EQ (see J. below). 3 1. Further review is needed to better understand and more fully address the following concerns relative to E0: a leakage currents and momentary electrical effects; i
- hydrogen burn scenarios, e
radiation and temperature stratification effects; 1 I
- long-term exposure to moisture;
- continuous submergence prior to the LOCA; l
a the effects of . fire on E0; ,
- combustible gas and chlorine formation effects; i l l
+ use of bulk vs. local temperatures; adequacy of MSLB qualification for 00R Cuidelines plants; and
- equipment interface problems.
I j. The resolution of other issues that were handled separately from E0 but that could have an effect on equipment qualification, such as the issues of mechanical and flow induced vibration, seismic effects, dynamic 1 effects, etc., should be reviewed to assure that EQ has not been compromised by resolution of these other issues,
- k. A large number of the concerns suggested that by using the additional information that has been obtained over the past 25 years effectively, and based on the THI-2 experience and PRA insights, some adjustments This in the E0 methodology may be possible and beneficial to the industry.
is especially true recognizing-that more emphasis is needed on maintaining equipment qualification over time and some " trade-off" may l I be appropriate. The NRC staff should be receptive to proposed changes (a) developed as an and improvements in the E0 methodology that are: industry initiati for example, the following elements of the qualification methodology were cited as potential candidates for improvement:
- use of analysis and operating experience versus test data; l
l A-69 i
A Mi n;.3 , aL. h'.., l amount of preconditioning required and possible use of stress testing as an alternative to this requirement;
- test margin requirements;
- post-accident operating time requirements; a
mandrei bend test requirements;,
- u. !
~ '
treatment of synergistic', effects., dose rate effects. and oxygen - diffusion effects; -
.gf.
. double peak requirementi -
radiation testing and' source term considerations; EQ boundary restrictions that make it difficult if not impossible to perform maintenance and rep 1.acement activities; schedular constraints for performing maintenance and replacement of E0 equipment (i.e.,:no grace period allowed); and a documentation requirements. l The NRC staff did not consider any of the EQ methodology issues to be immediate safety problems. f A-70
E W% , , , , f J'M w +xW ' :.;.p? -e C. D rrent Status and imolementation of EO Reoufrements I It is difficult to determine what minimum EQ standard was impored on licensees because a clear The record of.isexceptions,that further complicatedwere by allowed by the l. matter I staff is not readily available. the evolving nature of requirements that wereThe being promulgated by IE following Bulletins, Supplements, and ultimately by the EQ rule. j problem statements relate to this issue: I l ! Peer Review Comments- , a. In rev; ewing tho' concern and the following problem statements l presented in support this issue,.I would be remiss if I did not 1
- point out that they reflect a comp 11ation It is by one or the rationale'for why somethings are the way they are. ,
understandable not know the basis for that there is a sensereadily
- a. decision,tand.cannot of frustration find i . when o I
I agree that in lookir.g back, one can come up with a need for more and better documentation of the'basestfor many of the Thisdecisions Is this not true of any. human activity? that were made. , will be all the more true if that activity involves an attempt at l backfitting operating plantspand plants under various stages of to meet requirements based on an evolving construction,I technology. think that we should be able to.say enough is enough and move'on to.the morecir.portant items. If on'e wintFt6' reconstruct events.and basias' for' the many decisions"that were made by the'NRC headquarters' staff and the ! field inspection 1 teams, it can be done w ,It will.be a time consuming project and a costly effort a lt'will require the ' participation of' people from the:NRC'and the industry who w involved in.those days. i them actively involved in-the lndustry or'in the NRC, although , i they may not' be 'in the same -technical areas. - b. There has been clarification.but there are no exceptions to the !' j 00R Guidelines. 'IE Bulletins and their Supplements require responses.to" specific issues. ,Therefore, if one has all the Bulletins and:their Supplements, ~there'should not be any confusion ) as to the. requirements of the Bulletin. However,. if any such l confusion exists',' the NRC? staff is available to discuss specific
' issues.
Staff Commenti: " Based on the staf f's review under EQ-TAP Action Itein 3.e [10), it appears that the requirements and implementation Resolution of theof EQ requirements w more consistently established and well assured. trivial, administrativ staff review and inspection process was accomplishedGiven through the meetings that were conducted between the NRC staff and each licensee. , e A-71
% == m .. . . , -
f this process, only
- in the meeting very large number of deficiencies The less significant items wtre ie: .. ,Jd byficant that the EQ licablewhi typical at app minutes. ff's the viewless that signi licensee as needing to be corrected. .Whilef deficiencies may not have been documented. r fit'is the staf EQ requireme this does not represent a significant comp,omise o ff Itisnotcleartowhatextentthevarihu'sSlarificationsandsta11ett,s, re A;
positions that were stated in Generic Letters. !E'Bu of NUREG-0737, etc., were fully implemented,dand to by which ones a currently applicable since they are not specifically referre ? 10 CFR 50.49. Peer Review Commenti:
~
- a. I agree, ;
It seems reasonable to expect the .
- b. . Herits analytical resolution.
NRC to clear this up. All clarifications, staff positions, Generic Letters, td IE
- c. h
' Bulletins, and Appendix B of NUREG-0737 w document in question. itaff Asseytg at: h t was ! Based on the staff's review - under~EQ-TAP was prettyAction - ltem 3.e [10I required to be implemented in the'way of EQ requirements Letters and BulletinsHowever, clear. are given stilltheapplicable rapid ot have unle superseded by more recent requirements. l development and transition of EQ requirements, superseded" and there may
.Therefore, she NRC staff thebestaff r , n !
'been entirely clear as to what was being " int determine some confusion in the industry on this poshould pursue t is necessary.
- whether clarification of the existing requirements d Emergency shutdown systems "...used lt intoa breach id bririg the plant t shutdown condition following accidents which do not d to be resu of the reactor coolant pressure boundary toget it is not clear, Also, since qualified by plants subject to the 00R Guidelines, howeve.r. thAt this was the case for NUREG-0588 is currently plants. ired oy the E qualification of cold shutdown equipment was not r I
valid. Peer Review Comments: a, I am not aware of this issue.
- b. Plant-specific design bases,. I A-72 i
1 - I \
. -#D
- c. Merits analytical resolution! Although this reviewe justify a response. .
l d. Currently,' plants are required to qualify a path to safe shutdown. l Safe shutdown is,not defined the same way for all plants Plants must (i.e., some plants: define safe shutdown as hot shutdown). l qualify a path to cold shutdown only if their license defines l shutdown as " cold shutdown." (i.e... DOR Guidelines, NUREG-0588 Categories I and II). I Staff Assetsment: See the staff assessment of the previous problem statement. Evidently, the NRC staff considered certain parts of that were found to be acceptable to the staff are no and consistent in all cases. Peer Review Comments:
- a. Iamnotawareofthislissue, It seems reasonable to expect the
- b. Merits analytical' resolution,-
NRC to clear.uptthis issue, ' However, there may be
- c. None of the requirements were optional. There was optional ways to: comply.with a particular The requiremen without approval by the NRC Comissioners themselves.
intentional; differences"in the NRC. staff policy are those that places plantsLintotthe three categories to be reviewed under the 00R Guidelines,'NUREG-0588 category II and NUREG-0588 categor Nevertheless, NRC~{nspectors may differ somewhat in their determination of.what;is acceptable to meet a particular requiremento 'However vthese differences shoul way we.sse ,thL.;s,<or'there may be some differen inspector, Staff Assessment: Based on the staff's reviewThe underprocess EQ-TAP that wasAction used byitem 3.e (10), this do the staff not appear to be a valid issue. for evaluating licensee compliance While resolution withofEQ requirements many of the less was quite rigorous and well defined. but the process was consistent and involved the sa participants whit.h would tend to minimize inconsistencies. A-73
1 t DuringtheNRC'sE0 inspection'acilYItfesof_themid-1980 \ I and test results, peer Review C m ents: a,d' ' Region 34(temptid',to?fiplemerit*atconsistent
~
This was interpretation of E requirements during thetinspections in: question. accomplished through the use of a common pool of contractors, frequent'discutifons'with NRR on evolving EQ issues and the attendance of all available EQ training opportunities and meetings. It seems reasonable to expect the
- b. Merits analytical resolution.
NRC to clear this up. c. Inconsistencie's'that may exist are not the result of NRC policy; but rather, are unintentiona) errors on the part of the inspector (s). _taff Assessment: S Based on the staff's review under EO-TAP Action item 3.e [10), this doe While some inconsistencies were not appear to be a valid issue. inevitable due to the different knowledge a Regions various NRC inspectors involved, workshops were held with the The NRC and with the licensees to minimize the-extent of this problen. Headquarters Office was also actively involved in training the inspectors, providing guidance, and addressing issues requirements. Crediting EQ tests of commercial or generically named componen have been entirely appropriate when these tests covered various manufacturers, vintages, or designs of cables and interfacing components. peer Review Comenti: ,
- a. I believe that.the generic tests were proven to the results bounded the component in question.
- b. I don't think"that this was'done,
- c. I agree, butEthItstatement is too, mild.
- d. Iagreethat'CQ't'esfsshouldnot'be~extrapolatedtocommercialor The regulations and IEEE 323-1974 generically named components.
require that'the' link ~between the quallfled test specimen and the items in the plant,,: Including manufacturer, model and vintage be If similarity of the test specimen to the plantinstall established. was judged to se not qualified. ! A-74 I g
,- ,, , s..
e. More NRC oversight may be needed; this is a valid concern to the extat that any qualification program does not satisfy qualification requirements concerning the choice of test specimen l and the extrapolation of tests.to similar components. When did this happen? f. I am unaware of such crediting of EQ tests. It is entirely inappropriate. , Staff Assessment: y* !
.w . l There may have been circumstances where.this practice was considered tol be appropriate.
For example, this may have been allowed for equipment ' To the extent that focused l qualification under the 00R Guidelines. attention is placed on operat ' equipment performance, condition and However, environment mo irrespective importance with regard to aging considerations. of aging considerations, there could be some. question as to whether
" generic qualification" was sufficient to demonstrate that equipmen will function during an event.
any additional action is warranted to address this issue based on the information that has been accumulated over the past 25 years. All test failures (for all attempted E0 tests) were not specifically required to be documented, evaluated, and saved as part of the equipment qualification record and consequently, qualification may not have been totally objective (i.e., f0 may have been based on " selective" information). Peer Review Coments:
~
- a. IThis may be'true to some extinkbM{Ols believed 1
~
~
qualification ' including explanations:ofitest f ailures. 1
- b. In EQ tesling',' most Usl' pro [r~aidi werelerformed with' a minimum of ,
anomalies and all anomalies dncluding' equipment corrective actions l 4 andratestingaredocumentedr.iSince'itisnecessaryto demonstrate a clear path of.: successful. operation, when test f ailures resulted in substantiaDredesigns, some vendors chose to redesign andethen start the;quallfication process on new designed i equipmentU'Thus, not all test failures were passed along to the ! licenseesdThe process was ' objective ,in that a clear path of proper perfomance was necessary-to be documented. Although the NRC.did address
- c. More NRC oversight may be needed.
this issue in some of its EQ inspections, it is possible that the The statement of the ' problem was not corrected in all cases. issue is consistent with this reviewer's experience with qualification testing and documentation and his participation in EQ inspections;' and he agrees therefore that it is a valid concern. A-75
However[requirementsfor" Reporting '- d. Perhaps this statement is true. reporting test failures are g ; , of Defects and Noncompliance." I the scope of 10 CFR Part 21 should have beel l tions. ; would be.in violation of the Code of federal Regu a I Staff Assessment: h t The results of past research efforts The staff l nt should be ca applications in order to address issues dition andsuch as this o f
- experience and PRA information. equipment performance, con thattrending environment monitoring, root cause assessment,i and o information in order to identify and correct any EQ deficienc may currently exist.if necessary to ensure that current EQ testing practice appropriate. bility of
~; Non-saicty-related instruments that could impact the opera of > safety-related instruments were not initiallytion of this included in the scope equipment that was required to be qualified, and implementa requirement may not be uniform among all' nlants. Peer Review Connientit
- a. I am not aware that this is an3ssusik b.
