ML20206U705
| ML20206U705 | |
| Person / Time | |
|---|---|
| Issue date: | 04/14/1995 |
| From: | Holahan G NRC (Affiliation Not Assigned) |
| To: | Thadani A NRC (Affiliation Not Assigned) |
| Shared Package | |
| ML20206U672 | List: |
| References | |
| FOIA-99-82 TAC-M85648, NUDOCS 9902170290 | |
| Download: ML20206U705 (35) | |
Text
.. .. -. - .-.- - . - . - . . . . - - . - - .- .
e n. mm a n.n.png;w . - ,
5 i UMTED STATIS H -
4 L " '
i NUCLEAR RE0VLATORY.00MMl8810N. .
! WAttilNetoN Disii elm 6,4001 April 14,1996 ,
i j ...
l- HCHORANDUM 701 AshokC.ThadagtAssostate'Otreater for Technica seenment l
FR0Hi Gary H. llolahan Otractor h '
Olvision or tys{ ems infety and- An is a
- e v4 . #
! IUDJECTi RC3ULTI0FTHERIVIEW0FNRGAUp17/N8PECT10NPRACTICt8 i TACuMultta));<,-
} (CQTAPACTIONITEMlie)i(I.Ag.4'-
L?:.'a a . !
As discussed in the staff's invironmental Qualifloation fusk Aciton Plan '
) (tQTAP of June 16 1993 we are performinit 4 environm) ental qualif for s' tete en, eqv prog ammat's review of i i
this regard are spec' catio,n ficplly [Q (de';ined underpetDti htt'on Oureffortsii 1 64i 3 of the tQ "A
! includes the following elemental '
1 3.4 Review License Renewal Background Information 4
3,b Review fire Protection Reassenment Report' l
j 3.c flicitOpinionsfromOthers(Regions,[QExperts) 3.d Review Existing CQ Program Requirements
]
1 j 3,e Review NRC Audit / Inspection Practices i 3.f ReviewLicenseeimplementationPo.etites# ' '
! 3.g finalize Review Results. .h our objective in completing' w4eItems'3.4 th.g & M uisp,4 w -
to identify .;. R -
% % +
t rough"I.flJabove I potential (Q1:suesandconcernsthatmaydeservefurther) staff.concideration.
l It la important to recoanise thaHhis part of our Fogananatta retaw ta not ,
intended to resolve or to otherw se addrest tiy of te (Qissuesthatare identified. After ites: 3.a throuj1h 3.f or tie IQ AP inve been completed all of the to lisues will be conto (datud and inec'fically addressed in the, staff's final report under item 111, 'F'nalise lov'ew Resultsi ' which will .
Include recommendations si appropr ate. !
'.' ,'!.d 1 ,1 ;
- w a g g. , p,.
t AshokThsdani = t=
l ' y m. ,.,
- veg&.;xx.. w .c. -
l The pur) ole of this u m 11 to infore yo that We hAve templeted our review I
alloclaLed with ereWofNRCAudit i ' and ouritem 3.s of the evaluat<on in attac IQ TAP,he for pour. Informa",Unspection fon The i Practices,lisues potential that were ident'f'ed dur ig this reviaW Will be assembled an: I
! addressed in our final report along with tie other potential issues that have
- been identified, itaving completo IQ-i now prepar'ng our final resort whjch Iw;'A' Act'en the evenarlie Items 3.a tirough results of our Q3.f,(we are programmat'sreviewandmauirecommend4ontforaddretningsubst4ntive lisuet, Please contact M 'f you shtu'.s htye t$ quest'ont regarcing tha j attached evaluation. & + - ~ < " ' - --
1 l Atte.chunti j Reviewof(QAudit/InspectionPractices i
i i
l l
l l .-
1 4
1 i
i
)
}
4
l $ . yhhsdkNik 4
Athek 1hadant .t= -
l . ,p i t '-
Thepureoleofthismenoistoinfersyouthatweht,ytgespletedourreview ,
, associated with lies 3.e of the (Q TAP *i eyLew of MRG Audlt\lnspeetten -
Practices ' and our evaluation is attsche for enir inferwnen, The i
- potential, linus that were identified dur gg th a reVlev v ' be assembled and -
1 addressed in our final report along with tie et of potentist issues that havs
- been identified. HavingcompletedIQ-TA'ActionItems3,athrough3.f.weare
- now preparing our final report which wil summarise the results of our (Q
! programmatic review and mate recommendat' ens for addresning substantive lisues. Please contact me if you should have any. quest' ens regarding the j attached evaluation.
l Attachment -
} Review of [Q At;dit/Inspectlen Practices 1 .m m..
t Dl81Ritui10N '
I Central File ;
SPLB [Q file TMiraglia l WRussell
- GHolthan\MVirgillo i CNcCracken Cllubbard
- J1atua '
4 C0ratton j A0ummer CRerlinger. ICLB 4 JWeistol. HICO
- L01shan j (Rutcher l $Newberry t P1hemanskl,PDLR P0tR A[1 lasiloni, IPSO 1 L$hao, RCI
. MVagins, All l JCraig, RCl
, '*See Previous Concurrence g IPL8:051A SPL0iDl5A 00 DilA DIDilA CQratton* Jiatus* illo 4Holahan
- 03/f7/95 04/07/96 NVirg/95 f/ pl y///98
_ , M 48% mbh e%
Attachment
[ r, l' p z RtyltwOfCQAU0lfANDINSPttfl0NPAACTICll. ;
1.0 INTR 000C110N ,
. ..,x - ,
g Asditevisedinthestaff'sinvironmentalQtillifidallenTalk'AthlonPlan (t01Ap of June l6 1993 environm) ental quahl icatie, weehare ti f '
i fer str perfortin e ,programma c 'Our rev'twfforti o cetin paent ett 3.cf,the Q "AP, which thisregardarespecifte1y(tti includes the following e emen Pined un ers _ st' en I
- c 5 sg.'gr e w w. e #w w, w:-: -
3.a Review License Renewal backgr6und Information 3.b Review fire Protection Reassessment. Report 3.c ClicitopinionsfromOthers(Regions.[0trports) l 3.d Review [xisting [Q Program Re819trements 3.s Review NRC Audit and Inspettien Practitet s 3.f Review ttconsee implementation Practites 3.e finaltre Revtow Results This particular evaluation 18 intended to addrett (QaIAP action item 3.0,
" Review NRC Audit and inspectipn Practices," The speelfit objective of this review it to identify potential-erogram reviewing the audits and inspottlent e' ptlt (Q $88 vel.4fd etnterns by-11e subsequent enforcement sken 48.h retuLt e Ahole I ottlent 4 er the '
imptomentatton of the I rules- "hlt il not* Rtthd 0 bt & Comprehent'v4-review of all inspection and enfertteent 4tt'enti ut either a re eW of a sample of reports and background informatten te identify any sign Itant programatic litusi and concerns that pertain to the staff's practices regarding (Q. . .
Ultimately, all of the issues and concerns that are identified during the (Q programatic review will be consolidated and discussed in the final report
([Q 1AP Action item 3.g Therefore, this evaluation does not include specific recomendations). for further staff actions.
2.0 8ACKGROUND The criterta used in the NRC lafety revir~ ocols for all nuclear power plants (NPpi) includes the requirement th. afety=releted electrical equipment must be quallflod to function in harsh environment 6 that at ht occur as a result of detton balls acridents. Aithngh qualification blanda di and regulatory requirements have undergone 640nificant developmenti all currently operating planti are required to Comply w th 10 CFR 60,49 "[nvironment O mitftcation of [lectric (quipment important to lifety for Nuclear Power Planti.' which ensures.that struttures, systems and tempenents important lof
,c. , 1 . .
[ ~
i #$W /E%v ; 4 mC9EMBhu >
< l
} .j c; -
y y j
j s c safet shall be designed to acconenodate the effects of
} htth fhe environmental conditions associated with nemt!nd operation.to be compatible caintenance, testing, and postulated 4ccidents, including .0CAs.
i in the late 1970s, concerns were raised about-the capability of safety i eeutpment to withstand harsh environments, in response to.these concerns. the 4
J staffrequestedthatplantsparticip(atinginthe$fstematic(valuationProgram
($[P) submit documentation on their Q programs. Ihe staff's' review of the i svtmittals revealed that there were no-significant deficiencies with the j licensee's programs that required imedlaue remedial action but that there
! were deficiencies that needed to be addressed. To address these deficiencies, the staff developed and distributed the Division of Operating Reactors (00R) culdelines, a document used by the staff as a screening criteria for reviewing r.perating plants' [Q programs, and issued NRC Bulletin 79 018 requiring that all Itcensees assess the adeauncy of their [Q programs, in May 1980, the Comission issued Memorandum and Order CL180 21 which l established a r :hedule for the staff to issue. safety ev41'Jntion reporti ($[R) i for each operating plant assessing the licenste's compliance with 10 CFR 50 Appendix A, General Design Criteria (GDC) 4. *[nvironmental and Dynamic Defects Destpn Basis." The Order also stated that.the 00R Guldelines and port tons of NUR[G-0$88. " Interim Staff Position on EQ of. Safety Related
.! flectrical [quipment." form the [Q requirements that licensees must meet to l satisfy GDC 4. The Order proposed that rulemaking be used to provide a -
l permanent interpretation of GDC 4.
l The NRC had concerns regardin inadequate res onses to.Bul etin.79-ClB and
! tssued several Orders and But etins to'clarlf their petit on.' B
! the staf f completed their review of licensee responses to !!B 79 018yand midCL!-
1981
! 80 ?), but were unable to make a thorough assessment of the (Q programs l hecause the IIcensee submittals lacked sufficient detail The .iRC 5[Rs from l
thisreviewrequiredlicenseestomakeamorecom>rehensIvesubmittaloftheir i (Q programs. The NRC held extensive meetings wit) the nuclear industry to addrets industry concerns and questions regarding quellfication and to provide detailed information about the format and content of the SER responses.
In 1981, the NRC authortred Franklin Research Center (FRC) to evaluate Itcensee resolution c,f issues from the staff's SERs. and to prepare technical evaluation reports (TERs? for each o>erating plant, The [Q program deficiencies identifled in the FRC I:R Were conveyed to the 11Censee in an NRC SIR for resolutton. Once the deficiencies at each facility were addressed to the satisf action of the staff, the staff issued a final SER to the licensee documenting the acceptability of their [Q program,
! Stellar to the review that was performed.for operating reaClorse the NRC also
' reviewed the [0 programs that were being developed by license appilcants, To prcmote a more orderly and systematic implementation of'the [Q requirements, i
NUR[G-0588, 1[8 79-OlB and its supplements, and other regulatory documents were sent to tha license appilcants for consideration when developing their [Q programs. License applicants provided (Q srogram information through Section 3.11 of their Preliminary Safety Analysis toport (PSAR) and through other clarifying correspondence, The staff reviewed the submittalt for completeness I
L__-______-____-__-_______________--__
l l.