Point Beach was.the pilot plant;. all plants were similarly addressed by the EQ Branch, ll
- c. The inclGsion ,of;non-safety Thus, equipment this th plants had to have safety evaluations for 10CFR 50.49.This ty should have been addressed for all plants.
was addressed at all of the.EQ _ audits of.which I was ' d. More NRC oversight may be nee'ded.
- e. ThisltiGmut!say beitrue.9HoWever. Tit is not dr example?IE Bulletin 79-018 dated January 14, the , int'ent'yMhetsecond paragraph'of ' item I und NRCl.staffl 1980Pstite censees0f:AlliPower: Reactor.
Taken.B %.CicelisR).(Except;,th'o'se!!! SEP/ PlantsFacilities)(ith t.fsted on Encl operati f Electricaliequipmenttitems@h'ich are' components 'o 1)* tha systems"listede.in:.' . Appendf x. A'of.. Enclosure i t 4, wh operate in the FSAR safety analysis;and are relied on to design basis events are considered within the scope of this Bulletin, regardless whether or not they were llyclassified as
~
of the engineered safety features when the plant wa licensed to operate. A-76
safety-related plant systems'will;be dependent of the outcome of As a result the licensees and NRC reviews < subsequent <to THl/2 above,'the requirement to address CFR50.49(b)(2). . As indicatec this issue may not have been as clear at;the time of issuance of IE Bulletin 79-018 Nevertheless, this'is aas it was safety. when.the tissue 'EQ' rule and all plants was should issued. addres: s thisissusasrequiredtoinsure;y,afety/andsafe.shutdown event of a.ossign. basis.accideq$ ,, , i Staff Assessment: Based on the staff's review under EQ-TAP Action item 3.e [10), t not appear to be a valid issue. review and inspection of licensee implementation of E0 requirements for l all plants. The process appeared to be rigorous and comprehensive, it appeared to be consistent for all plants. RG 1.97 instruments were not addressed in the initial qualification i) requirements and it is not clear to what extent (and to what criter a instruments were required to be qualified. Peer Review Commenti:
- a. It'should be clear now, b.
Merits analytical resolution{ 1(..~.'s.,canilyze existing data to reach resolution). .p , ;._. I
- c. .Theguida'ncep'rEvidedinRGhf97,Reviion2,datedDecember1980, canbetracedtoNUREG-0737,Piub11shedNovember198
'Supplement'No.
Clarification!!,Udated Decembarc17,11982. HUREG-0737 and its supplementcontainedletters)that'issuedthesedocumentsas requirements..rather than just NUREGs. . Subseq met with-allGicensees and discussed' qualification requirements The NRC staff and implementation dates as related to RG 1.97. W subsequently.. rote safety evaluation reports docu for all plants. Those requirements apply to all plants and are the same as the requirements of.10 CFR 50.49(b)(3) whichThere were represents the criteria for all plants.The exceptions were based specific exceptions to this criteria. primarily,on di.fferences in plant design which could affect the requirement (s) for a particular' instrument. Staff Assessment: See the staff assessment of the previous problem statement. Requirements for protection from " control system interactions" may not be uniform for all plants. 4 A-77
k.'
, s.y<
"l l
r; i Paar Review Commenti: .- a.e W as not aware of this issue, l
- b. "Miiits aM1ytica1' resolution ~(lie.. analyze existing data
~
resolution). l i c. ThisstatiiidrFli'notcomalitelyclear..However,if"contro 7 system interactions' is tie same as Task Action Plan item A-
" Systems 'trderactions in NucleariPower Plants,* see the sl resolution of Jtem A-17 contained in NUREG-0933. {
$_taff Assessment:
See the staff assessrrent of the twb previous problem statements. The EQ inspections of the mid-1980s found thatllymany progra
- 2. documentation necessary to support (Qitinspection is doubtful activities, e '
Without sufficient documentationI i at the older plants.that qualification was truly established at these fact it P_eer Review Comments: ! l l disagree,,isince these findings a.* actions to' demonstrate qualification were required. were not dropped and license
" . Are not the NRC
- b. .Idisagres;,soundslikeaneducationproblem. audits an inspections or written responses from the' licensees 7 understanding that,E0 open items, such as E0
- c. ~deficienc 1t was myies",found during the EQ. audits of the mid-1980s, were required.foilow-up l items by HRC Regional' Of fices.
d.TMoiThRC)MstEfidy'be~rie%edU ' b l t o it;was i s'.'A.,Th{fissue'dpiolati'oni?itnd',,E and NRCijtiffjfudit'edLilW . njappro'priate,1 fines;wheni N, ivsn couldenot;befdesonstrated! at, a pfei'it all' determined;thatWuilificatio EatidnStandards~that"were'appled f acility4}{oWaver sithe' quillf)from those '.that were*1tpplied to
~
to' older pitots are differerittnewer!pl. anttMifor2 examp di f fe rept%oml,thi NUREG '05883C ategory?I? requ i rement s Of.fferendeMliii . qualification?feguiremer f If'documentatton atl l s uch" di f f ehn'ce E do~ e xi s t ;f i t*l1 F a ai st ake . any pla'ntdsMnsufficle'nt to' establish' qualification,* that a mistakeL Alle operating plants'should have sufficient documentation to demonstrate that all equipment re
> qualified is qualified.
a given plant, then that 91 ant is violating b intent. unsafe. A-78 I
. i
m
~~^
Stiff Assessnent: Based on the staff's review under.EQ The staff TAP agrees with the viewAction (stated item 3.e [10) not appear to be a valid issue. above) that the findings were not dropped and licensec action was required to resolve documentation problems. 3. Given the evolving nature of E0 and the confusion that existed in the industry, licensee QA programs may not have been well structured and focused on implementing EQ requirements. Peer Review Coments:
- a. I agree.
b. To some extent, this may hav $ en~truei during the early stages of The situation has long since been corrected, EQ implementation.and to the best of my knowledge,?the Industry QA/QC p reflect sensitivity to EQ requirements.. In fact, the industry now performs self assessments, and/or periodic EQ audits of their own programs, and vendorThis surveillances combined withto verifystaff ongoing continued attention to quality in this area. training performed by the industry should alleviate this concern.
- c. " L'icensee' QA personnel were Integ$), team . members in the EQ process regularly performed at the and judging that QA audits weregI believe that"they were' fully integrated into laboratories EQ process all along. I However, EQ requirements were d.
This statement may be true. established in the early 1980s (approxim any confusion that existed early However, .in this should timecontinue confusion frame should to have been cleared up by now. exist, the NRC staff is available for discussion as needed. Environmental qualification programs at plants are, and should be, }{ving programs (i.e., programs should be updated as new information becomes available) and when mistakes, the NRC expects licensees to correct those mistakes. By licensees the way, licensees can update EQ programs and correct mistakes
~
without being issued violations or fines. 11af f Assessment: The staff agrees with the view (stated above) that to the extent that this problem did exist during the early stages, it has long since been In order to account for any lapses that may have occurred corrected. during the initial implementation of EQ requirements, the NRC staff should assure that full advantage is taken of operating plant experience and PRA information, equipment performance, condition and environment monitoring, root cause assessment, and trending of information in order to identify and correct any EQ deficiencies that may currently exist. A-79
- W m y:;., ,. ,
Sumary Based on the staff's review of current status and implementation issues, the - following recommendations were made: J a. Given the rapid development and transition of EQ requirements, the staf may not have been entirely clear as'to what was being " superseded" Therefore, there may be some confusion in the industry on this point. determine whether clarification.ofcthe existing require l necessary. l b. There could be some question as to whether
- generic qualification" was i sufficient an event.
to demonstrate that specific equipment will func f is currently warranted to address this issue based on the information l that has been accumulated over the past 25 years. l
- c. The results of past research ef forts should be catalogu applications failures, and (b) in order to address issues such as: lapses that may have occurred dur test The staff should also assure implementation that of (4 program r#4utrements, full advantage is taken of operating plant ex information.root equipment performance, conditlen and environment monitoring, cause assessment, and trending of information in order-to identify and correct any EQ-related deficiencies that may extst on an The NRC st*ff should provide additional guidance if ongoing basis.necessary to assure that current.EQ.. testing and QA practices are cc y < ; (,
appropriate. ,;y;g - The NRC staff did not consider any of~the current' status / implementation issues to be immediate safety problems. _, A-80 E - - - - - - _ _ _ . _ . _ _ _ - __ ' --- _
c w -
.~, .
D. Assurance of Continued Oualification
- 1. Existing programs have not been developed and implemented to assure continued equipment qualification,: including qualification beyond theT established " qualified life."
to this issue: Peer Review Comments:
- a. I agree that continued qualification'has been fumbled by the NRC.
I remember..a spring 1980 meeting where the EDO expressed great concern on this very point.:but the'E00 and NRC management's interests were diverted to other.more&immediate issues. b','"l'disagrfilWTKCin'dustiyiiQisies1FiGesfthsGiedtoassure the continued validity of"the qualification that'has been Again, established, and have impleme'nted programs accordingly. this is an area where one.can find varying methods and levels of details. Many of the problem statements listed to support this contention are just not. valid. 'I would be remiss if I did not point out that they..do ref, lect a level of unfamiliarity with the ! industry programs in this; area. If there is ardth'ing thafthe 'NRC could do in this ' area, it is the
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development <cfra r guide based onia' survey of the current practices. I Such 'a guide' wills.go:a long say;toward promoting: unifor industry practices.t . ithelftCiMiss'ondPerhaps'a'justificationcan isiiinconsistentf eed to ' improve? con'sistency"in ins >ection befoundunde'Ct(h practices, and to reduce the cost burden imposed by tse EQ regulation,
- c. The awareness of the significance to EQ of Component Root Cause failure Analyses,+ information.provided in NRC Notices and Bulletins,tand realization}.that unexpected degradation impacts EQ EQ awareness'lwe'uld 'pr'ob' ably?b'e' appropriate.is
- d. Thi s: statemeint'Ts' iiicossEt'tW.In"all.l'pl ants, 'there is equipment that 1s not qualified 1(or'the'fortyr(40) year itfe of the plant.
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Itiswelliknown';throughout'industrythatwhenaplecoof equipment reaches the.end of;its' qualified life, it sh reachesathe enc
- ofbits qualified 11fe, 3 then the EQ program reviewediandv, approved bytthe NRChis not being compilance with:the,. requirements of 10 CFR 50.49.
Staff Assessment: 4 for whatever reason, the NRC staff never really got around to establishing guidance for maintaining continued (ongoing) qualification f of equipment other than the place or requalify" aspect discussed in
-81 y
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I .,
, ['g M ,
h staff ' the peer review comments (above). ' Essentially by pursued d default, t e accepted conventional maintenance and surveil B of this for developing further guidance in this area. uncertainties that exist in the EQ methodology (see section appendix) indicate that additional measures are needed While the to assure continued equipment qualification over the life of thef EQ plant. tices staff agrees with the views (stated above) that a re-emphasis o awareness and promulgating guidance based on current industry tion, prac would be helpful, a more extensive' effort is needed. staff should assure that operating plant experience and PRA info t cause i equipment performance, condition l t and environm Further, the manner in order to maintain EQ over the life of the p an . staff's guidance should not necessarilyldbe limited to practices." address this concern for active components, and - of the maintenance rule for EQ considerations. i The 00R Guidelines state that ongoing programs should exist to re surveillance and maintenance, records to assure thatasequipment ddressed exhibits degradation (e.g. cables) will be identified and a necessary. Programs such as these are generally not in place. P dr'R EtaE CE 9 tsl ' ans l a'.1 '. l'b' ell'e'vCTe'.'acciptdd'n3isa175Urve111ance and mai'nte 3 ast being ' acceptable;ti,ineet thiskeq'uirement. These programs ! should'still be ' acceptable!
- b. They should be. l' c.
Merlt's arialy'tical.The resolution"(i'.e., following additionalanalyze views were existing also informa esolution)', l toreach(Tn"res'ponse"tootherrelatedissuesandproblem expressed l ' statement ! A tRht'ening"of EQ, surveillance, and maintel given'to worst case conditions. Where'e'xperience predicts,that certain equipment in ce , locatio~nt.is.expectedto'besubjecttosteamleaksand l inadvertent;s' pray,actuations, tho'EQ program should incorpor, ate testing (suchlas humidity strl 4 ram, the existing program not' anticipated /in)the,EQ;pr tional testing or enhanced should be supplemented by a condition' monitoring to' assure that e during a DBA, A-82 l
There is now a need to evaluate alternatives to theOpera quallfled life requirement. enhanced condition monitoring are that should be considered. Staff Assessment: See the previous staff assessment. _ ticensee QA programs may not be well focused on rnintaining50.59- EQ requirements. For example. analyses performed by licensees (e 9. reviews, root cause, corrective action, etc.) may not be well focused in this regard. Peer Review Comments: a. There is no evidence of this at this time,
- b. If licensees are'not maintaining EQ programs as require Code of Federal Regulations,lations should be reported to the NRC.
of requirements and such vio I Staff Assessment: See the staff assessment following 0.1 (above). Changes in manufacturing techniques and use of mat equipment c- i' cation documentation.
;, q 4 peer' Review Cn= 6ntit - [.
a.i This could be true. It is
- b. IndustryVesp6nsiblittyImore NRC' oversight may be needed.
the industry's responsibility to, account for significant differencesthetWeenbthatmatarla1s and parts use that was quallffed ? More oversight may be needed to assure t3at qualification: programs.accounttfor such differences. Again, EQ should be a
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- c. '"If'not ade4uitely" addressed it should be.
living program. ?If Ilcansees discover that an EQ program or some parts of an:EQ program.is inadequate, that licensee should take corrective action without being forced to do so by the NRC. 51Mf AueumeAL: f The staff agrees with the view (stated above) that it is the licensee's i responsibility to assure that replacement and refurbished or repaire equipment is adequately qualifted,'and guidance for addressing this concern would be best addressed as an industry initiative. A-83 l
~ ~ ~ " ._ . - ,
%t . ,
4 yp.: Purchase specification requirements for replacement parts have not addressed relative to [Q. Paar Ravlew Commental alFIseemto'remembirtheywereIddresIed'{nthatreplacement equipment was required to meet Category I requirements, b. llave not been addressed by whom? Thil'-issue is addressed in R0 1.89paragraphC.6,andin10CfR50.49()).
}taff Attattment:
While the requirements are relatively CItar for instances where com replaced, the'requirementi are not 10 clear when i See the itaff components are beinpiece parts of qual fled component $'must bef rep assessment of the previous problem statement, Criteria for acceptable versus unacceptable aging degradation have been established. Peer Review Comments: . a ,e
.!fthisconcernslife.estension,thismaybetrue. I b.i # ;I do not' agree, c.".7PThis~stitHMhQ{Ttfufdhlflf# equipment that was not preaged Forthis'equpoent]"tlicensessmustdeterminethelimittowhicha place of equ pmentTo can be degraded.and yet perfors its requi date the NRC has left this action when called upon.
determination to the licensees... or pran ed equipment, the equipment'is preaged to the'end of qua)1f ed b in accordanceyth preag g ',testjng.and analysis)', then theIn this event,
' determined.
resping' environment Nas ncorrect) he prang qualified final sis and testing # ould be revisited an of the 'reviitt'.
}taff Attattment; The staff has relled~primarily on initial i This is a valid concern.
qualification testing as a means to estabilth [Q. but focused atten has not been provided on maintaining equipment qualification over th See the staff assessment following 0.1 (above). life of the plant. The ef fects of installation, maintenance and surveillance practices or equipment qualification have not been addressed, peer Review Commenti
- a. I see no evidence of this at this time.
A-84 l
. a .m v .
The merits analytical resolution. b, 'ndustry responsibility effects of installation, maintenance, and surveillance practices J have been addressed only cursorilyLinDindustry standards and While itets the industry's responsibility to regulatory l guidance. account for these effects, it would be helpj more detailed guidance than iso currently available, _surveillancedand'mathtenanceofequipmentis
- c. - The installationlbility of licenseesMTo the extent.these l the sole respons practices need to be addressed,/they must be addressed by licensees. ;
i Staff Asse nggal: i The staff agrees with the view (stated above) that if it has Set been the addressed at all, it has been done in a very cursory manner. , J staff assessment following 0.1 (above). , l Identification and treatment of hot spots, long o I chemical attack (e.g., boric acid leakage, decontamination activities). and localized anomalies have not been addressed paar Review Cnaments; ! l I see no' evidence of this.atithis-time. Hot spots, when
+
- a. identified,*.are addressed ~byullcansees.: So are the other. ,
conditions' The issue Industry ViiW6nfib'ilhFt"me'rits' analftt' cal resolution.
- b. " raised by.ithis statement <is similar to the one'in the preceding statementinTheMndustry'is aware.cf the need to account for these ,
effects totastttre' plant safety,%butiprescriative methods of,doing !' so are not:available. The' items named in tsis statement he more can be re arded.,as sa clinks'in 1:fetylsystems, as they ma3 11 ely to:ca se fillure' than;the' degradation of equipment in normal environmen'ts. Consequently, their importance cannot be overemphasiz' add!.However sincesthey are deviations from the conditions'plannedtoexlstiinnuclearplantsandcanhavemany individual variations,'it is not feasible to develop detailedNo procedures for dealing with them.
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to provide.some broad guidelines. 1 EQ progrims"'as"tnvision by the NRC and" industry should be set-u
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i c. to be continuously updated so as to be able to a
-It is the programs are referred to as living' programs.
responsibill.ty.of.; licensees.to update and mai truatment 'of" hot' spots 11ong ~ overhangs, insulation and jacket , embrittlement,' unintended long-term submergenco, exposure to l chemical attack, etc. I A-85 f
l
. r Staff Assessment: ;
that the importance of Thestaffagreeswiththeview(statedabove)idanceisneedad. See the this concern cannot be overemphasized, and gu staff assessment following D.1 (0bove). Maintenance and inspection activities ha've not been~ developed and ! implemented to assist in the aging management o_f EQ components. Pee'r' Review Coments: a.' I see no evidence of this at' thisittine, I b. This statemen't will certainly apply to plantsOne thatofdo the not have an acceptable surveillance and maintenance program. primary parts of:an acceptable EQ program is a comprehensive surveillance and maintenance program. Plant's without acceptable ; surveillance programs. and maintenance programs do not have maintenance is a major part of EQ and must be performed by the : t licensees throughout the life of the plant. l The (v11owing additional views were also l
- c. Industry responsibility.
expressed in response to other related issues and problem l stataments:
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A 'ttchten'ing"oT'EQ,"surve'111sncifind maintenanc 4, m given'to Worst' case scondi,tjons, Where e'xpeFisnce predliithliat'cekt'ain e6uipment in certain i l locations,is .sxpected ito be'. subject to steam leaks and inadvartent[ spray acttiationsnthe EQcprogram should
- incorporate. testing (sucfnas(humMi;tystress' tests)to simulate .these service 'coriditions ' .Where such; events were
. notanticipatedinetheEQ/ program,Vthe;existingprogras i should be; supplemented'byLaddstionalytasting or enhanced l condition; monitoring to assure that equipm during'a DBA. There is now a need to evaluate alternatives to theOperati qualtfled life requirement. enhanced condition monitoring are i that should be considered. Staff Assessment: The staff has relied primarily on initial i This is a valid concern. qualification testing as a means to establish EQ, but focused attent on has not been provided on maintaining equipmint qualification over the life of the plant. See the staff assessment following 0.1 (above). , / A-86
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l Mfm < , ' 2, Condition mor,itoring techniques have not been wfficiently developed to project remaining service life. Peer Review Cn = ants:
- a. I am not aware that condition monitoring is used to determine remaining service life,
- b. I agree. This is'well recognized by the NRC and the industry.
Ongoing focused. research can be effective in this A PSA area if it is be yrs) program and progressing.in.small manageable chu regard. . c . c. It is already'accepied'pract'icito calculate qualified' life from assumed ambient temperatures and to estabitsh actual ambient temieratures. Thus, the use of Condition Monitoring techniques, suc) as Infrared. Thermography and' vibration signatures, are a natural extension to. establishing remaining lives for mostTh , equipment.to be one of the most significant parameters at detecting age relateddegradationinNURE0/CR5762. The condition monitoring component
- d. Merits experimental re% arch.
of the NRC research plan has the greatest potential for benefiting the nuclear industry,
- e. This is correct.
Staff Assessment: The staff agrees with the views (stated above) that resea research industry, plan has the greatest potential for benefiting the nu techniques can be developed to project remaining service life with any degree of accuracy, but condition monitoring techniques can be developed and used to provide assurance that equipment has not degraded beyond some pre-defined acceptable level. Also, condition monstoring programs can best be developed and implemented as a cooperative effort with full industry participation. Over the next several years, the NRC staff should develop, in concert with industry, guidance for the mandatory application of condition monitoring techniques in order to assureThis is continued equipment qualification over its installed lifetime. a part of the more comprehensive effort that le needed to maintain equipment Qualification (see the staf f assessment following D.l. abovel. 3. E0 re utrements for replacement equipment should be better defined and) led. The folinwing problem statements relate to this issue: Just i Peer Review Comments: 4 A-87
h a, It is timeitadet.theilndustry by the industry, fine the tune theirIdisagree.-H part of programs, This areaThat requires continued' is the nature of beast, vigilance on it should 4 the NRC and. industry. also be pointed out that some of the problem statements listed f below reflect a level of.unf amiliarity.with the issues. f Staff Assessment: Since several different standards were allowed h EQ forrule) initial equipment j j qualification, depending $1nceon plant-vintage, a transition period was 10 CFR 50.49 ( rigorous requirements of the rule, impact on necessary for upgrading replacement equipment to minimize the operating reactors. " reasons to the contrary" appropriate d in for the transition process were established by the NRC staff and include Regulatory Guide 1.89. long this transition period should be and more appropriate " reasons to the contrary" have not been estabilshed given To that ample time has been the extent allowed for the " transition process" to be completed. that it is truly necessary to upgrade to the more rigorous be E0 requirements, established, more appropriate
- reasons to the contrary" sh changes in the methodology for establishing initial equipment d t qualification may be possible that could be of benefit to the in us ry.