3-1 qualification methods and I and acceptability accident environments.of the The systems staff conductedand on components,ite s audits of each apdicant
! EQ program to verify that the appilcant had established a program tha,' was in i accordance wIth their subutttal. Section 3,11 of WREG 0800, ' Standard Review j Plan,' Revision 2, and NUREG-0588 formed the basis for the overall evaluation
- of the E0 programs that were being established by the Ilconse app 1feants.
! The proposed final rule on environmental cualification of electrical equipment
- was pubitshed in the Federal Register in January 1982, and became effective in
- February 1983. This rule, Section 50.49 of 10 CFR Part 50, specified the requirements to be met for demonstrating the environmental qualification of electrical equipment im>crtant to safety located in harsh environments. The i
rule stated, in part, isat each licensee must ident{fy all equipment within. ,
4 the scope of the rule and submit n/ schedule fo'riitt qualification. The rule j also stated that all EQ components under the scope of the rule had to be fully qualifled no later than November 30, 1985.
The staff began conducting compliance inspections of EQ programs in 1985 to the requirements of 4 verify 10 CFRthat licensees 50.49, had implemented and to follow-up on open items from a program the r meetin]RC TERs, license j applicants' on-site audits, and SER: issued by the staff. Each operating i
power plant participated in the compliance inspections. The staff issued
{
~
1emporary Instruction (TI) 2515/76, ' Evaluation of Licensee's Program for Qualification of Electrical Equipment Located in Harsh Environments," as guidance for inspectors conducting EQ inspections at NPPs.
I A more detailed summary of the development of EQ review and inspection
- practices is provided in Appendix A. Summary information is also provided abc< inspection practices at vendors providing EQ equipment and services to i the nuclear industry, and about NRC enforcement practices associated with the j EQ inspections, h 3.0 EVALUATION OF EQ PROGRAM REYlEW AND INSPECTION.PAACTICES
- m. - .
The objective of this section is to identify potential programentic issues and l concerns in the staff's review and inspection practices regarding EQ. To j
accomplish this objective, the staff: 1) reviewed the metaodology used to and vendor EQ programs, and 2) reviewed j evaluate the results of license appilcant, several EQ program rev licensee,iews, including TERs, SERs, and i inspection reports for operatin reports for license applicants;g and reactors; auditreports inspection reports,forSERs vendors. and inspection 3.1 Evaluation of EQ Program Review and Inspection Methodologies i
Franklin Research ' enter's Technical Evaluation Reports (0perating Plants) -
The staff reviewed the method used by FRC to evaluate EQ program < nfomatuon 4
subattted by Itcensee in response to NRC SERs. A summary of the scope and methodology used by TRC to review the EQ programs of licensed plants during the period 1980-1982 is presented in Appendix 8. Overall, FRC performed a i comprehensive review of the information submitted by licencess in response to NRC Bulletins and Orders regarding EQ. However, the following programmatic h
[
. . , .4
-4=
issues regarding the methodology used by FRC to conduct the program evaluations were identified: , .
t' s The scope of the evaluation did not include mild' environment equipment, coldshutdownequipment,seismicanddynamicqualification,(protection against natural phenomenon, operational service conditions e.g., ,
vibration), outdoor environments, protection.against fire hazards, and 1 protection against missiles. .. l c .
Tne sco>e of the TER did not provide for an evaluation of the accepta)llity of the licensee's stated service conditions for values and profiles.
While the TERs did not address the completeness of the master equipment list.
this was addressed by the staff during subsequent EQ inspections (see below).
NRC safety Evaluation Reports (Operating Plants) - The staff reviewed the method used by the NRC to ensure the EQ programs at plants licensed to operate met the requirements of 10 CFR 50.49. A suemary of this methodology is presented in Appendix C. No issues or concerns were identified re SER process used by the staff to review the licensee EQ programs. garding the NRC safety Evaluation Reports (License Applicant:3 - The staff reviewed the method used by the NRC to review EQ programs at incense applicants to ensure license applicants met the requirements of 10 CFR 50.49. A summary of this methodology is presented in A>pendix 0. The staff followed the guidance in NUREG-0800, ' Standard Review 'lan," for reviewing license-applications.
Because these facilities did not possess an operating Itcense at the time of' the review, and thus did not present an operational safety. concern, the methodology used to review the applicant's~ EQ program was slightly different from the review conducted by the staff for operating plants. The staff's review of license applicant EQ 2rograms included on-site audits (conducted by the staff and contractors) whic.) were comparable in scope to FRC's review of operating plants. A sunnary of the en-site audit process is also presented in Appendix 0.
The staff identified the following issues and concerns relative to the staff's review process for license applicant's:
The documentation seems to indicate that the reviews of license applicant EQ programs were not as comprehensive as the technical evaluations perfomed by FRC and the staff for operating plants.
Section 3.11 of NUREG-0800 was last revised in 1987 and is badly outdated. This document is still used to review EQ programs for new applicants.
MRC EQ Prograa Inspections (0>erating Plant and License Applicant) - The staff reviewed the method used by tie NRC to conduct EQ inspections at operatin plants and license appilcants (for post-licensing compliance inspections)g ' A .
susmary of the methodology is provided in Appendix E. All licensee EQ I
~
.S'-
I programs have been inspected and accepted by the staff per the general guidance of Tl 2515/76.
The staff found il 2515/76 to be a comprehensive guidance docuraent for reviewing E0 programs at operating facilities. The Tl provided specific instructions and criteria for the selection of equipment to be reviewed, for the inspection of procedural and programmatic documents, and for the inspection of E0 documentation files. The TI also provided a series of checklists for use during the review of documentation files and for the physical inspection of E0 equipment (i.e., system walkdowns). The checklists were detailed, comprehensive, flexible (i.e., able to be used with different qualification requirements), and added censisteney to the inspector's review of E0 equipment. A copy of,the il is provided in Appendix F.
i However, the staff noted some problems with the use of TI 2515/76 for both !
operating reactors and license applicants:: '
Il 2515/76 was issued. March 27,-1986 .and. expired one year Iater.
Licensee inspections prior to the issue date used a draft version of the !
T1 and were conducted'in a consistent manner with those inspections conducted after the Tl was issued (See Appendix F. Nine Mile Point I for an example of an inspection conducted prior to March 1986). Even though the Ti 2515/76 expired in March 1987, the staff continues to use the il to perform E0 inspections and as a guide'to perform pre-licensing audits i of license appilcant EQ programs.
7 1
Tl 2515/76 specifies that several E0 experts are needed to properly conduct an E0 program inspection. While many of these specialists can be provided through contracting, the staff must have employees trained in E0 to act as team leaders and team members. EQ training is unique and is not normally acquired during "on-the-job" training. There is no information in the T! about what level of expertise inspectors must have l to conduct E0 inspections, only that they be " knowledgeable",in l electrical equipment qualification. Most of the staff inspectors who participated in the E0 program inspections from 1986 to the present are not available to assist less experienced inspectors develop expertise.
Durint; the E0 program inspections (1985-1987), the staff conducted three-day E0 training seminars to educate inspectors and consultants on the specifics of E0 inspections. 'However, when the bulk of the EQ program inspections were complete, the NRC stopped offering this j comprehensive training on E0 Currently, no formal training is offered '
to educate the staff on environmental qualification practices and issues.
Currently, there is no program in place to periodically perform inspections of licensee E0 programs that have already been accepted by the staff. E0 inspections are conducted reactively, usually as the l result of a problem identified by the licensee or following the failure i of a qualified component.
3.2 Evaluation of E0 Program Review and Inspection Findings
i l
i
.6-To determine whether EQ program review and inspection practices were thorough
) and consistently applied by the staff and its contractors, ten (Q program See Table 1). Inspection reports and inspection evaluations support documents, were such examined as (FRC TERs and the staff's 5ER Ware locluded material examined for this review." Appendix G summartiet the findings from the TERs. SERs. and inspection reports that were: included in this. evaluation.
- % g ? M p 2 4 .8. n < a ' N' l Table 1 EQ PROGRAM REVIEW DOCUMENTATION PRESEEED IN APPENDIX G l PLANT QUAL' STATUS' PLAW QUAL STATUS
$ Kewaunee DOR Oper Pallsaden DOR Oper Nine Mlle Point i DOR Oper Turkey Pisint .1/4 DDR Oper
} Monticello DOR Oper Peach Bonom 2/3 DCA Opet St. Lucle i DOR Oper Nonh Anna 1/2 DOR A Oper Cat 11 Waterford .1 Cat il LieApp St. Lucle 2 Cat i Lie App
- n. r4 p.g.ie m m. tw i. . at Ormug meerine av.dehnes @ mh NURBoelat rewpnry 11 frH th et Coweary I frH n i ' n.. u.... . Lu.. .uio. or m. ri.m .. o. .. ok. so na, wie deveky.d npee ihe ce lie. eppflesen
. ,I im ;jf y f >
~ . '
- l Ooeratino Vt Antt ,
,s /
l The staff compared the findings from'the FRC TER: for eight operating plants to the deviations presented in the staff SERs to ensure'thalithe issues and 4
concerns identified during the program review were addressed by the licensee.
Because of the tremendous number of deviations identified by the staff and FRC l during this process, it was not feasible for the staff to document the
- specific resolution of each issue in an SER. Instead,-the staff held meetings with the licensee and reached an understanding as to how the unresolved issues l would be addressed before agreeing to accept the program. Because the specific issues and resolutions were not documented, it is not clear whether j they were addressed consistently from plant to plant.
The staff's " final SER" accepting the program generally recognized the resolution of the program deficiencies, and specifically Itsted any program deviations that were still outstanding and had to be addressed by the licensee
!' with a " justification for continued operation.' Any open items and i outstanding issues identified.in the FRC TER or :taff SER were addressed by )
- ' the NRC inspection team during the on-site.EQ program inspections. The scope )
and depth of the inspections were compared to guidance provided in 11 2515/76 and found to be satisfactory and consistent across the eight sample plants.
I
I
, ,m4
\ , :p ..- .
- . .q ; r .q,.. '
The staff also compared the scope and depth of the review process for each of
, the eight operating reactors selected for this sample. The staff considered i
several variables when comparing the oractices and findings from this sample j of program reviews, such as when the inspection.was. conducted, who serformed the inspection, what NRC Region the licensee was located in, and otier factors that may have affected the consistent implementation of inspection practices.