This is especially true recognizing that ongoing measures must be' developed and implemented to assure continued Therefore, resolution of this concern should be D.l. above). with industry initiatives to improve the E0 process. coordinated ! l
" Reasons to the contrary" for not upgrading replacement d equipment requirements stated by 10 CFR 50.49 appear to be without merit an should be justified.
Peer Review Comments:
- a. I am not aware of this issue.
- b. Several " sound reasons" were Itsted in a 1982 (?) Generic L signed by Cisenhut.
where necessary, ) c.
^' Sound reas' ens to the Contrary
- are probably antiquated and be droppedim.The more common practice of upgrading replacement equipment has been in effect:since 1983, l d.
Perhaps, but a reading of the reasons to the contrary as !outilna In AG 1.89 seems to suggest that economics is involved and technical justification may be somewhat elusive. Staff Assessment: See the staff assessment of the previous problem statement (above), j l A-es
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f$[ "_ { (,;.J4 g 5l .
- .tn .. .
Equipment that is quallfled to the"00R Guldelines'and is well suited for its application must be replaced with NOREG-0588 Category 1 equipment regardless of whether the upgraded equipment can perform the desired function as well as the older equipment, . Peer Review Comments:
- a. I agree.
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- b. . Is this true? ~l' thought " sound reasons" applied. It certain1y should -- replacing equipment with a different type often creates problems that we don't want or.need.
j c. This' statement is' not correctJ(see Regulatory Guide 1.89 Rev 1 Regulatory Position'C.6). In addition, since replacement equipment.is more. rigorously. tested than 00R Guidelines equipment, how can it be shown that DOR Guidelines equipment is better suited for a particular application? If a particular item is performing a given function and it is replaced with an. item that cannot reliablyperformthatfunctiog)thenthisisnotconsideredtobe an upgrade. Staff Assessment:
- The real problem here is that, to the extent that this situation exists, licensees have not planned for the eventual' replacement of plant equipment and have not taken the necessary steps to qualify equipment to the more rigorous requirements. This problem is best resolved by the industry. Also, see the staff. assessment following D.3 (above).
The requirement to upgrade equipment from Category 11 to the Category I criteria of NUREG-0588 is prohibitive and provides no safety benefit, especially if the installed equipment has been preageo and all that is missing is the Category I documentation. Peer Review Coments:
- a. If this is true, the requirement should be relaxed.
- b. Apart from my concern about " sound reasons," I don't understand the last line -- does it mean that DOR level documentation is available7
- c. For equipmenti to be certified asjHURCG-0588 Category I or '
10 CFR 50.49. qualified, required moreithan just pre-aging.' Categoryillandl10.CFR50.49'cer,tificat'ionrequiresbetterandmore complete ' documentation of performance characteristics during the harsh environment. Thus, equipment which was pre-aged, but was lacking in current practices of' documentation, has been certified to meeting Category II or DOR Guidelines requirements.
- d. Industry responsibility; merits analytical resolution. If "all that is missing is the Category 1-documentation " it is not A-89 -
dd - the obvious why the existing documentation 1, it cannot I is cannot more demanding requirements of NUREG-0568, Category be concluded that u9 grading from Category On the !!lyto Category other way always 'prohltitive and proviN no safety11ty.
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benefit.' In hand, upgrading the qualification ls:.not necessarily i and the on to provide reasonable assurance of, equipment"oper.bl certain cases, increased survalliance,fcondition monitor ng,. operating experim.ce may be' acceptable alternatives. from the'fil'a of this e. Exactly wh'athdocumeM eor
'..e isen preage it'tdN16[d only, or has it been equipment?' Has t u If-it has been preaged only then.it is preaged and LOCA tested?
culte obvious that required performancetable. in BAa beDBA has not b emonstrated, and this cendition'is"and'should c assured? Staff Assessment: I The staff agrees with the views (statedd that upgrading above) that Category qualification requires more than just preaging. ovide reasonable an qualification is not necessarily the only way ttol pr As discussed in assurance that equipment will function during an even for . Section B of this appendix some changes in the methodo ogyible th establishing initial equipment qualification may be possThis is especiall e continued be of benefit to the industry. ongoing measures must be develo qualification over the installed lifetime oTherefore, licensees, toresolution the extent that staff assessment following D.1, above). this concern represents a significant problem for should be pursued as an induttry initiative. f qualified l - There equipment. is decreasing supportThird-party and cooperation vendors will from ve i tn provide qualified replacement equipment. supply Peer Review Comenti: Qualit/ may be suspect, also,
- a. - Third party dedicators?
- b. Jindustry responsibility, ~
lity of
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- c. 'I believe this statement 1s co'rrect, but ithat ed is the rea the market. place.
of a plant by using equipment not qualified to perform requ functions when called upon. Staff Assessmed: l i of this The staff agrees with the view (stated above) that reso ut onHowe concern is industry responsibility. A-90
,.Wo. ,
- ~, ~^ <. -
V of this appendix, changes may;be possiblelin the f0 methodology that ma help to alleviate this concern. The MC"staf f should be receptive to (a)'developedasanindustry such proposed changes that are: initiative, and (b) technically justified.
- 4. Tight budgeting continues to be a challenge to any advancements in area of E0 Peer Review Coments:
I know many cases where.
- a. I agree, and that is the real world. advancements have been I believe that time and market forces will take care of this,
- b. Merits analytical resolution. The suggestions (made in response to other issues and problem statements) that EQ requirements be reviewed in light of the experience of the last two decades has the prospect of increasing the assurance of safety and reducing CQ costs. For example, if the qualified life requirement were replaced by standardized stress testing, it.could reduce costs significantly. .
g.w; p . - Staff Assessment: The NRC staff agrees with the view (stated above) that a review and adjustment of the EQ requirements.in light of the expe prospect of increasing the assurance of safety and reducing EQ costs. However, resolution of this concern is industry responsibility and should be pursued as an industry initiative with full NRC staff cooperation. Sumary Based on the staff's review relative to assurance of continued Qualification, the following recommendations were made: a. While the NRC staff agrees with the peer review comments that a re-emphasis of EQ awareness and promulgation of g and PRA information, equipment performance, con monitoring, root cause assessment, and trending of information are used in a comprehensive manner in order to maintain E0 o plant. to current practices." This approach would be useful in addressing current concerns such as installation, maintenance, and surveillance effects; hot spots; long overhangs; aging degradation; etc.
- b. Implementation of the maintenance rule should help to assure continued equipment qualification over the useful life of each active item that ls qualified, and the staff should initiate action to include passive electrical equipment within the scope of the maintenance rule to better assure continued qualification of electrical equipment.
A-91
' #r o
st af f should develop, in concert
- c. Over the next several yea s. the NA: i condition t
with industry, guidance for the mandatory application qualification comprehensiv over its installed lifetime. effort discussed in (a) above, th equipment qualification, d. To the extent that it is truly necessary to upgrade to the more rigoro E0 requirements, more appropriate " reasons to the c established. changes in the methodology for establishing initial equipment h industry. qualification may be possible that could be of benefit to t e This is especially true recognizing Therefore,that ongolog m installed lifetime of the equipment (see (c) above). reso t initiatives to improve the EQ process,a. The NRC staff agrees with the peer w comments revie../ that a review d and e. adjustment of the EQ requirements EQ incosts. light of the exp prospect of increasing the assurance of safety and reducing d However, resolution of this concern ($ industry responsibility an should be pursued as an industry initiative with full NRC staff cooperation. f The NRC staff did not consider any of the issues pertaining to assurance continued qualification to be immediate safety problems. e l l l A-92~ ' !
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E. Ecutoment-Related issues 1. Failure of other electrical components:such as-penetrations and connector assemblies may be more importanti.than the failure of electrical cables, and more attention:may be warranted for these
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components. Peer Review Comments:
- a. Both f ailures could be extremely detrimental for plant response to a DBE, so the issue of more significance / consideration for one failure versus the other escapes me.'
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- b. . Operating reac't'oh' inspection's"c'e'n6nt('a'tyd on non-cables.
c. 'Depuding Vpsn~6n~e's' perspective,' a ca'se 'can be made for one or more component (s). as more important than'~others. I do believe that the focus on cables is correct'and should be continued. Decisions relating to the importance can probably be~best addressed if'we complete a PSA of EQ priorities as discussed i elsewhere:in this-document. A few guiding factors in establishing such importance rankings include:
- maintenance and surveillance being. performed on the items of interest;
- potential.~for.as yet'u'naddressed or unmanifested common cause t f ailure mechanisasi' .J.'
cost to replace, particular1yiduring an extended license
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term;
- potential *for causing iiulfiple's/ stem' and component f ailures simultaneously;,and
- lastT'but'not ileast,. fa'ITu'ri experience.
- d. Shat does ?"more $important' mean?i' Risk' impact, higher failure rate?
- e. Judging'fromthe,;failuresnot'edlin"BNL'sreviewofLER'sandHRC's Notices and". Bulletins, connectichsiand; penetrations may be experiencing more aging degradation than cables and thus would I warrant additio'nal attentioni f.
Merits analytical resolution. A valid concern because it is possible that the failure ratestof connectors and penetration assemblie's exceed that of cables;-
- g. First of all', all equipment within'the scope of the EQ rule is important, as is indicated by its title, "t'mdronmental Qualification of. Electric Equipment-Important to Safety for Nuclear Power Plants." The NRC' expects licensees-to use good A-93 i
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engineeringjudgementwhenmakinfeqdipment,operabilitydecision As i and decisions involving the operation of plants.in general. for 'his particular situation, althoughlelectrical penetrations andconnectorassembliesareimportant7theywillnotfunction without the cables that transmits. power to~them.
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Staff Assessment: ; Based on the peer review comments (above), the specific lidconcern regarding electrical penetrations and connector assemblies this is a va one and further action by the NRC staff is warranted to resolve This concern should be reviewed in light of the ongoing
' issue. ,
literature survey that is being done under contract for the NRC to Corrective ! determine to what extent a significaret problem may exist. i that action should be taken depending on the nature of the deficienc esl are identified (should any exist). > operating plant experience and PRA information,i equipment i perform ; condition and environment monitoring, root cause assessment, and trending of information in order to identify and correct E0 defic enc es (see Section A and Section B of this' appendix) will i help to addres this concern nn an ongoing basis. comments that an importance ranking may be appropriate tion. given oper plant experience (i.e., equipment failure data) andthe PRA informa
- 2. Holsture transmission through cracks This in cable insul l terminal equipment not designed to withstand moisture.
vulnerability has not been addressed. ffer Review Commenti: I disagree. Cable' qualification testing addressed this, a. It deserves sometattention in the ongoing
- b. I agree partially.
literature survey that is being done under contract for the NRC.
- If the scores of' cable testing perfonned to date indicate that moisture.. intrusion through cable : Insulation is' a high probability l event, we should perhaps:initiateoadditional research on cable l connections.: I am familiar with a' couple of instances of suchinn b
l occurrancesig ut(need .more con (ijhtth'e?)EEE-383%orking group and , otheEsF e79Mc6mittee7membersqualificatientsbe'clalistsp
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l the weakes G1tnC1n the cablefsfstemss'
- c. JThis l1s. a Nal,1d fissue.
i nt has
- d. .The inforniatiWibout moisture transmis'ston intosequ pme been addressed and was passed along to the in e.
Industryfr'esponsibility';. meritCas19t'ical.iresol'ution It'is primarily the and perhap l more NRC oversight may be needed. responsibility of ind I A-94
this statement, but the process could be aided by guidance and l increased oversight from the NRC. a l
- f. This address.
is the type of situation that preaging is supposed toIf trackingishould occur during:the accelerated On the other hand, aging pro the cable, thereby exposing the Vulnerability, der the requirements if you are referring to equipmenti.quallfled un of the DOR Guidelines where preaging.did.nol~.take place, then you
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are corrnet. 11Alf,Ak111ELt!11' The NRC staff agrees with the view (stated above) that this concern should be reviewed in light of the ongoing literature survey that is being done under conteact for the NRC to determine to what extent aA significant problem may ex::t. (above). L Solenoid valves may not be sufficiently qualified for certain applications. Peer Review Coments:
,I I - a. There is no evidence of this at.this time. l flaving said '
- b. Idisagree.,,?!amnotawareofanysuchinadequacy.
that,,let:me, also mention that;there 'is certainly room for ' qualification programs for certain;$0Vsidhaddress;som [appli' cations]? .s. .; . l ' t
- c. ConsiderabTe" effort'has been?dedlUtidi o* sol'enoid' valve i
qualificationWTheFqualification of tsolenoid. upgrades is i currently beinig 'a'ccomplished'linHndustry. , d. Industry responsibility; more'NRC' oversight may be needed.
- e. This may be correct, but we need to discuss specific applications.
4 Staff Assessment: This concern should be reviewed in light of the ongoing literature I l survey that is being don.* under contract for the NRC to determine toCorrective I r what extent a significant problem may exist. be take'n depending on the nature of the deficiencies that are identified , (should any exist). Beyond this, focused attention on operating plant l experience and PRA information, equipment performance, condition and 1 environment monitoring, root cause assessment, and trending of -' information in order to identify and correct EQ deficiencies (see l Sect ton A and Section B of this appendix) will help assure that problems l l of this nature are identified and corrected. I n,. A-95" i i
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y %. >
- 4. EQ barrier elements may not be adequate.w .y g.;pi;;;
Peer Review Comments: ;.
, yg' %;V,. ;
e.
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a.. :,1 am not' aware of this lssue. kut/l's'notNnethatcouldbe
- b. I agree'.T This is' a' vaMd concern $1t should be addressed through '
resolved?by>additionalJ research.5 , plant configuration; control programs.
- c. . Th'is statesent is not clear; ,
- d. 7The information ab'out moisture.Ninishdion~into~ equipm i
! been addressed and was passed along to the e.
This may be correct,' but whether they'are quallfled or not ~ on the specific application (s). This comment lication seems to be more plant specific than general and is representative of appEQ barrie problems that must be addressed by the users. are capable of being qualified for some application (s); but should not be assumed that they, ara qualified for all If these barrier: elements are'being used in sppilcations. l i ; applications for)which. they'are' i the not; qual user:and ' led,~. it is a vio the NRC.
' of the EQ rule and should banddressed.b Staff Assessment:
E0 barrier elements consist of flood barriers, walls, dverse enclosures, penetrations, seals, etc., that provide protection against is not aTo the t environmental consequences. credited, the equipment that is being protected by these ele EQ barriers. i required to be quallfled. tight enclosures, it is not meant E.2, andto E.3be exclusive of other (above). See the staff assessment of E.1 5. Qualification of equipment seals and vapor barriers on plants, NUREG-0588, especially those that are subject to the DOR Guidelines and may not be tufftctent. Peer' Review ComentYt a. 7 There is no evidence of this at'this time,
- b. * *Ilknot of n641 sis for.this concern,
- c. ' This'. statementlii 'not clear. ,..
Elec'tricalilnterface Sealing l' .1988; d .' EPRI NP-5000*,PHindbook'In! March,1990; and EPRI HP-6408,/* Guid 4 Maintaining and Extending the' Shelf Life C 3 nuclear industry. ,
'A-96
1 Industry responsibility fn HRbIover'sightimaybeneeded. e.: l l * ~but Yh' ether they 'are qualified or not depends f.
.6This comment seems to be more l
l
'This on the' may specific"be"c#~/ect,ication(s)d appl is representative of ap ' plant specific than general an Equipment seals and problems that must be addressed by the users.
vapor barriers are capable of being qualified for some application (s); but it should not be assumed that they areIf equipm! qualified for all appilcations. barriers'are being used.; tion of the EQ rule and should beln ! qualified.11t is a viola addressed by' the user of tthe'se materials and the NRC. i Staff Assessment: i See the previous staff assessment; this is a subset of the concern i expressed by E.4 (above). l s 6. Epoxy compound used "* for potting electrical penetra and/or during a MSLB. d Peer Review Comm'e'nt}: i
- a. There is rio evidence of ,this' a't"this time.
l
~
- b. I know of n'6'bailt' foIth'ido'ricern.
- c. Potting part of tht 3omp/penetr,ation.11finot';jshould have beel oun'ds;in penetrations itif s most likely a vendor spec t fic* oMmodeli spect(16' problem.
l I 1
- d. Industry responsibility; more NRC' oversight may be needed.
f This may*be' correct, but~whether'it is qualified or not depends on e. i the specific application (s).. This comment seems to be more plant specific,thad. general and lsjapresentative of application ~ Epoxy problems'that must be addressed:by the users. ing"qualif f capable'of'be,d'thatti not,ba, assume s' qualtf,iedifor/ soms application (s); b
't/sedlin*jed 'for allt applications. Iapplica
*s ?
j itisf8{fbal i epoxy coinp/7t'ils,"a'Wo qualiffe'd ation'60'the#EQ rule and should be ; d addressed;bycthe user and the.NRC. ' Staff Assessment: This concern should be reviewed in light of the ongoing literature survej that is being done under contract for the NRC to determine toCor what extent a significant problem may exist.
- be taken depending on the nature of the deficiencies that are identified (should any exist).
- 7. Use of the following products in EQ applications may need to be better defined and justified:
A-97 y
,c .w
- - - " ~ ^ " - - ' - - - - - - - - - - - - - - - _ _ _ _
- - ^ ~ - - -- - __ _ _ _
l'
- polyimide insulation (Kapton) l
- Butyl rubber insulation l
mineral wool insulation (especially in wet environments) i
- bonded jackets l
;
- coaxial cable i a terminal blocks I Pee'r"6viG'GnmEfD l
n'. dJRii5 hip ~ ibis 1,1/? f~or) hwy {fRjFiSWa$liKTAKEdil41El f fe ; extens orp . ggf. . , ] t i b. I' kriWof?ho'<bVsibTor thitIc6nieiE.
- c. t aminot,elear what?thalpfobiliiiisilW' ii)hithEllite'd sitsrjals.-
l De fine . the3 problem.' _ ,
- d. 'Ho' inntWill.'shbuldIbi% Tid?
Mhn OilTf6dT$dfs i appilcationb All"ogthey{ hii$hid:spectfic qualification;;testuperfdrmedj , _,tsj 1
- e. Industry respon' sib (11f#WifffTrilTyfEir,7 Tis 10tf6ti'.
! f. This may, be,.,corregt',', but who,t Mthe se :matniil si}a re > qu a.1;i fi ed ,_ not depend's4cn,the$. s titlyeccf i be more plarit spec h6acif.ic { C ~jnsN;Albbf a spitcationiproblemj eone tlesi liiateF1als 'ipe i tod( ' Jjgiused l applicaf,difo qual ie l i64 f6sM
~
j .eW{ l vibl onlofit thesematerills RQ aj , . ,e. j Staff Assessment: . .; J This concern should be reviewed in light.of the ongoing literature } survey th.tt is being done under contractTfor the NRC'to determine to l what extent a significant problem may exist with any of these materials. i Corrective actions should be taken depending on the nature of the l deficiencies that are identified (should any exist). Beyond this, j focused attention on operating plant experience and PRA information, l equipment performance, condition and environment monitor i l EQ deficiencies (see Section A and Section B of this appendix) will help i assure that E0 deficiencies are identified and corrected. 8. The color of insulation material may have an influence on the rate of l its degradation. Peer Review Conrnants: l a. I am not aware of this issuis I l ' l A-98 < l
' #( . ,
, :hjy5p.m ,g.; ,s .
o ;s+ ~aqQ4.;gyy 3%:av._ . . g. b '. . I know'of no basis for'this' concern. ( ! c. This is n valid concern.
- d. "Insulatio'" ncolor"differencessirf rste~ of> degradation 1s probably l another second. order'effect which is overwhelmed by the severi,ty .
of the DBA te' sting;
- e. Merits analyticali. resolution.
Staff Assessment: To the extent that focused attention is placed on operating plant experience and PRA information, equipment performance, condition and environment monitoring, root cause assessment, and trending of information in order to identify and correct EQ deficiencies (see Section A and Section B of this appendix) concerr.s such as this one are of minor importance. Summary
.hhN -
Eculpment-related issues and concerns should be assessed primarily through ! f review of existing information and by taking full advantage of operating l plant experience and PRA information, equipment performance, condition and environment monitoring, root cause assessment, and trending of information l l on an ongoing basis. Corrective actions should be taken as appropriate for significant issues that are identified. .. Equipment items and concerns that require further review and assessment by the staff in this regard include:
. electrical penetrations and connector'assembifes
! a solenoid valves E0 barrier elements e seals and vapor barriers
+ epoxy potting compound
- moisture intrusion through cracks
- polyimide insulation (Kapton)
I
- Butyl rubber insulation
. mineral wool insulation (especially in wet environments)
- bonded jackets
. coaxial cable
= terminal blocks The NRC staff did not consider any of the equipment-related issues to be immediate safety problems, A-99
-. . _ _ ^ -- -- . -- . -, . _ _
l F. NRC Oversichl ' 1. The prescriptive regulatory approach that has been taken relative to CQ is counterproductive, inhibiting progress and innovative approaches in resoSing this complex issue. Peer Review Consnents:
- a. The regulatory approach taken.Wdidriven,(to a large extent, by '
the lack of attention by the,industrfen,this alssue.iLTherefore, I disagree. e;w's.;perfomed EQ
- b. Can th'ose of us4ho'.ke(tipinh~oy~ehting'yhi' i inspections ~ hop'e 16{be 'parolid. soiieda)NTOslomentieflects how the NRC operates.- q.
j 1 c. I agree. There is some validif/N DBsM@?!fhfuld 'be noted that despite this, there,han been 'several ihnovations on E0 i problem resolutions. My guess is.?thtt'the industry will not, and generally has not, sat ~1dle iff theref are.. cost' savings to'be.had through innovations; No researchnvork is*needed on this topic. i j , do
- d. Herits an'alytidal resohltiond, Uthe'y" Hat'%gi;1at' ape ions'ju. allow Meviations stified.' i from prescribed Howsver.sthe requirement findustr juluallf h rb, t.s (Fhif tr;.itoffellow 4an
! ~ approachlknown'tolbe R e I '{d*ofgunds$akisp.the" rilk of ! justifying ~.aninnovafie"pth approa 7,er/b. ps/jthfMRC~ y lve approac6hs'should by _. i facilitatetheintroduct.fon-6fM encouraging them and providing'.A more efficient process.for their i l review.