Even though the specific findings differed from plant to plant, the process j used to evaluate the plants appeared to be consistently applied at each plant.
l la sumary, after reviewing the EQ program evaluation details for eight i operating plants, the staff concluded that the EQ program evaluations for
) operating reactors were cospleted in a consistent and comprehensive manner.
i However, because of the lack of documentation, it is not clear whether the j staff addressed the r:solutico of specific program deficiencies consistently j from plant to plant.
?
l License Aeolicants
! The staff reviewed EQ evaluations of two license applicants'(Waterford 3 and 1 St. Lucie 2) and the findings are summarized in Aspendix G. The staff eerified that issues and concerns identified in~tae pre audit review of the
- applicant's program, during the on-site audit, and during the staff SER process were communicated to the license applicant and addressed to the satisfaction of the staff before the final SER accepting the program was
1 issued. The staff found that the methodology used to review a license '
i applicant's E0 program (see Appendix D) was applied consistently, based on the j findings from the two license applicant reviews summarized in Appendix G. The staff noted that there were significantly fewer deficiencies identified by the a contractor during these reviews and deficiency classifications varied from i those used during the operating plant reviews. However, as in the case with j the operating plant review process, issues and concsrns identified during the pre-audit review were resolved or addressed by the staff prior to the applicant receiving an operating license. Even though there were 4 significantly fewer deficiencies identified during the license applicant I reelews. the number of deficiencies identtiivd still made it unfeasible for l the staff to document each deficiency and resolution in an SER. Deficiencies were individually resolved during a meeting with the licensee and generally referenced in an SER. Therefore, documentation about how the staff resolved iadividual deficiencies was not available for this reviev. ,
1 I
) Compliance inspections were also conducted at each licuse applicant's l facility after they received an operating license. The staff followed the
- methodology presented in Appendix E to conduct the inspections, which was similar to the methodology described above for operating reactors. Based on
! the inspection reports, the inspections appeared to be comprehensive and comparable in scope and depth to those conducted at the " operating plants" described above.
l l
3.3 Evaluation of Inspection Practices and Findings from Vendor Inspections l
a I
1 i
2_T T T T T Tl~___ T _ T_1 1 X:T L - _ -__.__-_-_ _-__ _-____ ___- _-__ _ _ -_ -
n
'}$ ;P l
The staff reviewed NRC inspection practices for nuclear industry vendors to 3 identify any putential programatic issues or concerns. Appendix H summar 2cs j the staff's review of the methodology used to evaluate vender programs and '
includes a sumary' of the findings from a sample of vendor inspections. The ;
staff determined the scope and depth of the inspections by reviewing i inspection reports and discussing the process with staff who were. involved in ,
the inspections. !
l In general., the vendor inspection reports were consistent with the scope ofi the inspection program. Documentation;fromtthe5 inspections ' revealed a '
consistent approach to inspecting EQ testing programs ar'ainst the requirements of 10 CFR Part 50, Appendix B, and Part 21, Methodologies'used to evaluate test plans and practices were consistant in scope and depth from facility to ,
facility. However, the following programmatic concerns were identified during this review:
1 There is currently no program to inspect EQ testing facilities or vendors. All inspections are done on a reactive b, sis.
- The systematic review of all EQ testing facilities wa.t completed in -l 1986. EQ testing facilities that began operations af ter 1986 have not been inspected by the staff to ensure that their programs and facilities meet NRC requirements.
No NRC inspection document was developed to provide consistent guidance ,
and directinn to the inspectors performing EQ inspections at vendor facilities. General guidelines for conducting QA and Part 21 inspections were available to provide consistency and scope for these inspections, and the IEEE standards and NUREG-0588 were used by the staff to form the technical basis for inspecting the vendor's EQ testing practices, but no programatic inspection guidance was ever issued to ensure the inspections were consistent in scope and depth, i 4.0 EVALUATION OF ENFORCEMENT PRACTICES AND FINDINGS-The objective of this section of the staff's evaluation is to identify potential programmatic issues and concerns in the staff's' implementation of enforcement practices regarding EQ. To accomplish this objective, the staff reviewed a sample of the enforcement actions (i.e., Notices of Violation) that ;
were taken as a result of the NRC EQ program nnspections, or as a result of a l reactive inspection involving EQ. A list of the plants that were sampled and a summary of the enforcement actions that were taken are summarized in Appendix.H.
The staff examined the Notices of Violation and supporting documents for each sample plant, and compared the NRC's application of the enforcement policy at the time to the enforcement actions that were taken. The level of enforcement
{
was compared among the different licensees to check for consistency, and the staff compared the enforcement actions taken with the guidelines in effect at ,
the time to ensure that they were being implemented in an appropriate manner, The staff made the following observations regarding EQ enforcement actions j
that were taken.
1 i
4
.._.-._..__...._.y_ __ .. _ _ . _ _. .. . _ . . _
i L. .
l V .gf :M%W;W4d5~\,4 % -
p,. m ,. v=c ,w-
.- 9' yn l
- In general. enforcement actions th' a t were taken[b[theNtaff were: '.!
- appropriate and. supported by'the documentation in,.the inspection. )
reports.. The staff followed the guidancelin GLs'86-15 and,88-07, as; ' J!
!. appropriate. The nuclear industry claimithatiGLl86-15:was not- .
. .g :
i prescriptive enough and thus:wouldcresultlinithe'staffrissuing excessive ' m; civil penalties that were noteconsistent:withithodsafety' significance of '
the issue was not evident inithe. - enforcementf. actions 1that were reviewed.. :
7 I C The staff identified some apparenttinconsistencies.in the implementation l
- of the NRC's enforcement policy:for EQ-(from GL.88-07) given the relative similarity of the deviations found'during some of the
- j inspections. 1 For example: ,
l (1) At Farley, the staff sought a $450,000 civil penalty for 'l
- unqualified configurations (electrical splices and connectors). found on >
! numerous compcnents and several examples of EQ documentation t'.at did -i not support qualificatien. At Indian Point 3 . thirty-seven components were found in unqualified configurations and the similarity analysis l that was used to qualify the hydrogen recombiners was, deficient, but' the :
staff only sought a civil penalty of $75,000. .. .
, .y;i e y 9 ,r (2) Some deviations from 10 CFR 50.49. such?as omitting EQ equipment. l from the Master Equipment List:(MEL)'or;festallinr equipment [in a ..
configuration that did not . demonstrate;qaljticat' on.2Were. no.t6 .
~
& VM ;
consistently categorized. Safety"equipmenbaccidentally left off the .. )
MEL was a Level V violation at: Brunswick,1a LevelelV.at Indian' Point 3, .
1 and was included in the basis;for escalated enforcement' and issuance of i a civil penalty for H.B. Robinson. While many. factors are considered
- l before enforcement action is taken,' including'the licensee's most recent I performance, it is expected that similar inspection findings would l result in similar enforcement' actions, per:se.. i 5.0
SUMMARY
OF CONCERNS AND POTENTIAL PROBLEMS.
The staff's evaluation of the NRC's review and ins >ection practices pertaining to E0 identified several potential issues for furtier consideration within the- ,
overall context of the EQ Task Action Plan. The issues have been summarized ;
into the following two categories: (a) Review and Inspection Practices -
Methodology, and (b) Enforcement Practices. ,
Review and Insoection Practices - Methodoloav i l
=
The scope of the technical evaluation performed by Franklin Research I Center (FRC-TER).did not include' mild environment. equip" ment, cold shutdown equipment, seismic and7dynamiciqualification~, protection against natural phenomenon, operational. service. condition (e.g.,.
lvibratlon),: outdoor environments, protection:against fire hazards, a'nd-
' protection against missiles, y *
\) 9 s
_ , , _ , , , , . , . , _ , _, , , ~ , _ _ .-
l . .
wp~+y ,
[ ,f, . ::h, % y2,M85 >
> .,.. g; n. .
- The scope of the FRC-TER did not include an evaluation of<the acceptability of the licensee's/ stated service conditions.for values and profiles.
- Th- documentation that was reviewed indicates that the audit of license ap,0icants by the staff and INEL may not have been as comprehensive as the technical evaluations that were performed by the staff and FRC for npersting plants. i
- The NUREG-0800 Section 3.11, used to review an applicant's EQ program, was last revised in 1987 and is badly outdated. !
, o 1
- The staff continues to use Tl 2515/76 even though the document is out of date and was not designed to be used for license applicants.
- The NRC no longer provides training or practical experience in the area of EQ that would prepare the staff to address-EQ. problems at nuclear power pl9ts.
)
- Currently, there is no program in place to perio'dically inspect licensee l i
E0 programs that have already been accepted by'the staff.
- Due to a lack of documentation in their SERs, t is not clear whether the staff addressed the resolution of specific E0 program deficiencies consistently from plant to plant (for operating plant reviews as well as I license applicants).
There is currently no program to inspect EQ testing facilities or vendors. All inspections are done on a reactive basis.
The systematic review of all E0 testing laboratories was completed in 1986. EQ testing facilities that began operations after the systematic review ended have not been inspected by the staff to ensure that their facilities meet NRC requirements. Also, the staff has no plans to I
periodically revisit the facilities that participated in the original round of testing.
No NRC programmatic document was developed to provide consistent guidance and direction to the inspectors performing . vendor-inspections.
Enforcement Practices
- A review of similar violations' revealed an inconsistent application of enforcement actions taken by the staff, possibly indicating a need to clarify the staff's enforcement policy on EQ.
Principle Contributor: C. Gratton
l Appendix A Development of NRC Review and Inspection Practices l
1.0 INTRODUCTION
The criteria used in the NRC safety review process for, all--nuclear power plants (NPPs) includes the requirement that safety-relatedfelectrical.
equipment must be qualified to function;in harsh environments-that might occur ,
as a result of design basis accidents.8 Although qualification standards and I regulatory requirements have undergone significant development,'all currently '
) operating plants are required to comply with 10 CFR 50.49, " Environment Qualification of Electric Equipment important to Safety for Nuclear Power Plants," which ensures that structures . systems and components important to safety shall be designed to accommodate ~the effects of and to be compatible l with the environmental conditions associated with normal o)eration, maintenance, testing, and postulated accidents, including .0CAs, in the late 1970s, as concerns were raised'about the capa'bility of safety equipment to withstand harsh environments, the staff developed two methodologies to review E0 programs and practices at nuclear power plants: one to review the E0 programs of operating plants, and the other to review the E0 programs of license applicants. Also, concurrent with the effort to review EQ programs associated with power reactors, the staff reviewed the )ractices of vendors supplying goods and services to the nuclear industry. Tiese vendors are subject to inspection of their operations under the quality assurance requirements of 10 CFR Part 50 Appendix B and the requirements.of 10 CFR Part 21 for reporting defects and noncompliances.o The staff also-
- formed a group of inspectors to review the EQ testing programs tof those-l eendors performing EQ qualification testing. - ny ,-
l To better understand and evaluate the NRC's practices for reviewing and l
inspecting licensee EQ programs, background information regarding the staff's practices is presented in the following sections.