- e. Perhaps, but the prescriptive >tijjulat6ryVapproach res01ted'.from sresistance a I f
lack of initiative,by the indd's rthe"out-right.tcanjbei seen l by, industry.;to'the.NRCainttiat e.i F E i.'!his i f E;B lletins"79h01,- i in.tholindustrM.iresonsecto}is Gly- eVNRChas i 79-01Af andW94018) tidt1 Ash Mef?, W Union sent'a " Petition *fo Emergeh'c ibn.in'two 66ght l ofConcerned'SciintistO'(UCS) 'able s, .innd t environmental areas: fire, protection for'.e ~ Th l qualification of electricalc Commission to immediately, shut i ' nonts@ sall spa'efpetitions.askedithe rating. plants,.and to ! l hait construction of new plants'.V$kshairesult, .the Commi.ssion issued a Memorandum and Ordera(Cijs 80-2))jdated:H4y;27,'1980, which ultimately' lead to :the sprsMipilve r,egulatorylapproachEEE j (through documents Standardi323 1974 La; s uch . a s thel DOR 7Guidel ine ndt.10CFRj501491 l here thattth0 MRC'idap;iMach?resuls rom %fndiistr'y'?f refusal *to ' 3 be cooperative after repeatedYrequest ?from'the NRC. i 5taff Assessment: l In general, prescriptive regulations do not allow for innovation and advaaces in the state of technology and tend to be counterproductive. i:. A-100 A.
),
3 The NRC staff should encourage i industry 4 nitiatives regulation to improve the state (10 CFR.50.49) - of equipment qualification, and changesdin3theu
~
f ; should be made to facilitate this approacKM5pel ! for establishing and maintaining EQ should be prov ; other documents where changes can easily be mad 2, The safety-significance of EQ issues,is not' differentiated and recognized in the regulatory process.JFor example, the EQ inspections of the mid-1980s emphasized documentation, without.a corresponding emphasis on the equipment's safety significance. : Peer Review Comments': ,
~
I disagree. The documentation findings were associated with l
- a. j equipment identified by the licensee as being ;
)
separate safety classificationt safety related. ..
- b. I disagree 'itron ly.3fTheille'inshibet'functionalfpdforma'nce criteria reflect ng necessary?safetylfunctionsWThe6,6umerous C
complaints aboutfdocumentationXf 6 vite the rebuttal:what:do you want instead? a i m a iifgl
- c. Human endeaibEFaff:iU6jE7foTfunIa$sa%
~
9 one.j:One,1should poor (9.Qfidf documentationicitedhinftherskamp@ipfitst,were;condu'ctid recognize tha'trthe JRCuins' lif M en#th eqid headM}Atath'atddneturei.able w implementing EQ:waiim6 Vin epa thelonly,,fojajJRC f) ed i alkdownsitofredew Evenithen,athe 1]fi i etisieEiiji?$ubsehuerit equipmentiinstilli jind is.have focused
' inspectientlat?<the:,p's ~ lt enInseand ,facQitf testreqdipment nd e on :hardWarelinstillat ?kri d%It : HolyNill"not;want 'to problems',i oneilllin ittkofiEQ'a're' achieved. With find out,'if the~reaFsafity'b toi. improve, attention lto safety that said,'let'us nowslook/,atth^
! significance.'*'."Th'e answer 1sVPSAMAS$ent' a systematic e j that type, we c'an only"have' conjectures, and' honest professional disagreements on this issue. l d.- ~T he' hsue'is not E cliar)Mt'd(TdtTc1'eii9whatblifmhntiby5the f safety-signir.icarice ofiEQYissue Doesfitirefecto"the different i i ffi " ;' d,fipment3'tess7%Does iff the contributionsttoirisknfqd)?s@t statement 11mplypthiit'ith'e're JEi :emph.or'ent(l;ivel'siof ails 9en1 documentation in safet insteadofjustClassh1E7t1No the mid-1980s-was nece'ssary,,thecause'"it Wasinot feasible at that timetorevieWrEQ!ProgramsFwithfut7at$eastfadequate documentation.) T
- e. It has been' determined'by'tlie C'oiimiiiion"thattbe A-101 i
-x 1
-<.c ,rc. .
' issues have similar'safetyrsignificahce..uihis approach is j reflected incthe issuance uf,GepericTetter 88-07 where in its
~
l , enforcementthestaffwasnolitequired'to.,determinethesafety ! J significance of each violationfofJ the EQ rule, but rather, was 3 required to aggregate the numberfof' violations and I Staff Assessment: l The evolving enforcement policy relative to EQ The staff indicates agrees with thethatview there is i some degree of truth to this concern. (stated above) that PRA may help to place EQ issues in properThe NRC s perspective. for using PRA and other tochniques to better focus EQ requirements and for placing EQ issues in proper perspective.
- 3. Given the state of the art that was in-existence at the time IEEE 323 was developed and the limitations that existed, it would seem that EQ program requirements may have been misdirected (especially with regard to the required determination'of *qualif teddlifeP and the absence of surveillance requirements for obtaining advance warning of significant degradation).
Peer Review Conrunts:
- a. I disagree, -
- b. ~ ! agreal' The concept'Sof ?quilli;fisd;11(e't, stiould,be eliminated altogather, and,emphast: .should 1 Wp), aced'on; surveillance, maintenanceandconditionmo6{toringi
~
- c. The concept of qualtfled lift hit"merlfin anny fe'sp4 cts',' not the least of which, is theiimpact;en knowing which safety systeme are relied:vpon?for foni Theiattai.nmentof beinyfled.
qual life is'hthh. ' .antgergff616 Pro S] f thWrUlspa;; flaw in the origins 1' asstanptions; yafonceritri)iti ief fort ;t'o$no.nttor extit could be equipment's/conditl'on hp i s @l, 'theylt.tionlp)rovides cond detected 4pTheimonitd continued a'ssurance;'th Tife71sibtainable when no I.oh.Vida necessary(feedback,and deterioratlon9Wfound] corrective actionioppo dtpro$h nitle Turianticjpite'dfdegradation"is found. tAihin[advancedMrning'of Non-intrusive lsufveil' lance lf ' erformance'of; component root. significant% degradation *andit cause failure Lanalysesffor' obtaj ing"the. Information' on actual i equipmentdeg'radatich7.areNactlyties:.whichpromisebothsafety and economic payback 1
- d. The NRC s'taff do'es%IWsGd'aTiiifsfhnfiss'istid tbtilicensees a appilcants include surveillance.and7 maintenance as'part of their ,
EQ programs. In fact, the staff. considers an EQ program without a l surveillance and maintenance' component;to be unacceptable. ! However, the surveillance and maintenance insisted upon by the staff are minimum levels of acceptance, licensees are not A-102
, l I
l restricted to these. minimum levels and are encouraged to develop j more comprehansive' programs.TAssyou hav l beanacceptablemethod5cfcomplyinfwi.thctbe.requirementsof'
' J CFR40.49.'IEEE323-1974,nisorprov:desfa"iddentogo.beyondit-of compilance. and . licensees',aresnopferb ,
limits when developing'EQ programstJAs.forKthe: requirement of . detemining' a qualified lifeepto,date..neitheriindustry nor. the NRC
- has found a more acceptab)thsubstitutelfor'dete M or to be installed in'NucleatuPower: Plants. ~
e.N MeritslanalyAicanresolutto ' ' ~~ Weedts?of!!EEE Std 323-74 were notinecessar,il,ylalidt eretthe7best?that'the
'we h&ve .
industry'consensuscould'pr6 duce tPtime M 1owever;d an gainedmuchexperienceLinthetwofdecadessincethen,}onoit'is f importanttoincorporatecurrentdnowledge.InarevisThe! following qualification requirements.also expressed in response to other re i statements: More effort should be directed toward applying the lessons learned 'dur.ingithejjas,t(Ltwo a requirements to reso1V the problem ~of demonstrating"a decadas to. modify qu I me aning fuli,qu al.i fi. ed ili fe' (re : ~ ageconditioning]! l Jo7thCreh reminF 6 iidFlifeisthe testit,gd6d]ehhanced N use of stress OneThit'eWitGe testing' prior.{to't.0CA(oik t T ilj,f, s i condition' monitoring'iniservice [retc state of art I capabilities). , The issu'e'emphaiEssMhEEdihtilhatLhas beanimade by.several . other.tsues' andoprobleeGstite'ments.that"an;' effort is needed equipmentaging)[.to replace:quali itdl1.ifens;a i
- . Operatingaper.ierdesaid;'eMancedIcendttion7monitorin$eare u of among the"a tornatiMthattshould beEconsidered*tri t
it 1 a qualified life [ru ' scheduling'EQ repetitive ma n enance). s The effects of installatio'nr maint'enarice, Land ~ surveillance practices have been addressed only cursorily in the NRC'provided more detailed guidance than"is currently effects of installation, maintenance, and available [re: ; surveillance practices). Tho'suggestidnsC(made Liri. response to otherlissues and l problem'statomentsf that;EQ requirements be reviewed in
- light of the experlence' of, the.last two' decades E0 costs Ire: tight budgetingj.
? re g.
A-103 i ( I
u w a,% . , , .. L.
- Staff Assettment!.
~
d
$~hfh!;fh. w %. .. . . , .,s.
hd.[ ( - d for Given the shortcomings and uncertainties tha the focused attention on maintaining' continued qualification over ftojustify installed life of the equipment, and failure t NRC efforts of the werestaf multiple EQ standards supportslotthe However..a of contention good technical tha NRCwork staff has been somewhat done by the nuclear industry and byto misdirected. both theincorporate decades NRC, in a and the agrees with the view (stated above)lthat it is important current knowledge that has been 9. tined t overd the last twoThe NRC sta revision of the existing qualif kation requiremen s.shou i ce has been A lot of research has been completed and to much d but focused more exper en
- 4. obtained in the area of EQ since 10 CFR i 50.49 continually was issue ,
NRC programs and initiatives apparently do not ex sthis information for equirements. monitor progress in this area and to make use of tr v vww.x.g,. . , Peer Review Commenti: his l
- a. performed ,underkcontractjo'Jhe c
,NRC'sh concern. "d of"tho' previous b.- Meritslanalftid1' resolutionf(ses7coment !
concern)'. I disagree c.' portion of th's ~r sitpthJgfYitimiirQJheSRCWyonsored 'both the btainable afsigni hetearchhohduct4Nintth'ishr,ea,'dand'uses results'of thatiresehcV/sdtal1$pplicable' d experience high o ; minimum acceptable rievelstof?compilanc levels of safety. Staff Assessment: However, except for situations where i current ily This EQ ispractices a valid concern. are perceived to be lacking or improvements inadequate, and it is p Nonetheless, the responsibility of the nuclear industry toid identify alternatives that are desirable and technically h justif that dvances e. the NRC staf f should catalogue and be familiar with tt e ain the area of are being made, and maintain cognizance and expertise Further, the NRC staff should encourage and be supportive o initiatives to improve EQ methods-and practices based on new developments and advances that are being made. l in resolving ; I NRC research activities have not been entirely i d (see the successfu summary
- 5. the " age-old" EQ issues that were initially identifddresses e EQ-of NUREG/CR-4301 in Appendix 1. of the staff's repert that a I TAP Action item 3.d for specific examples). i A-104 I , . . -- - - - - - - - _ . _ _ _ _ ' " - - - - - . _ _ _
- pm qqyypq;p3 y, ; ,
y
.cc w . _
l 1 peer Review Comments:
- a. I am not aware of this issue.
~ e(thatis'currentlybeing b.-
I agree. ,The ongoing literature".reperformed under contra concern, at least partly. .. d
- c. Merits analyticali resolution 4kTh@hndvince1" slosly"within<t emphasizes' the'"piint"that3 , bevtakeh researclimitations'of.: funding 5ff Thisoracogn'f tt'on3hou ;
d theil teehthfiresourcasehereto/4The , new research' programs"statementfalso'4upports'this*rev.lewer!,s I Experimenta1'Research* comment;. faxist'ing
- d. 'If successlcMisured;onlyiinNNai$f'r'eidlV6{ RdT6 problems, ~then"yo0Lare correctFMioweverftresearchkthat)does not provide solutions to'old problems can and often does provide new infonnation about existing problems .or< products. The NRCtresearchI '
activities have been more. successful in providing new information and in identifying previously unknowntlimits in component capabilities. Staff Assessment:
- Research accomplished.
is good to a point but there are limitations to wh l and the information should be well understood and related to specific An further research should: l equipment applications, as appropriate. b) be a) be based on a well defined need for addi lonti information, formation I pursued only if there is a good likelihood that the desired inifc the co ' i will be obtained, and c) be pursued'only'it to public health and safety. justified in terms of the expected benef l
- 6. NRC reporting requirements for EQ-related t problem l plant operation) may not be sufficient for establishing an appropria e j l
' level of oversight. Peer Review'Coad stR
- a. Ilasnottiwars7c~f'thiff'sive!'
l I disagree. If the 10 CFR 50.72;"73 and Part 21, requirements are b. inadequate for this, I don'teknowr what.else can be. . If my ~
- understanding"Is correct l*thersu re ongoing effortstby the.HRC and ~
l the industry to streamline these, reporting requirements either j because_ they are unnecessary l or duplicative, or burdensome. l F c. Merits analytical resolutionjfaiore'NRC oversight may. be needed. l This information statement 1siconsistent sithitheccommon in industrysa'nd;NRCfdata;basesi(such i observation as~ LERs) is not t only deficient but can'be,mislea' ding. l f A-105
i
.If l d. Reporting requirements are inlaccordance with 10 this statement 1: l ,
then specific ^ examples .should be. cited. ;The oversight. ggg g a y,a. l j
' MMad i-. @
..m Staff Assessment: s that j There is a large degree of uncertainty. inherent in the E0 procesfor f exa must be recognized and compensated.for, le size to be d on the testing typically does not involve a large enough samp test results of a single unit), and how equipment wil f speculation. By ise during plant nuclear power plant environmentais?largely'a matter o canarbe understanding and resolving equipment problems that operation, much of the uncertainty inherent in the E0 proce compensated for. blems that are reporting requirements; a low threshold is necessary erging EQ l
deficiencies so that the staff will be cognizant of E0 issues. Generic 7. Justifications for continued operation (JCOs) allowed under letter 88-07 may not be appropriate. P=er Review Commenti: blN.her$
- a. There is "no 'ev'idence'.~0
- b. research focusFltCis'anTindustry/ho'use keep
- c. That is correct. 9.,, -
Staff Assessment: ~ f relief The intent of the JC0 process was to provide lification an during interim period o The when appropriate to allow licensees to establish qua finding of deficient. instances when equipment qualification is found toble be JC0 process outlined by GL 88-07 allows licensees to "make a operability using analysis and partial test idata hen to lified and provide rnason assurance that the equipment will perform its safety funct on w called upon," even though the equipment is supposedly not quaHoweve ith the EQ does not satisfy the provisions of 10l CFR i to E0 50.49. temp rule must ultimately be implemented. be reasonable given the circumstances in general. the EQ and rule uncertaint process does not recognize the need for an exemption from per 10 CFR 50.12. l
- 8. Dif ferences in individual HRC; inspector's EQ licensees' E0 programs.
A-106 l w+e w*
f).; M. m., , j,
.,j;Y^;'ij .
(It was suggested that the NRC'should perform technical review issue safety evaluation reportsJ(SERs) for each qualification test report Issued by a vendor or original equipment supplier, so that licensees would know which test report is considered valid and l acceptabletotheNRCforequipmentqualification.)
~
Peer Review Comments: !
- a. O'.1591 tee?,pe'g'iFdGg'sTii;ia~ctRoj$N8GihWectors ithat ;h'aveivar ;
experience 1eVels. I agree. All human endeavors.afel subject to humanPerhaps failings.the !
- b. '
Maybe there is room for" Improvements;in this area.NR by someone from outside the NRC with knowledge about industry programs. . I evaluationtof.; test' reports, The second item regarding techh ald a ;asfalse sentc9f security - it'siabad4deaM.Will . forgotten'.thattthe amongst?theilicensees? et , ' f;the'p1anthsdVl))' pay licensee is'responsib1 , i the price 'thTthe.andi';notionlyh ' {,th .NRC review,.;but ' any undesirable'consequenceitherefromi L
- c. The same could be said of a11' inspections, not just 'EQ;
- d. During the'.1980ts isH6tfGantly5iofe ' iri d 'doursesSThesedrainingNRCrand indust &peVionn ;
were regularly"attendin EQi ' a minimum'.underi.tandirig?and thebasf courses did/proy,{de)?di fils~591ite) tid levelopment$, providedlfiforumbfor e./ 'Mer'itsyisalptWil'Ms~olst'is@atsigneditoiEQ NRC~ staff'nembepijh' ave'been adtiVities they had no prior,.MillfrityNith(thi<subj'ectCThiNRCTshould assure that inexperf4ncedt staff'are not put .in 'the; position of making safety decisio~ns.before;they'are. adequately trained. The suggestion ofetechni'calire'v%WJ6 fig}ual,1ficattor).; tesl i (presumably;by'quallfladhstaffhmen.its considerationiONhile it l - might not be:.feasibleitoirey;i.e.plj.(taptWeportsbit' 5 mightibe . feasible to d6. s6"onraiselectiMbasistf. perhap's5atfew reports cln each\equipaintd. category $51ncete3testGep~ortimightibelusedul h tj) P heitt s a veral 5di f fo rent / appl ic at.1 on s] .' est raport?demiig)edownersfs
'to Accrif trm2tha responsibility'bcriteriai6Geac theiacceptance . 'ap 1Jch lonfirefnet;
'f.
First of 'allRit"!was#the',,intsti3f,"thENRCJ.t3.beVcon'i,istent as possible in the application'of;the/EQ ruleLHow It dis'our goal howeverb to of the rule wil10sometimes;occut' restrict these differences to the' Ifferences in individual personalities that we all. share in our, perception of the wo.1d live in. A-107
dbrs or i Iecond, the idea of reviewing test reportsEQ isca issuedbit by ven original equipment suppliers is impractical becauseFor to be example, a te more complicated than that. f trate , that demonstrate'acceptabl'eiqualificationf t ..site587! or a particulargitem used in a specific application *it site Af mayisnot. demons
~
same item-is qualified NRC dfor: ais'imilar> s sua sian .SER, application s tating that' .a the si tem /used
'11fthinkthe%itesican;be, Consequently,9 f f.jthe;[Jq{falifle,t qualif ted,0both'esite h?and?si d RC'iflfib51theTother': hand,n6tcq beeause91t'Wat,Tfound a the NRC,s)SERist'athdithattthB They
'e have;thet tytton that
~
rfve'd sitfdepeM 17a'dOlicensees ; bedep%todi exists dal,fida ing{ifi val catn heir 2raspective sites. are resp'oss. ., .x ,~ l Staff Assessment: l of EQ is a very specialized area and requires alevel certain of levesary l i (nor understanding and expertise. 'While a and it is not necesfor training and qualification is necessary. Office should establish and maintain expertise in this are , sial or be resolution of specific EQ problems that are controverdiscussed ff assessment with the H knowledge staff. level of fleid inspectors, should beWith regard of f.9 (below). EQ have not been NRC review and inspection programs relative to For example:' 9. adequately maintained. Peer' Revin"Commiin't5: l M11T.TcodstsisTt'e'dT(fielow). a.
. There!,iWiiMalityjiosQ$thl@(IEo l
{ a'T6i@{oNMff@@)f%b}1'ost)T@o6a9aiTE?b'f ,t b.9 However, some of c. The statementEthat[follhr are* basically true. ? inspections of the
~
the current,iEQi. inspectors:di{j(;taksipartyin the1661uding'S 1980s.j, !nladdifionflthMSRP 4 u processtoffbe{ng1pdated; Staff Assessment: l s published d uncertainty The and implemented, concern there is a was valid a lotone. At the an of controversy time had that the EQbyr been approved associated with the qualification methodology h ical . justification, that The situation the and information staff, multiplein thisstandards area was rapidly existed h evolving.without tec nNRC staff warranted continued focused attention by t e i d through f better understand the information that was be.ing obta ing problems neting plant ex research activities, and to closely monitor opera i and EQ problems that were being identified so thata more ld establish cont nu could be recognized and resolved.. The NRC staff shou t A-108
h
+ ' 9.~;&iQj;; Gfp;.Q ".y, _
- vg.:
-q i
\- focused program of EQ oversight 1byi. (a) establishing and maintaining a high level of expertise in the area of EQ '(b) maintainin l l through research and industry initiatives; (c) developing andd inspe implementing ongoing EQ audit an threshold for reporting of EQ deficiencies so that the staff will be better informed of EQ problems:that are.being iden directing research activities.lf4
- Training / qualification The of HRC inspectors and reviewers relative to EQ EQ inspections were conducted on a one-has not been maintained. l '
time basis and a periodic NRC inspection program has not beenCurrent established and implemented. to EQ issues, they do not receive training on EQ issues and standards. l and they did not participate in the EQ inspections of the 1980s. Pe'er Review Comenth a.'" i I don'tido'ubid t'. _ GsXnstgrion 1(ish'a{f6tenththeistatoments Inithis b'. 7TkIMfi'$Wr!etedp;Vhoweve paragrah?sti oV$h'el,'sXtentithit?tthe'yjmayh :'an
;trung -
action; ylth'eiNRC Wou thafed$ Als6f'idrasponse ; (WWas' expressed: l earlier} issue [the fo Therelhaire?b'eiiEMtiEIis ICshich'NRC'. staff members;h' ave "al'thoughtthef.hhdno. prior hed4t " epij 14 Uhe?NRC?should M suretthat - beengassig/ famillir.it Aft.t suSJ inekp'effencedif rdhidt?) tigl.thWpos'itidnvof making f s afety{ddi sionsWafoSthey^de cadequ ately tt' rained '[rei ' NRC . inspectors',e EQtknoWjedg'e])
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Staff Assessment: See the staff assessment of F.8 (above). The SRP (Section 3.11) is very much out of date and needs to be made current (e.g., the Environmental Qualification Branch is listed as the lead review group; there is no reference tn the EQ rule; a " central file" is referred to contrary to what was ultimately required by 10 CFR 50.49; and RG 1.89 and IEEE 323-74 are not recognized as the appropriate staff guidance documents for satisfying EQ requirements). pes Risf'eWCEmiWt*H i a.' ' T fa y esi
- Staff Assessment:
This is a valid concern. See the staff assessment of f.9 (above). 381, 535, 627, 649. and 650 (and perhaps others)
- IEEE Standards pertaining to EQ have not been endorsed by the NRC.
A-109
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Peer Review Comunents; w.. a a.