2.0 E0 PROGRAM REVIEW PRACTICES l #
9a m lina Plants in 1977, the NRC staff instituted the Systematic Evaluation Program (SEP) to determine the degree to which older operating NPPs deviated from the current licensing criteria. Electrical equipment qualification was selected for accelerated evaluation as part of this program. 1. ate in 1977, the staff requested that all SEP plant licensees initiate reviews to determine the edequacy of their existing E0 documentation. Preliminary NRC review of the SEP plant E0 programs led to the preparation of NUREG-0458, "Short Term Safety Assessment on the Environmental Qualification of Safety-Related Electrical Equipment of SEP Operating Plants," which was an interim assessment of the status of SEP plant electrical equipment EQ. Even though the review concluded that "no significant safety deficiencies requiring immediate remedial action wero identified," the staff recommended that additional resources be expended
.to examine E0 documentation and installation configuration of_ safety-related
l l
'A-2 electrical equipment in harsh environments for all operating NPPs. The staff's review of SEP plant EQ programs'also indicated that additional deficiencies may exist related to: ~1)thescopeoftheequipmentaddressed.
- 2) the definition of harsh environments, and 3) the adequacy of sup)orting documentation. To address these deficiencies. the staff developed tae .
Division of Operating Reactors (DOR) guidelines for electrical equipment EQ, 4 which was intended to be used as a screening criteria for reviewing all operating plant EQ programs, including SEP plant EQ programs.
Concurrent with the SEP review program, in 1979 the NRC Office of Inspection and Enforcement (IE) issued IE Bulletin (IEB) 79-01, " Environmental Qualification of Class IE Equipment," to all licensees of operating plants (except those included in the Systematic Evaluation Program). This bulletin, along with previously issued IE Circular 78-08, " Environmental Qualification of Safety-Related Electrial Equipment at Nuclear Power Plants," required licensees to assess the adeqbacy of their EQ programs. SEP plants were excluded from IEB 79-01 because they had already performed program assessments
- and documentation reviews as part of their participation in the SEP program (SEP Topic 111-12. Electrical Equipment Qualification). The staff's review of licensee responses to IEB 79-01 indicated that certain deficiencies also
. existed relative to the more recently licensed (non-SEP) operating plants and i
that the generic criteria developed for SEP plants should also be appilcable ,
to non-SEP plants.
On January 14, 1980, the NRC issued 1[ b 9 018, which included those criteria 1 embodied in the DOR Guidelines and NUREG-0388, " Interim Staff Position on EQ ' {
of Safety Related Electrical Equipment,".and required licensees to provide additional EQ information on safety-related electrical equipment. The 00R Guidelines were to be used as the criteria to evaluate the adequacy of
- equipment qualification, with NUREG-0588 used as a guide in instances where
- the D0R Guidelines did not provide sufficient detail. i t was originally intended that licensees would evaluate their qualification documentation in
- accordance with the DOR Guidelines. However, initial NRC review of this :
! documentation, which was gathered to support licensee submittals, revealed the need for obtaining independent evaluations and for accelerating the SEP plant ,
equipment qualification review program.
In February 1980, the staff and representatives of the SEP Plant Owners Group !
!. held an open meeting to discuss the accelerated review of SEP plant EQ l
- programs in accordance with the 00R guidelines. At this meeting, the staff i j gave the SEP representatives the DOR guidelines and a second document.
! " Guidelines for Identification of That Safety Equipment of SEP Operating l
, Reactors for Which Environmental Qualification is To Be Addressed." The shff i requested that the SEP plant owners review their EQ programs and provide !
.i additional information to the staff on an accelerated. schedule. '
4.,
Subsequently, on May 23,11980, Commission Memorandum and Order Cl.1-80-21 was issued which stated that the DOR Guidelines and portions of NUREG-0588 form
- the EQ requirements that licensees must meet in order to satisfy 10 CFR 50, j Appendix A, General Design Criteria (GDC) 4. In the Order, the Commission ,
- established a schedule whereby the staff was required to issue safety '
) evaluation reports (SERs) for each operating plant, including SEP plants, I
mm-..-,
n .
, m ,
A assessing the licensee's compliance with GDC 4. The staff was to issue these SERs by February 1981, and licensees were required to complete all actions necessary to come into full compliance with the Order by June 1982. The Order also proposed that rulemaking be used to provide a permanent interpretation of GDC 4. Supplements to IES79-018 were issued for further clarification and September, and October of.
definition 1980. Theofstaff the held staff's positionmutings regional in Februaryleensees with l in mid-1980 to discuss the Commission's position regarding the EQ submittals required by CLI-80-21 and IES79-018.
Due to NRC concerns regarding inadeg ite responses to IE8 79-018, the requiring that licensees Commission issuedtoanother comply with CLI-80-21 provide Order in August '1980,information by November 1980.
the necessary ,
The Commission also issued an Order in October 1980 requiring each licensee to l establish a central file by December 1980 for maintaining all _ equipment '
qualification records. ,
By mid-1981, the staff completed their review of licensee responses to '
and issued SERs to most IEB79-018andCLI-80-21(includingtheSEPplants)letocompleteathorough licensees. With few exceptions, t3e staff was-unab assessment because licensee EQ submittals were incomplete or lacked sufficient detail. The SERs highlighted program deficiencies and provided guidance on l'
how the deficiencies should be addressed.. Licensees were directed to submit their responses within 90 days of receipt of the SERs and to facilitate this effort, the staff held extensive meetings with the nuclear industry to address industry concerns and questions regarding qualification. The staff also provided licensus with detailed infonnation about the format and expected 1 content of the SER responses during these meetings, i in late 1981, the staff authorized Franklin Research Center (FRC) to evaluate licensee resolution of outstanding issues related to EQ discussed in the staff's SERs and to prepare a technical evaluation report (TER) for each of the operating plants. The objective of this evaluation was to: 1) identify all cases where the licensee submittals did not resolve the significant safety issues, 2) determine which equipment had adequate documentation and which did not based on established criteria, and 3) evaluate the adequacy of qualification documentation for equipment located in harsh environments that was required to be installed by NUREG-0660, 'NRC Action Plan Develo>ed as a Result of the TMI-2 Accident.' FRC issued a TER for each licensee >ased on a review of the licensee's EQ program.-
These TERs ultimately became the basis for the staff's safety evaluation for each licensee's EQ program. The deficiencies identified in the TER were reviewed by the staff and included in an SER to the licensee, with the TER included as an attachment to the SER. The staff met with each licensen to address the licensee's EQ program deficiencies. Once the 'EQ yrogrr deficiencies were addressed to the satisfaction of the ibff end A.tsM ;.bl e schedules were established for resolving the issues, tir s">'F ..culd Iaut a final SER documenting the acceptability of the lictuse* M EQ progr*s.
The proposed final rule on environmental qualification of elettri;al mtpment was published in the Federal Register in January 1982. T is Nle,' Section
{
_w______. - - _ -_ - _ _ . - - _ _ -_____ _ _ _ _ _ - _ _ _ _ _
i l
A-4 !
I 50.49 of 10 CFR Part 50, " Environmental Qualification of Electrical Equipment l Important to Safety for Nuclear Power Plants," specified the requirements to !
be met for demonstrating the environmental-qualification of electrical l equipmentimportanttosafetylocatedinhars% environments.rThe.rulestated, ,l in part, that each licensee musttidentify alliequipment Within'the scope of l the rule and submit a schedule for'its qualification, The rule became effective in February 1983. The rule stated that all EQ components under the scope of the rule had to be fully. qualified no:later than November 30, 1985.
License Aeolicants Similar to the review that was performed relative to operating reactors (discussed above), the NRC staff also reviewed the EQ programs that were being established by license applicants. Commission Order CLI-80-21 imposed the requirements of NUREG-0588 on the license applicants and in order to promote a more orderly and systematic implementation of these requirements, NUREG-0588 was sent to all license applicants in December 1979. Other applicable regulatory documents, such as IEB 79-OlB and its supplements, wc.c also sent to the license applicants for consideration in developing their EQ programs. a License applicants provided qualification program information to the staff, typically through Section 3.11 of their Pre!!minary Safety Analysis Report (PSAR) and through other clarifying correspor.dence. .The staff reviewed these '
submittals for completeness and acceptability,ofc qualification methods, and accident environmentM)he systems.
$ection 3.'11and components, of NUREG-0800,'
" Standard Review Plan " Rev. 2 (1981), and NUREG-0588 formed the basis for the overall evaluation of the EQ programs.that.were being established by license applicants. ,,
]
Included in the staff's review was the on-site audit of the applicant's E0 program. With the assistance of the Idaho National Engineering Laboratory (INEL), the staff performed a review of the applicant's EQ program similar in scope to the reviews that were performed by FRC of operating reactors. Prior to issuing the final SER accepting the program, the staff would conduct the on-site audit to verify that the applicant had established a program that was in accordance with his submittal. The on-site audit was not considered a compliance inspection because the applicant typically did not have the entire EQ program in place at the time of the audit, and the program had not been formally reviewed and accepted by the staff. The audit team would review a 4 small sample of EQ equipment files (typically 10) and perform a walkdown of the components contained in those files to ensure the EQ program was being implemented per the stated requirements. INEL would prepare a report of the issues an.d concerns identified during the pre-audit review of the program material and the on-site audit of the applicant's program. These issues and concerns were conveyed to the applicant and rectified prior to issuing the operating license, unless a justification for . interim operation was agreed to
~
by the staff.
l t - - - _ - - - - - - - - _ - - - - - - _ _ - - _ _ _ _ _
- -. . . ~ . . - . .. . - . -
. . ., ;.c . , :y ylghyg9 - .
k;W,khhbf5h . $' * $ 'i
'A-5; jd>. 3 ' .
3.0 EQ PROGRAM INSPECTION PRACTICES.
- Nuclear Power Plants ;. ,, j, i
Starting in 1985, to verify that licensees had implemented a program meeting the requirements of 10 CFR 50.49, and to follow-up on open items from the T Rs that were issued by FRC, applicants' site audits..and. unresolved issues i documented in the SERs that were issued by the staff, the staff conducted compilance inspections at each facility.
The staff developed Temporary Instruction (TI) 2515/76, " Evaluation of Licensee's Program for Qualification of Electrical Equipment Located in Harsh Environments." as a guidance document for conducting the on-site inspections a at those reactor sites that were operating during the develo) ment of the EQ rule. The staff also applied Tl to those operating plants t1at did nnt have an operating license during the development of the EQ rule (i.e.. -the license-
- applicants). The objectives of the EQ program inspections were to
- 1) verify i that EQ files contained the appropriate analyses:and-other necessary documentation to support the licensee's qualification ~ conclusions,-2) ensure that maintenance and surveillance programs for qualified equipment were s
adequate to assure that this equi) ment was maintained-in.the as-analyzed or i
tested condition, and 3) verify tie > implementation of licensee commitments and actions that were described in written responsesetoFthelstaff's'SERs~(and' ~
TERs) or during meetings with the staff.- The first. ten inspections were conducted on a team basis, with members of the headquarters. staff (typically from the Vendor Inspection Branch) leading the inspections. Other team members included regional inspectors and consultants.- All subsequent inspections were conducted by the Regional Offices, with support provided by headquarters inspectors and contractors..
Vendors
- in addition to inspections of operating reactor and license-applicant EQ programs, equipment and service vendors supplying products to the nuclear industry were also inspected by the staff's Vendor Inspection Branch during
- the early and mid-1980s. The objective of the vendor inspections, defined in Inspection and Enforcement Manual Chapter 2700, was to provide reasonable assurance that the products and services sold to licensees in the. nuclear industry by non-licensee organizations met NRC regulations. The staff i inspected vendor facilities to ensure that vendor. programs met the quality assurance provisions of 10 CFR 50 Appendix B, as required under 10 CFR 50 Appendix B, Criterion IV. In addition, the inspections included a review of the vendor's 10 CFR Part 21 practices,for, deal.ing(wi.th..componentidefects and -
nonconformances. ,, ,
Under the vendor inspection program in the early 1980s, all of the nuclear steam system suppliers and architect engineering firms having active contracts in the nuclear industry were subject to regular inspections. Selection of vendors providing products and services for inspection by the staff and the frequency of the inspections were generally based upon the safety importance and the quality of the product or service being supplied, along with the vendor's performance history. It was the goal of the Vendor Inspection Branch d
e i .
37
. M a +:-
[. k; . - ,
- www .
n.e - . - -
1 4
A-6 to inspect as many vendors as resources would allow during their two-year
, inspection cycle.
I In 1981, the Vendor inspection Branch formed a new Environmental Qualification Section to specifically address concerns surrounding-the testing of.
environmentally qualified electrical equipment being supplied, to the nuclear industry. Each supplier and laboratory. performing 9EQ: testing;of4 electrical ?
equipment covered by 10 CFR 50.49 was;. inspected over'aTthree; year period. The
! staff stopped performing these inspections in 1986.after all testing 4
facilities had been inspected at least once..
. . , .x 4
4.0 EQ PROGRAM ENFORCEMENT PRACTICES:
4 The deadline for compliance with 10 CFR 50.49, " Environmental Qualification of
. Electrical Equipment important to Safety for Nuclear Power Plants," was specified in the rule as the date of the second refueling outage after Harch 31, 1982, or March 31, 1985, whichever was earlierc Some plants received deadline extensions to November 30; 1985.
In August 1985, the staff issued Generic letter (GL) 85-15. "Information Relating to Compliance with 10 CFR 50.49," to remind licensees of the deadline for meeting the requirements of 10 CFR 50.49 and to inform them that
, extensions beyond the November 30, 1985 deadline would only be granted in rare circumstances. Licensees without extensions approved by the Commission.that
! chose to operate with unqualified equipment beyond the deadline would be
- subject to enforcement actions. To emphasize the seriousness of being in non-compliance with the new EQ rule, GL 85-15 stated that licensees will pay civil-penalties of $5000 per day for each day of noncompliance after'the deadline.- ,
for each unqualified equipment item. However, GL 85-15 did allow for some
- mitigation (or escalation) of the civil penalty, based on.several factors
=
Had the licensee identified and promptly reported the noncompliance?
Had the licensee applied best efforts to complete EQ.within the i deadline? -
=
Had the licensee proposed actions which could'beDexpected to result in ,
full compliance within a reasonable time? ,,
Each of these factors c N J be used to mitigate or escalate'the civil penalty.
However, no clarifying instructions were given on how to implement this guidance at the time GL 85-15 was issued.
, in September 1986, in response to questions raised by the nuclear industry, the staff issued GL 86-15, "Information Relating to Compliance with 10 CFR i
50.49," to provide additional guidelines on appropriate licensee actions in situations where environmental qualification of equipment is suspect and on the current NRC policy on enforcing EQ.
The following guidelines were set for licensees who discovered a potential deficiency in E0 of equipment: ,
e Make a prompt determination of operability.. .
yp i[
a 3-
.% 3 Ms. -
%(& .
.yy , y : n y m s y ..,
d&5.+h
^
~ .,
~
Q % N W 4h $ $$$ki&G
&,- M et9 h f f Ww&:
]?E$$ ? @$ ' ? ? ?. 1 l
I A-7
- Take immediate steps to establish a plan with a reasonable schedule to ;
correct the problem. -
- i Have a written justification for continued operation.(did not require
..n73 qq&@-A y We . ,a '.
NRC review or approval).x . , ,
.3
~& h .m . .
.+ . r In addition, if the licensesNaP"unkbleit'o' demo ~nstHkup' era:bility' and the N " '"
equipment was covered by plantitechnicalespecificationsPthe licensee' was -
required to follow the approprlate actioncstatements in.the technical.
specifications. Otherwise, the 1.icensee could3 continue operating using limitedadministrativecontrols;,tolersur6thesafetyfunctionwasperformed, or by ensuring that the equipment's' ufety function was accomplished ~by other designated equipment that was;qualifled.s.. .t'M . +
4.s 7 a. . . .m. . . ., i GL86-15alsoincludedanenclosure;withexamplesthatclarlfiedthe application of the " Clearly Knew,or Should Have Known"! test , the time ~ periof to be considered far daily civil penaltiest and;how to apply the mitigating' factors to determine the amount-of'the ;,r a osed penalty..
In April 1988, the staff issued GL 88-07, " Modified Enforcement Policy Relating to 10 CFR 50.49, " Environmental Qualification of Electrical Equipment important to Safety." The E0 enforcement policy was revised because the j Commission found that the policies established in GL 85-15 and GL 86-15 could result in penalties that did not reflect the safety . significance of the violation, when compared with otherinon-EQ penalties that were being imposed.
GL 88-07 superseded the policy established in GLs 85-15 and 86-15, and made.
five major changes to the EQ Enforcement Policy that"had been' established by ?
GL 85-15: 1) it aggregated significant.EQ violations ~ rather-than keeping them separate, 2) it assessed a base: penalty according'to the number of systems affected by the unqualified equipmentc3)itt established a maximum fine of,
$750,000, () it established a~ minimum. fine ~off$50,000 for'significant EQ violations,and5)itconsidered/mitigationioriescalationlofthecivil'penkity based on several factors (e.g.,7 identification and(reporting,Ecorrective .
actions, duration of the violation, etc.)./ m Included with GL 88-07 was an enclosure.~to' provide details'and examples on the modified policy for EQ enforcement F The enclosure was.dividedKinto four "
sections: (1) Scope, (2)' Applica' tion 7ofathei" Clearly Knew, or Should Have Known" test for violations that existed before the November 30,.1985 deadline, (3) Violations Not Sufficiently,Significant to Merit a Civil Penalty, and (4) Basis for Determining Civil Penalties.
Full mitigation was allowed for those licensees in violation of 10 CFR 50.49, who met all of the following five criteria:
violations were isolated and affect limited systems / components.
violations were identified.by.therlicensee,- " ,
violations were promptly reported,
' A test to determine whether (ne. licensee knew or~should have known they-had equipment for which qualification:could not be: established by. the dead 1H established in 10 CFR 50.49.- -
'/ " ~<
]jer.A",s'ph ~
l
.7 ,. '4., d Y.T
- f 3+ , "'w' . ,
j j
_ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ __ ---- - - - - - I
- w. ~:,,.H ayo.g.5p:
..,4..<.. . ,
.c
%S-
? x,.$. f ? -2a.5; $.: .Q.
'4. $.~, . #n. $ Q W 3 'i h
g'
[:g.ps, ax ? g .p y g p; g :.p p
- .2... A 8! . . '
, c; , .
- violations were corrected'Nithin N eIso'nablE time,Nriod', and ~
violations for which the. licensee has: demonstrated )est efforts to complete EQ within the stated deadlines. -
, +.s . . iv .~ . .
- The decision to allow full mitigation for those violations meeting the five i criteria above was deemed appropriate in order to remove the disincentive for
- licensees to report E0 viciations found during their internal audit. and i inspection practices.
x . a: .
i y;, .
c,* . , a ._
a
- ; '. : g w.,
I[j ', 'f b <, ,
- t.; .
.,_ . . . j
- e Q4.y \lr O ~ _ {}h;'{py'sf*ah-k%9e. *!D <?l W' ' ' ' $-
- t. :.
.'.: 4 ,. 2 t
/.,
"p's,,
w ,'
o f
i i
- f W.-
j ','
ji "fgba e' 'f . 'N ,
?t '*_ .f
,3 ik.
i
_ _ _._ _ _ _.- _.-~.- - - - - - - ---- -
J% %;: *
. )#
j l'
&& 9&[X.E&&al%%& '
p _
Y"* *f
]
L. .
, Appendix 8- ,!
.a
.b- U
]2 ,.
([' [
Technical Evaluation Re ortss ah M e '
aagi j ' Backgr,ound,
,, ggfg gjfjggg y ..
l Technical Evaluation Resort (TER) eve nament A :;.p s m M - '
- ].+
- In December 1977, nuclear power plants part{cipating
- inithe Systematic -j Evaluation Program (SEP) were requested to review their equipment !
j qualification documentation to determine its' adequacy. The resulting- ,1 i submittals were reviewed by Franklin Research Center FRC) and a TER ~.l
! documenting the licensee's EQ deficiencies was pre are(d for s&ch facility. 1 The staff prepared a safety evaluation report (SER to document the
! qualification documentation deficiencies and forwa ed the SER'and the TER to j!