~ 1 Merits ' analytical 'resolutionE
_taff Assessment: S See the staff assessment of F.9 (above). 10. The NRC has not provided guidance on how plant data can be used t modify the projected qualified life of EQ components. I Peer' Review Commenti: l
- a. 1; agree. _f iisueTsuchl M i b,
- True(but"'do"se9e211Y/w^a'nt'}%elliRM{$y 1y)iand;a co11ectiv licensees should-develop onedpreferabl .:
implement them consistently. r wIhe.NRCes* input' wouldn't-h ; Maybe IEEE :hould be; called bpon}to do this~ expeditiou see pear: review;commerits elsewhere7ohstotally getting; rid qualified 1,1fe concept; . on7 ((pitiateid%6ieffort:to c.9SNeiitti Wil.1Saddr~pisithejse.'of consid sMjQ1TisoTu popahti As,xpg,f erig ui] f. nB (pf)j$ E. operati ' d.':"If;'thi%hi'1(fidd31Tf'eTof%iliF i IntFhTilti6sifFditeEmihif by 6dd!tryMndTthescomponents1in acieptible"to?b'oth the?NRCda Tthereare quo s ti onTh'avoire achadi thed endto f'4th41'r:r q6aTi fi ed li f ve j oni and b)'p'(two?accep retestlthefcompotientst t abl eipo s si bil .t ki e)(@,( ! J
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Staff Assessment: The NRC staff agrees with the view (stated above) that guidance use of plant data to modify the projected qualified life of toEQ components would best be pursued as.an industry initiative. :Howe the extent that focused attention is placed on operating dplant experience and PRA information, equipment performance, conditio environment monitoring, root cause i assessmen may exist on an ongoing basis, this concern becomes one of m nor importance, Some licensees expressed the view that information Notice 92-81,
- 11. ** Potential Deficiency of Certain'~1nstrumentation and Control C was not well focused and created confusion.
Peer Reviss' ConsneMt'il s Aglin; we should'never forget "th'at
- a. There is some truth to'thih J Hopefully, we human activities are' subject to human failings.
have learned from this. A-110
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I I b.' WHerits'analytica14esolution$1f, colifusion exists, .there .is a. l need for, clarification.yPerhaps morejimportantly, there is a need to answer the questions,: raised a ia: consequence of the fact the/Sandia Nationald.aborjt thermalfaging. Wit;hasbeen - (agingplusLaccidentidoses claimed that thjslprodidur) e pr,ochuce more. cable-degradation than either the ,sequenci%f thsemalf g,ingifollowed ~ aging, and accidentvirr.adiation." ' ' '
- c. '", 'Infdhiali60N5t'fiss$lfchj$iD o,nct i
' require chflin a92-81){he'providedTfor response -
the' edificationfofs.11cen'seesM ned'in' an Infonnat' ion Notice is However lif theithformatjon' con applicable ('to*aYp'arttiGlaQl;igenisee'sjstructures, , systems,Kand components,then.thath'}"f6nsee?ft?expectedtoftakecorrective actions:asnecessary.?tomainta'IDafetylinaccordancewiththe Information requirements of the Code of Federal Regulations. Notices a affected licensees with the flexibility that may be necessary to Specifically, minimize the impact of a potential resolution.Information Plants having N insulation manufactured'by two;spectfic vendors. these cables in envir'onments represented by the test environments failed,j'hodld.conductan,investiglationtoniiFpecess in which the cablas'at determine;;if'() twh gacts HitTeesla Ways, provide an with'that actio M oc[tR(ypay? af censies uld'use'sthe' applicable NRCtechnicalicdn(act cl.ir,Micationfassnecessary. J technicalconta"ct'ltok ,. Staff Assessment: ,[4. . l 1 While it is important to alert'the industry of This is a valid concern. potential problems with equipment qualification, the N about the specific problem that has been identified, 92-81, there was some controversy about the aging sequence that was us l by Sandia. Also, irrespective of failures, under the accepted j methodology a single successful test result provides l conditions the suspect cables were not quallfled for. 12. 10 CFR 50.49 does not define the terms "similar" and "significant" and guidance is needed on how to use these terms. Peer Review Comments:
- a. I am not awarr'that this is'still'an' issue.
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- b. See the enforcementift.1.e'si helone' hand.we, criticize the HRC
- c. Wi"cin't haWII(b5thKaky0$on the'other we want' to prescribe i forbeing'too'preschiptiv4,fand even ordinary and commonly used terms which, in their usage in EQ context, have none other than their dictionary meaning.
A-ll!
- _ _ _ _ _ _ _ _ _ _ __ _ _ J _ _ r __ - __-_ _ - _ _ _ ____
m -w.w. .. ~. w.
- !]g;;.g .;;
I d. Jn HRC/EPRI"diktionary was pNepare'd[td. provide definitions and
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agree on terminology & l
- e. Meritss analyticalJresolution, To'date the'NRC' staff haskiriterprete$the term "stallar" in the l
f. context of EQ to meanf*the!Jame";;the' term "significant" in the context' of 2EQ has been prihiar,11y41ef tAtoith's discretion of-
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l l licensees'and applicants. Staff Assessment: Confusion of this nature is best addressed through industry initiatives. The NRC staff should encourage and be supportive of such efforts. 5_ummary Based on the staf f's review of NRC ov0rsight , issues, the following recommendations were made: a. The NRC staff should encourage industry initiatives to improve ) the state of equipment qualification .and changes in.the regulation (10 CFR 50.49 should be made to facilitate this approach. Specific m for establishing and maintaining EQ should be provid other documents where changes can easily be made (a) b. The NRC staff should be supportive cf' industry initiatives to: improve and streamline EQ requirements, methods, and practices ba:ed ca the knowledge that has been developed over the last h letwo decades; e use PRA and other techniques to better foca place EQ issues in proper perspective. c. The NRC staff should establish a more focused program of EQ oversight by: (a) establishtag and maintaining a high level of expertise Area Of [Ql based on advances that are made through research and industry. initiatives: (c) developing and implementing ongoing EQ audit and insoection programs; (d) setting a low threshold for reporting of E0 deficiencies so that the staff will be better informed of EQ problems that are being identified and better able to recognize and resolve emerging EQ issues; and (e) better managing and directing EQ research activities.
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- d. The one issue that remains to be addressed relative to JCOs i process does not recognize the need for an exemption from the EQ rul per 10 CFR 50.12.
- e. EQ is a very specialized area and requires a certain level of{n r d f
ObbIfkklbbkbh lbh IhIfk$$I; bk I kk k$ 00k YENIfor A-ll2
training and qualification is necessary-and should be provided. Resolution of specific EQ prchlems that are controversial or beyond knowledge level of field Inspectors, should be discussed with the HQ t staff.
- f. Research is good to a point, but there are limitations to what can be accomplished.
The results of past research efforts as well as other insightful information relative to EQ should be catalogued and the information should be well understood and related to specific equipmen Any further research should: - l applications, as appropriate. if on a well defined need for additional;information, b) be pursued only : i there is a good likelihood that the desired information will be obtained, and c) be pursued only.if-thefcost of.research is justified in , terms of the expected benefit.to;publicthealthiand.
. g.yg;9; ,
safety.: While it is important to alert the industry of potential problems with 9 eauipment qualification, the NRC staff should take care fic not to act prematurely before enough is known and understood about the spec problem that has been identified. l
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j , . ,y - i ! G. Miscellaneous Peer Review Comments
- a. The list. appears to have at least t'wo' problemfMfirstdit' presents both sides. of most concerns identifiedi(onithe:one':han' d?'the old criteria, .
- requirementsP~ methodology were;toorrigorous,tprescrfptiveWand ~ onerous; and'en the'other hand,ithey werecno t.~i s t i f fgeno ugh )?.p S econd ;It he ..l i st .
doesn't reflect much study of what was 'donetin$ licensing "a'ndroperating reactor EQ actions'in the 1984289'timelframe!7For"exampleLeground. rules were documented concerning cold'shutdowri,* th'e esc'alated enforcement
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4 actions for 30-some' plant sit'et'inspectionsFintroddced' considerable j consistency procedures addressedwith regard to significant!v(iolations?'and the EQ inspectio PRA for'thesampli,ielection4rocess~. Here's an eximple'of "shst haiWendsn'eTTh"e"FrTnklin ~TERi'of: thi sa'rly I to mid 1980s documented EQ reviews for allr6f'the' master 11st equipment at all of the operating' reactors. 'During' theEQ' inspections,"we found i pood and bad aspects, including the failure of many licensees to ' identify ill equipmtpt requirigg qualification and we built on.the foundationoftheTERs.'Oneofthestrongpoja,li6f.th4TERIWilthat they addressed the plant functional, requirements'for ush component; the component had to be shown to be capable of performing specified functions for a specified environment (i.e., don't ask me if it's i qualified, ask me what it's qualified,for).a;ilt wasn't.over-simplified generic analysis, it was realsworldmihe Franklin:TERs weighed.several
- hundred pounds. Was the information.irnthem' evaluated.asDpartiof
- f ormul at i ng the pre s ent ,11 s t? rSome j offthe ,crj ti ci sms; mi,ght;re ad differently if.'they.were.
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- b. 'IP s too bad'that EQ M s*consi'gned3t' Tinbiffir7i6TainbeirdWibrito the present resurrection'. Continuit w'as<pr' e tt/tthoroughlf disrUptfdi
- and those of us who' plowed thousandt, f? hours into' EQ'infthe.1980s' have discarded and forgotten considerable informationsthat might be
- useful now. ,
[ s s t ..p' A-li4
j April 8, 1993
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j MEMORANDUM f0R: Thomas [. Murley, Director
'. Office of Nuclear Reactor Regulation fHRU: William T. Russell, Associate Director for Inspection and Technical Assessment ! Office of Nuclear Reactor Regulation l' fROM: Ashok C. Thadant, Director Division of Systems Safety and Analysis , Office of Nuclear Reactor Regulation
SUBJECT:
RISK IMPACT Of *0LD" ENVIRONMENTAL QUALIFICATION (EQ)
- REQUIREMENTS f0R ELECTRICAL EQUIPMENT AT OPERATING ;
! NUCLEAR POWER PLANTS l 1 I ] In response to your request, the Probabilistic Safety Assessment Branch ; (SPSB/DSSA) performed a preliminary risk analysis to quantify the risk impact i ! of electrical equipment qualified under the "old" EQ requirements (i.e., DOR j Guidelines or NUREG-0588 Category !! requirements). Due to Ilmitations in i current PD4 models and data, a screening evaluation was perfo-med. The scope i was limited to core damage prevention and in-containment electrical components. Plant specific analyses were performed for two PWRs (Sequoyah and Surry) and The results of these preliminary analyses indicate 4 one BWR (Peach Bottom).
- that the risk impact of "old" EQ requirements is plant specific and could be significant. For an accurate quantitative assessmert a more detailed risk
} analysis is required. Details are included in the enclosed report. I Should you have any questions regarding this preliminary risk analysis, or need additional information, please contact Nick Saltos of my staff at 504-1072. Origir:alsignedby A.C Thadent Ashok C. Thadant, Director ' Division of Systems Safety nd Analysis Office of Nuclear Reactor Regulation l
Enclosure:
As stated , ' cc: w/entlosure ! C. McCracken , L. Kokajko P. Shemanski A. Dummer DJSIRlWilB: ) SPSB r/f AThadant ; BBeckner NSaltos p$ " g f 50418 1(. SUP!K95-128 PDR SP5B:055A SP58:D55A %P5BNS D:055A T NSaltos:rl A[l-Bassioni BBecMkr AJhagani WJRussell 03/ 30/93 03/>c/93 03/y /f3 /4/93 OJ/$3 A:\EQRISK.MEM q 7ncy _ _ _ _ _ . . - ~ __ _ ,}}