< each licensee. + 0W ,
i
(
In 1980, all licensees of operating plants (except those participating in the .i SEP program) were required to examine their initalled safety-related ,
i electrical routpment and ensure that sufficient' qualification documentation
- existed to demonstrate that the equipment would function under postulated '
I accident conditions. By mid-lg81, the staff completed their review of the . , ,
licensee submittals and issued SERs,for each operating reactor. 7The SERs- <
T l required each licensee to respund to' the deficiencies identified within 90 s 4
days. FRC was again tasked with reviewing theilicensee: responses and
! preparing a TER for each fact 11ty.WEvenAthoughdheeSEP4 plants;hadralnadyW,Ow ?w '
i made an Initial submittal and'underg'oneT review bhFRC;1the ' staff 2 requested . .e :
li that they submit their EQ program inform &ti6n'andtincluded the'SEP plants:in ' '
this more comprehensive review. FRC reviewed the EQ information that was '
4 provided by the SEP plants and prepared TERs to'documentLthe results of their reviews. The final SEF-plant TERs were based on.(1) the results of the
initial TER, and (3) the licensee's updated electrical .equipeent quitfication l
! (EEQ) submittal. The TERs for non-SEP plants were based on each licensee's q l updated EEQ submittals and response to:the staff's SER. ,
. .y . 7 4.
im .e, .
-4 1
{'
The following paragraphs describe the scopiaridlcelhodologf used by FRC to . L :
develop the final TERs. Final TERs were issued for all' operating plants, 1 including those participating in the SEP program. The initial itRs for the l SEP plants were limited reviews and their results were reflected in the final TERs for those plants.
Purnose and Scone .
The purposes of the FRC review were to: 1) evaluate the licensee's resolutions of outstanding issues related to safety-related EQ.equfpment' andildentify : 9.@ 3 where:the 1icensee's'respu.aes did not resolved thetsignificant~ qualification m. .
issues that were identified, ^2)--evaluate'theilicensee's' documentation and ' i determine which equipment had' adequate'EQ do.umentation and which did not, 3). '
evaluate the licensee's EQ documentation.of; equipment identifledtin- r
- NUREG-0737,."THI-ActionPlanImplementation,0and4)~ determine'whetherthe-- * .
licensee proposed adequate corrective.. actions to resolve qualification j p ?
l x ;
.l p :, e A '4L'. cf' 'P~ A!' '
-l
, +
< ~
y w
u___ _ _ _ . _ _ _ _ - _ _ _ _ - _ _ , _ _- ~ __ - _ ~_, ,
- ~
i l
l l
l 8V i deficiencies and provide a schedule for the comhletion of the corrective l actions.
1 i The scope of the FRC review was limited to evaluating the qualification of I
equipment that must function to mitigate the consag ences of a LOCA or HELB whose environment was affected by the event. The scope of the review also i i i included equipment in NUREG-0737 but was limited to equipment having an
) installation date prior to January 1,1981 (although equipment installed after l January 1, 1981, was also reviewed in cases where adequate information was :
i provided by the licensee).
- The scope of the review did not include lld environneritN idf N or cold j shutdown equipment. Technical data or test results that?satt ed the i qualification criteria were not discussed.- Other aspects-of qualification
! that were not included within the scope of the FRC review were:
1 i e seismic and dynamic avalification 1
- protection against natural phenomenon operational service conditions (e.g., vibration)-
outdoor environments
- e protection against fire hazards * '^ #
l
- protection against missiles j in addition, the scope of each FRC review did not address: 1) the completeness of the licensee's master list, or 2) the acceptability of the licensee-stated service condition values and profiles. The completeness of each licensee's master list was, however, verified in later NRC-lead EQ program inspections.
l Review Methodoloav i
i The relative completeness of each licensee submittal was reviewed by FRC using j the following NRC-supplied bases:
determine whether the licensee responded to the NRC concerns documented in the SER, -
determine whether the licenses proposed corrective actions for the deficiencies, including a schedule for completioni e
determine whether the licensee addressed the NRC's concern for margin for containment environmental conditions.
detemine whether the licensee revised the environmental parameters.
- determine whether the licensee's System Component' Evaluation Worksheets were updated to correct deficiencies, e determine whether the licensee provided justification for interim operation for all unqualified equipment, and determine whether the licensee addressed aging and .corporated the results into the equipment maintenance program.
~% a '
, g. .
.g >
- p: u .;sa wn + , t.
.; .. .. A .,. ,. '
,c., ,g. m B-3 4 -sa Q4 % 4 . - .. .. ,
'd Eachlicenseeanalyzeditssafety-relatedequh"dnt~andgroupeditinto
' equipment items,' or groups of identical equipment that were exposed to the ,
same environmental service conditions. The FRC TERs included aspendices that a) listed the environnental service conditions for each applica)le plant location, b) contained the tabulation of the equipment items, locations, required operating times, function, riant 10 numbers, and applicable qualification documentation references, and c) listed the plant systems identified by the licensee and the NRC as being essential to safety. .
l For each item on the equipment item. list, FRC reviewed: !
= the licensee's response to the NRC SER deficiencies, a
the technical information received from the licensee's submittal or as a result of requests for additional information.
NRC DOR Guidelines and NUREG-M88 Revel cr.iteria, _.
+ the licensee's definition offharsh service environment,-
a documentation cited by the:licenseeins evidence of qualification,
. applicable and available qcalification documentation associated with the overall equipment er.vironnestal qualification program, a
th2 licensee's analysis and justification of qualification, licensee-proposed corrective actions for qualification deficiencies, the licensee's equipment and part replacement schedules, !
l e
the licensee's technical arguments concerning the adequacy of equipment, l based on system operational considerations, and a
the licensee's rationale concerning exemption of equipment from i qualification.
TRC also included an evaluation of the equipment included in NUREG-0737. The
- objective of this review was to evaluate the qualification documentation of equipment within the scope of IEB 79-01B, Supplement ~3, in a manner identical l to all other safety-related equipment-located in harsh environments. The i scope of the review was limited to
- TMI Action Plan equipment associated with l those sections of NUREG-0737 which had equipment installation dates prior to January 1, 1981.
To assist FRC in the review of each equipment item, FRC developed checksheets that contained the various screening criteria required by the NRC. The checksheets contained the following information:
e equipment item information (e.g., licensee ID number, location, etc.)
. qualification deficiencies identified in the NRC-SER l
,, . - mg.9 -w .m gzt.: , . w. e
+ . . ;g ;. 1: : y. ,,
. %<> y.p. . ' , y . .1 -
B-4
- the licensee's response to the NRC-SER licensee's statements and y:: rationale for.q;ual.ification__
w c n y >., x n l
- licensee's corrective actionsland feplac6 ment 1.Achedules: -
i L%my,, 2;h:Mw . % ,
evaluation of qualification)inc1'uding identification.of.all deficiencies
- evaluation of systes. considerations presented by the licenses as a rationale for excluding equipment from qualification The results of each equipment ites evaluation was summarized'en a final checksheet, which identified any deficiencies and indicated which NRC- !
developed qualification category.the equipment was assigned to.~ ;
,9 yo . .:]
Tne NRC provided FRC with ' Qualification Categories" as part of the evaluation program. FRC was instructed to >1 ace each equipment item in one of the following categories, based on tse evaluation of all available qualification information.
Category 1.A - Equipment that satisfies all . applicable requirements of the_ !
00R Guidelines or NUREG-0588, or the licensee has presented' information to determine that deviations from the criteria are acceptable c: insignificant'.i For. example, Palisades - '
ended their 1.0CA testing to..thez30 Jays post-accident
- period. The Itcensee' jusifie $rior,dMdinf the test early (after. '
l 14 days) because*the equipment %s'stt11' functional after the test parameters returned to are-accident levels 11 days ;
l into the post-accident period. d RC. reviewed the licensee's '
l justification and; agreed.~. a v.s.i., v -
Category 1.8 - Equipment for which deviations from the DOR Cuidelines or NUREG-0588 are judged conditionally acceptable provided that l specific modifications are made.; Examples of modifications include: replacing unqualified equipment with qualified equipment, modifying the equipment to' meet the criteria, relocating the equipment to meet submergence requirements, etc.
Category ll.A - Equipment for which qualification documentation is
- insufficient to establish that the equipment is or is not l
qualified in accordance with the DOR Guidelines or NUREG-0588.
Category !!.8 - Equipment that is unquallfled. ,
Category !!.C - Equipment that satisfies all applicable requirements of the i
D0R Guidelines or NUREG-0588 with the exception of qualified' l life (for DOR equipment component replacement schedules discussedintheguidel!neswereconsideredthequalified life).
l j
g>. . ~ , aww . r
. 2
- fy.$y$i ? kM&$$i?:$.&"
y0LlJ,d llM. 'T $$Y ~ * ~ SYC
?
" ^
,T.,.. -r ,
^
. :y g,g.
gtQ.- >;-.'.,, - --
Category Ill.A - Equipment that is exempt from qualification (e.g., does not provide a safety function, some other fully qualified equipment that is single-failure proof can provide the safety function).
3 Category III.B - Equipment that is not in t.he scope of the qualification m
R review (i.e., cold shutdown and mild environment squipment).
Category IV - Equipant for which qualification documentation has not been -
made available for review, In addition to providing the NRC with the list of equipment ites; falling into each of the above categories, FRC also deficient in the following categories (grouped equipment items that werean equi or more of these groups). The criteria used to determine whether the documentation was deficient Wat contained in the. applicable requirements document for that Itcensee (e.g., DDR Guidelines, NUREG-0588 Category 11, etc).
and au mented by the information provided by the staff in supplements to IE Bul etin 79-01E'. L
} . . 5:L . .% o
- 1. Documentedevidenceof.[inadequatequalification.
l 2. Adequate sinilarity between equipment and test specimen was not established.
- 3. Aging degradation was not adequately evaluated.
- 4. Qualifiea life or replacement schedule were not established
- 5. Program to identify aging degradation not established.
- 6. Criteria regarding aging simulation not met.
- 7. Criteria regarding tempart.ture/ pressure exposure (EQ testing) not met.
- 8. Criteria regarding spray not satisfied.
- 9. Criteria regarding submergence not satisfied.
- 10. Criteria regarding radiation not satisfied.
- 11. Criteria regarding test squence not satisfied.
- 12. Criteria regarding analysis of ten failures or severe anomalies not satisfied.
- 13. Criteria regarding functional testing not satisfied.
- 14. Criteria regarding instrument accuracy not satisfied.
- 15. Test duration margin not satisfied.
- 16. Criteria regarding margins not satisfied, These deficiencies were reviewed by the staff and forwarded to the licensee with instructions to address each of the deficiencies that affected the qualification of the equipment ~ itert
,..c .
- m -
,r
. Opw mghhh+my.# * -
N4
- n. s. -
.~
i a+c. % ., ep/7 a. .1 ..
"AppendixLC ~
+ . w w. .s e _
{
3,,
ix,
?..
< j w:g gyn .
}l :n safety Evaluationsneportsifor/ Operating: plants m -'
.1:
35 cope;andysthodologyp* * -
= sg.a , .ncmp-
- l ,
After reviewing the Franklin Research CentarMRC)' technical evaluation report (TER), the staff would document the finding 'n a safety Evaluation Report i (SER) and forward the $ER and TER to the l'consee. The licensee was given 4 time tn review the staff's SER and provide a formal response to the '
deficiencies that were identified. Subsequent licensee submittals were then i reviewed by the staff and a final detemination was made about the acceptability of the licensee's program. 7 Methodoloav The staff's acceptance of the Itcensee's CQ program was based on the results of an audit performed by the staff of t 1) the licensee's proposed resolutions ;
the Itcensee's compilance -
todeficienciesidentifiedbythestaff'sSER.D2) with the requirements of 10 CFR 50.49 and 31 the licensee'sjustificationfor ,
continued operation (JCO) for the. equipment /tems;for.which qualification had not yet been established. - o ? Y ;"." -
Licensees addressed each SERjef,1c[encyyttyg{on%ot.noresafethe fo110 wing!" <'
replacement of the deficient equipmenfitMP "^' ' ' '
] ,
a additional analysis ..
+
additional qualification documentation not review by FRC-a reclassification of the equipment item such that the requirements of 10 CFR 50.49 did not apply n Deficiencies were typically diteussed item-by-ites during a meeting between the staff and the licensee untti agreement was reached on the resolution of all defielencies. Analysis and documentation deficiencies were not included in this review, but were followed-up during the subsequent site inspections by the staff.
To ensure the haster Equipment List (MEL) was complete and met the requirements of 10 CFR 50.49 sections (b)(1), (2), and (3), the staff completed the following reviews:
Forsection(b)(1)t'~safetihrelatMel '
hNb ktilhbunt" The staff reviewed the design basis' events considered by the licensee when selecting safety-related equipment,'the licensee's e utpment selections based on the infomation given in.10 CFR 50.49 b)(1), and the Final Safety Analysis Report (FSAR) Technical Specificat ons. Emergency Operating Procedures (EOPs), piping and instrumentation diagrams, and i other procedures and references.
i_ . _ _ _ _ _ _ _ _ _ . .
l , p t<. , . n 's . ~.p..
e hL. ., .
.w.
_. .a , f:7.m .
l ,f ,,
l '. .
C.h -
.i'.
l
- For section (b)(2): non-safety equipment whose failure under accident l conditions could prevent the satisfactory accomplishment of a safety l function ,
l The staff reviewed the itcensee's selection of non-safety. equipment for this category to ensure that adjacent safety-related equipment Was '
! electrically isolated by properly coordinated protective relays, circuit
- breakers or fuses. Operation of all support
- systems end equipment.
l includin room venttiation and co onenticoo.11pggthetiwerte..directly,or 6 -
3 indirect y connected to safety eq poen greIgd gy . ;
j
- For section (b)(3): certain post accident monitoring equipment
- 2,.. ~
y -s .. -
l The staff reviewed the Itcensee's selection of e
! Regulatory Guide (RG) 1.97, ' Instrumentation 'to Assess...quipment Plant and required by
! Environmental Conditions During and Following and.. Accident ' to ensure I
that equipment 1ccated in harsh environments was.6n.the MEl..
.,. . .- ,~
finally, the staff reviewed all of the ustifications-for continued operation.
(JCOs) for deficiencies that were ident fled in the TER and not corrected by the time the submittal was made. The staff's acceptance of JC0 that were j submitted was based on the (c110 wing criteria i i
i a the safety function could be accomplished by other qualified equipment l
t a
partial test data provided a basis to conclude that the equipment would.
j perforrn its function 1
i e limited use of administrative controls over equlpment;thet.Was not-- '~
{
demonstrated to be fully qualified ,y was employedWZl.
1,;.. .a p.;p.g. N o"7?' ,..g . 4 .
i l for all of the criteria specified above, it Wat &ssumed-that the failure of i unqualtfledequipmentthatwasaddressedbytheJCO.Would: net: impair.the- l l safety function of other safety related" equipment.' i,Q y e ** e I
q_ \ .. . l .
l l
- a w ;. ... l 7 )
"i%%6f@$$$)$pf@%4 (t ; ,
M**"-
N. 7 Fygpp w -
~ ,
a .. . ,
- w. g b e e " ' ' Appendix D i
9 v.
i
. m.
safety Evaluation Reports for License Applicants' scope and Mathedology W M 9 - -
n-I l License appiteants were required to subalt 'EQ program information for review i by thw staff to ensure that their regree met the requirement 8 of M,
! 10 CFR 50.49. The staff's evaluat on of the applicant's EQ progree lacludt- 55 l an on-site examination of equipennt, audits of qualification decumentation
- andareviewoftheapplicant'ssubmittalsforcompletenessandacceptabillty l of systems and components, qualification methods and accident environments.
- The staff used WREG-800, " standard Review Plan
- Revisten 2 i 3.11. and WREG-oLas, ' Environmental Qualificatlon of Electric (al Equipment 1981),Se i luportant to Safety for Nuclear Power Plants " Revision 1, to form the basis for their review.
- k j kURfc-a00 - Sectin 3.11, E0 af Machante11 a#J f16eirlAA1 faulmnt'- ,
I ~
Infonmation necessary to support the conclusion,that ,
! are capable of performing their design safety functio.all n:Whder allitems 'of equipment normal
~
> abnormal, and accident environmental conditient L arovidedbytheapellcant ,
i in section 3.11 of the Preliminary safety Analys's hepert. PSAR . Thls i information was reviewed by the staff to deterstne whether(the r)e '
! environmental capabliity of all equipment. hts been demonstrated. quired-1 m ,
! the environmental
! At the timerequirements qualification WREG-oso0,wereRevision embodiedIinwas Genera developed,l Desten Criteria J4DC) 4 of
! Appendix A to 10 CFR 50. These requirements could further be generaLised as .
i follows: [1) en:h piece of qualified equi
! its funct'ons under all normal, abnormal,pment accidentshall be designed to perforu and post-accident i environments for the length of ties for which its function is required! (t) the equipment's environmental capability shall be demonstrated throuJh appropriate test and analyses; and '3 place that meets the requirements10 ofCFRp a 50 quality Appendix assurance program stall be in B. The environmental design of mechanical and electrical equipment tras deseed acceptable if it could be ascertained that all three requirements were met.
For EQ equipment locate.1 in harsh environments, SAP 2.11 identiftes the appilcable IEEE standard or NRC Regulatory Guide to be used to evaluate the appl tcant's program. In most casest the appljCant Was~te preVide-documentation tant addressed the affects of 4 quallflod equipeent's service conditions (including the effects of design basis accidents and HELBs'inside ,
and eutside containment), submergence, chemical. sprays 'And radiation if. . i appitcable. For coe>onents in s'Id environments, the' reviewer was only i reovired to ensure tsat the equipment would perfore its function under normal l and abnomal conditions and that it was supported by a maintenance and l surveillance program and good preventative maintenance.-
l The staff had the opportunity to review the program at both the construction permit and the operating Ilconse application st6ges. At the construction ;
permit stage, the staff esasured the liceasee's program agalnst the ;
i i
I w_. - - , - -- - - - - - -_---a_ - - - _ - - - - - - - _ _ _ _ - - - - - - - - - - _ - - - - - , - - - - , . - - _ _ - - , - - _ - - - m --- w- - -
l y .q s i s v
i O.3 i I
- requirements described above, paying particular attention to the proper use of -
i test and analytical procedures used to qualify.the components. At the -
operating license sta e, the staff erformed a. final ?iew of the EQ program l
! described in the appl cant's Final afety Antlytil R6purt, which' included an. Nn l
- on-site audit (described below) of the licensee!scequipment.. qualification gb' documentation and a walkdown of safetyirelatedtsystent and temponents.
g, !
e ,%v,y '
i from the final review, the staffi l enerated a'$4fetyltV11[ationlt$ port ($ER) Mgg . J documenting the acceptability of?",heL11censtata!EQiprogramHlf- the staff?
identified any deficiencies, the.llcenset was required to.resolvo the W' Wg i deficiencies, or submit a justification for interim operation for review and 4 e approval by the staff, before the operating license would be lssued. Qg Paview of Ann 11 cant's E0 Procram
- i The EQ program review was develo>ed to evaluate an' app)lcant's EQ program and was similar in scope to the Franclin Research Center's (FRC) technical
[
, evaluations that were completed for operating plant EQ programs. ~The review 4..
- included an on site audit which would typically be conducted in the latter iR phases of the construction program when the licentee had completed their EQ 4" program and was implementing the program on those systems turned over for l operations. According to the Idato National Engineering Laboratory (INEL). "
i NRC contractor for program audits, the scope of the rev'ew included an N. . '
evaluation of the completeness of the Master Equipment List, the criteria of which must be met, the environments in which equipment must. function, and an M Q
assessment of the documentation for the equipment d . ,
The program review consisted of three-major parts.ty;4g _ y%
+ m ..
% w w]p .~;to going toakgi
.m. u .: . ,w (1) An evaluation of the applicanV Ue. WVerall? ras prog P the site. This review would include a programm4 tic'r)eview ofable aval 4 procedures, and a technical review of the basis for each piece of 3 equipment in the EQ program.g.
, ... T (2) An on-site audit of the applicant's central files containing the EQ program's documentation. The. applicant's central files were reviewed by e team of EQ specialists from the NRC staff:and their consultants. The team would typically review 4 portion of the'EQ files. ^
(3) A visual inspection of the equipment' items for'which' the central files were audited. During the visual inspection the team would consider those. physical qualities important to environmental qualification. auch as the component's location, orientation, and condition, The observations and concerns identified during the program review were included in the response to the licensee's submittal. The staff separated the electrical equipment into three categories: 1) equipment recu) ring replacementpriortoplantstartup,(2)equipm(entrequiring;acdttional 9 information or corrective action, and 3 - p' conditionally acceptable, pending imple(me)ntattori of'the~ maintenance andequipment '
surveillance program. The staff did not necessarily consider equipment in
- category (2) unqualified, however additional .information and analysis was
-_e- - - - _ - _ - - -____
l , ,
- . .;3 . -.-.z...,.
- ~ g y y, g ..g g; l
) Q ,Q NY ATAW~9 ~^ *
~. . w . pg,= .,p . ~
. g]~
3 a
g,m na>x9ew +<v = k 3.g. , r j w , . .
.% . .: n ;-
- -
- , ~~ -
1
- 04- . ,
.g a_ ,
1 s required before the staff would accept the equipment. For egulpment in i category (2), corrective actions er deficiencies:Were noted In the following _ W.
j areas:
g , \ g ;j y g y , ,
4..l; l
- Material aging evalestion; replacement schedule;' ongoing equipment i
! surveillance. '
Cheetcal spray !
Exempted equipment , justification inadequate-
!
- Humidity l
- Hell evaluation outside containment not completed .r l
- Margin 5
- Pressure .
.w :
Qualification information being developed , ,. . .... .
'm g' ".
Qualifleation method + 9 W W9 & W '". '
i i
Qualification time Radiation
%^ wmMWsWNW- '
~ 6. *
, , t Equipment location or replacement.scheduleinet.provided. ,
3 l
!
- Retest, schedule not provided{ ~ "9* ?* W '
"" "'f j
- submergence :'
- Separateeffectsqualificationjuttificatteninedequate 1
- u' !
l Temperature 2
Qualification critaria incorruct. .
.g y,s l . -
t l The staff identified one concern during the evaluetten of license appilcant EQ #-
- program reviews
- %.
s
.z
{
As part of the evaluation of ' inspection practices, the staff reviewed the findings from a total of ten program evaluations at operating plants I '
andlicenseapplicants(SeeAppendix6.
I operating plant TER revtews to the find)ings conse from l' appitcantComparing the findings .
progran reviews perfonned by INEL, the staff observed significantly !
fewer findings documentation. The(innumber aggregate)d an type of deficiency catogortes used byfree th INEL also varied from those chosen by FRC. Because INEL did not include '
information in their audit report about the methodology used to review !
the apailcant's program, it is het clear Whether the scope and depth of the INEL reviews were equivalent to the FRC reviews.: .'
- l
.c e
gg i e
l'5*
s
's),
Y
}
l
-- ww -v ,eemi-.s'ss-**wS4.14.mee..ame-lE m m es -es mesum4m.,w '46 -e- ' anum Jm_WMaim-- at.Maah A e a 4m.enhameh4 A.e we eam w e a-as 4a d41r i,m.,.mm.mam e w- ww w sgmea.w,4u..u.*.a.hMw_ 4 Maw m, 6
- r
'.n *
-' $sJ .I p,j
' , g w
- 'g 9l 8 ; <- <,
s .e
, l* 8 \ d ^= l
" 1 1
i e
f POW.. g .eq@-W. ( .
( 4As . 'eh-f ,-
O.*a , ~'Mq a ,
0 J S --
'f y e,.Ji
- MY.n .< , ** b w o t"
/,*(,.-
' , , < , . rs .;'
. > - p + 4'i 1
,a
' @. . . ..e.),. - ~ ,1, < . J.3w ' & .s. ~
>-f
.,,,S ' %E g
+: .
p .g
- d
- lg ' t
" i '; ,N w
vse*~.',v ,,,y.
is; . ; 7' % .* ig--
9 .
8 p j', d 0' , ,4+'..e ; ,,
- P' 9
6 4 e
y I
F a<' = .**4e .6 g' .#, . I e' s :' V _.. y2 ; *r. , * ,=,e ,
,s 4 f *W ?,
- $A %' I' 5 N ' Edu' ', I, n' % a '"'*-'+gw * -
ys -
g- n -- - (
a 1 1 e s
h..
,,s i ./ e, u q
' g h.'Y 'e ' aE
~'ge ,h
k .e*. 4( 4#[ 'M '_D o.'415 $8
- I~ k 6
.,/;; ,,'_'-
z.g r . m. 9 ,.. l> , g "- ,
e p
p i . f' 1
1 I
1 4 1 I
S '* i
..c 9
- , 1
, , .. ,3q
-a . et m n, 9 gf, v.i k. .. ' .,_ .e q-y, . ~-
- S.
4..< l 4,p,.
.5 I
t Y l
l l
l l
\
l i
i sk
+ w -
,.ya ,
4 l 9 4 -r hM
-%lfi & n % p; W R " >
{
Appendix.E l '
l NRC EQ $lte Inspections' l Objectives and Methodology l
Prior to the implementation of the EQ rule for licensees the Vender' Inspection Branch (Vit) conducted ins products and services to the nuclear industry. pections:sf
'!t was the goal vendors,who of the V!S at provided EQ the time to inspect as many providers of EQ services.es the new EQ rule, the VIB was tasked withjesloping and:possible.< As part ofcenductin .
program to inspect licensee EQ prograntMThe Vlt developedinspection' -U instructions (Temporary Instruction ProgramforQualificationofElectric(TI)EquipmenblocatedinHarsh4till/75 al MEvaluation invironments') and, using the EQ inspection experience gained from the inspection of EQ vendors, conducted training seeintestfor regional-inspectors at 5andia National Laboratories (NL Contractors from Sandia NL and Idaho) National Englueering Laboratories (INEL)befo assisted with most of the EQ inspections.
Typically, an on-site inspection of the licensee's EQ regram was performed after the staff 1) reviewed the EQ program submittal ) reviewed the Franklin Research Center (FRC) technical evaluation report program, 3) performed a site audit of the3 llcenseelTk as implemented"for EQ that Ilcensee's IQ program, and 4) accepted the licensee's EQ program' including any corrective action plans or justifications for interim operations, and: issued the final safety evaluation report (SER).
Obiectives The objective of Ti 2515/76 was to provide guidance?fer the inspection of licensee environmental qualification prograssifer.aelectrical equipment
- important to safety located in ~ harsh eny ronmenta as required by 10 CFR 50.49-,
The il also ensured that Itcensee commitments for' resolution of outstandln; >
1ssues from the staff's SER: were bein3 properly,1aplemented.. .
During these inspections, the NRC: 1)ireviewedthelaplementationofthe licensee's EQ program, 2) reviewed the licensee's laplementation of SER corrective action commitments, 3 reviewed the licensee laplementation of a program for maintaining the qual)lfled status of equipment during the life of-the plant, and 4) performed a walk-down of equipment to verify that-the installation conformed to the SER cosal,tments and qualification requirements.
~
11tr Insoection Methodoloov The staff assembled an inspection team consisting of a team leader, a technical specialist (electrical and power control equipment), a quality assurance (QA) specialist (QA requirements for procurement, maintenance, and testing), and an EQ specialist (EQ testing, analysis, and documentation requirements). Prior to each inspection, the inspectors would review the following documents applicable to the site (at a minimum):
o e 4
'( '
- I* ,.y
.Q J Q- e
l y , -
. Gfsy. Wh% e$
i n! W l?h h: $ -
h YNW 5%
W&;$ff?qpg?"
- t.e 7 3 -
The FRC Technical Evaluation Report-(i!R), as ap>1(cable.
- Thelicensee'sMasterEquipmen'tLis_t.(MEL
= Generic Letter fCt) 84-24..' Certification)<of: Compliance to 10 CFR ,
50.49,* and the Itcensee's;responsestotClt84-24 m
~
- EQ procedures .i .- -
In addition to reviewing these documents, the inspection included an evaluation of the qualification documentation and physical inspection of 10-15 equipment items. The inspection team selected the equipment items based on criteria specified in Tl 2515/76, which included:
- Deficient equipment items identified in'the TER.
= Outrtanding IE Bulletins and Infomation Notices related to EQ
- Accessibility of the equipment. .. N -
- Plant specific EQ-related. Licensee..EvenL Reports and problems reported
.j under 10 CFR Part 21.
]
= Equipment added to or deleted from'the HELLsince the issuance of the -
TER. 'm Equipment that changed TER categoriasisini:e the TER was issued.
- Equipment that had no documentation submitted for the TER.
Newly installed equipment;that replaced unqualified equipment.
=
At least one piece of 00R Guidelines ' equipment, as applicable.
i variety of equipment types.~. -
Sensitivity of core damagogo_ component 7 failure. .
The site inspection consisted oflhree parts: 1) a procedural and programmatic inspection, 2) a documentation file inspection, and 3) a physical inspection !
of equipment in-situ. Comprehensive checklists were develo)ed for each part of the audit to promote con,istency between inspectors and )etween inspections. Appendix F contains a copy of the Tl including the site audit checklists. ,
During the procedural and programmatic review, the inspection team reviewed the licensee's procedures for generating and maintaining the HEL, reviewing and approving EQ documentation, and addressing IEBs and ins related to EQ. The team also reviewed procedures that implamented EQ maintenance and surveillance practices, procurement practices, and controlled plant modification practices with respect to EQ. The inspection team interviewed site personnel about their responsibilities regarding qualifi3d equipment and reviewed QA/QC records for conformance to procedural requirements.
.- .n .
During the documentation file review,' among otherithings', the inspection team l reviewed the completeness of thetlicensee's MEL, evaluated whether program procedures regarding changes to the MEL were being followed, reviewed the qualification files of the equipment" sample that was selected to ensure the qualification requirements were addressed, reviewed the documentation files to determine whether similarity was established between qualified devices and the tested equipment, determined whether commitments for corrective actions were fulfilled by the licensee, and examined the replacement equipment review and approval process.
w
~
E-3 -
During the physical inspection, the' inspection team determined whether the installed equipment (equipment type, installation orientation'and -
was the-same as described in the-configuration Ilcensee's qualification requirements for qualification)hecked documentation, and c 3 the equipment surrounding the qualified equipaent to determine whethersfailurosof the surrounding . .
equipment could affact the ability of<.the. qualified.equipmentato7 perform its : ~
required function.
- .g g g*cy.{.;r g - ( Jge Tl 2515/76 was also used as guidance by the staff whan inspecting the EQ t programs of those plants licensed after:the EQ rule became affective.. The '
staff used portiores of TI 2515/76 to develop the~1nspection~ plan for the post- :
licensing comp 11nce inspection that.was conducted-at each facility. :Because the TI was specifically developed to inspect EQ' programs.at facilities that were already operating when the EQ rule became effective some of the reviews raouired by the TI were not applicable to newer plantsE In general though, the TJ provided an acceptable framework upon which the inspector could build ;
an inspection plan.
The staff continues to use the T1 as an aid in developing inspection plans for license applicants. T% TI has not been revised since 1987 and contains guidance that is not applicable to reviewing EQ programs at license
- g %
- cants. s -
i
~
, j (~ , ,% r 5 f_(V 5 W., k')*: ' '
! _' , 3 JgjN g " . ? . vi, g "t?,Mjjgl}l .[h@4%j4: ~
l
. L -
uL i _
, r k
,'d.' 1 ,,a ,
- N. gr .J .
j' X~ ,
e
.___- _--__-_ _ - _ -_ _ __ _ _ __