ML20206U717
| ML20206U717 | |
| Person / Time | |
|---|---|
| Issue date: | 03/22/1994 |
| From: | Virgilio M Office of Nuclear Reactor Regulation |
| To: | Thadani A Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20206U672 | List: |
| References | |
| FOIA-99-82 TAC-M85648, NUDOCS 9902170305 | |
| Download: ML20206U717 (13) | |
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6 MIMORANDUM FOR:
Ashok C. Thadant. Associate Director for Inspection and Technical Assessment FROM:
Martin J. Virgilio Acting Director Division of Systems Safety and Analysis
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RIVIEW OF EQ INFORMATION RELATED TO PLANT LICENSE RENEWAL (EQ TAP ACil0N liEM 3.a) (TAC M85648)
As discussed in the staff's Environmental Qualification Task Action Plan (IO-IAP) of June 16, 1993, we are performing a ;srogrammatic review of environmental qualification (EQ) for electrical equipment.
Our ef forts in t h t '. regard are specifically defined under Action item 3 nf the IQ-TAP. which int.ludes the following elements:
I 3.4 Review I trense Renewal flackground Information l
3.b Review Itre Protection Reassessment Report l
j 3.t Elicit Opinions from Others (Regions, EQ Expert s) 3.d Review Entsting EQ Program Requirements 3.c Revlew NRC Audit / Inspect ion Pract it.cs 3.f Review License...clementation Practices 3.4 IInaltre Review Results Our objective in completing items 3.a through 3.f (above) is to identify potential EQ lssues and concerns that may deserve further staff consideration.
It is important to recognize that this part of our programmatic review is not intended to resolve or to otherwise address any of the E01ssues that are identified. Af ter Itas 3.a through 3.f of the EO-TAP have been completed, all of the E0 issues will be consolidated and specifically addressed in the st af f's final report under item 3.g. "Finaltre Review Results." which will include recommendations as appropriate. Our final report is scheduled to be rompleted by Aurpnt 30. 1994.
(urrently, i;t have completed the review associated with item 3.a of the (0-TAP. " Review License Renewal Background Information." and our evaluation is encine.ed for ynur information, the potential issues that were identified iluring thie. review will be assembled and addressed in our final report along i
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with any other potential issues that are identified as we complete items 3.b i
- i through 3.f of the EQ-1AP. Please contact me if you should have any questions regarding the enclosed evaluation.
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Martin J. Virgilio, Acting Director i
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PEVIEW OF EQ INFORMATION RELATED TO PLANT LICENSE RENEWAL
'l (TAC NO. M85648)
!.0 INTRODUCT10N As discussed in the Environmental Qualification Task Action Plan (EQ-TAP) of.
June 16. 1993, the staf f is performing a reassessment of the NRC environmental qualification requirements for electrical equipment. Action item 3 of the EQ 1AP lists those actions that pertain to the programmatic review of EQ, which include:
3.a Review License Renewal Background information
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3.b Review Fire Protection Reassessment Report 3.c Elicit Opinions from Others (Regions, EQ Experts) 3.d Review Existing E0 Program Requirements 3.e Review NRC Audtt/ Inspection Practices 3.f Review Licensee implementation Practices 3.y finalize Review Results This particular ' evaluation is intended to address EQ-TAP Action Item 3.a.
" Review License Renewal Background Information." The specific objective is to identify potential EQ issues and concerns by reviewing information related to the Itcense renewal initiative.
This is not intended to be a comprehensive review of documents related to license renewal, but rather a review of
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suf ficient background information to identify any significant issues and concerns that pertain to EQ.
Ultimately, all of the issues and concerns that are identified during the EQ programmatic review will be consolidated and discussed in the final report (EQ-TAP Action Item 3.g).
Therefore, this
" valuation does rot include specific recommendations for further staff actions.
2.0 BACKGROUND
INFORMATION ON LICENSE RENEWAL
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In support of 10 CFR 54, " Requirements for Renewal of Operating Licenses for h
Nuclear Power Plants " the staff reviewed the original EQ requirements that
',i were imposed on licensees in order to determine if additional EQ measures should be required during the renewal period.
As a result of this review, the
.j staff ultimately questioned the adequacy c' the less stringent EQ criteria that were imposed on licensees by the Division of Operating Reactors (00R)
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Guidelines and by the Category !! criteria of NUREG-0588, " Interim St af f l
Position on Environmental Qualification of Safety-Related Electrical
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1 Equipment," as compared to the more rigorous Category I criteria of NUCEG-0588 LL that were imposed on the newer plants. Ultimately, the staff determined that ti i the adequacy of EQ requirements (DOR guidelines and NUREG-0588 Category 11 7 1.
versus NUR[G-0588 Category I) should be reassessed as an operating reactor J(
issue and not as a license renewal issue.
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1 3.0 REVIEW Of PLANT LICENSE RENEWAL INTORMAIION PERTAINING TO EQ l
The staf f reviewed information associated with the Draf t Br. inch Technical i
Position on EQ (EQ-BTP) for license renewal in order to identify EQ-related j
issues and concerns.
Each document is briefly summarized below, and the f0-related issues and concerns associated with each document are listed, 3
i 3.1 Memorandum for J. Crato from P. Shemanski. " Summary of Meetina with NUMARC on Ecutoment Oualification Issues Related to License Renewal "
January 7. 1991 i
i On December 14 1990, the NRC staf f met with representatives from the Nuclear Management and Resources Council (NUMARC) to discuss equipment qualification issues related to license renewal.
The following views and information were expressed in the meeting miuutes:
1 1
The staff indicated that none of the EQ programs currently beinq j
implemented by licensees fully satisfied the requirements of an established effective program as defined in draft 10 CTR 50.54. and that 1
,ome existing proqrams would have to be modified to adequately determine i
the qualification of equipment during the renewal term (after 40 years).
i fur example, some components may require additional extensive testing or i
reanalysis to establish qualification for the renewal period.
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NUMARC discussed the use of IEEE 323-1983 as the basis of component qualification for life extension.
IEEE 323-83 introduced a new section on extension of qualified life which credits the use of reanalysis for increasing qualified life by using conservatisms between the initially assumed environmental conditions and those that actually exist in the plant.
The staff agreed to assess the suitability of IFEI 323-83 as an equipment quallfjcation standard (IEEE 323-74 was the version of the i
standard currently endorsed by the staff).
Components that were qualified to the 00R Guidelines and NUREG-0588 Category !! requirements were not required to be aged before type testing.
Synergistic and dose rate effects were also not required to be addressed by these criteria.
The staff noted that there was insufficient data to conclusively predict the threshold of aging degradation that a component could sustain and still be abic to pass a LOCA qualification test.
The staff indicated that the exemption allowed by Regulatory Guide 1.89 for replacement equipment may not be appropriate for the license renetzal term.
The staff indicated that there may be a need to conduct walkdowns and and inspections to support the renewal term.
Testing may be warranted in conjunction with the inspections for some equipment to determine the state of degradation.
The staff indicated that any justifications for continued operation that are currently in place for inoperable equipment (as allowed by Generic i <
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e Letter 88-07) may not be appropriate for continuation into the renewal term.
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Based on the information contained in this memorandum, the following issues and concerns were identified for further consideration by the staff:
l adequacy of qualification methodology for establishing initial a.
qualification, including differences between the less' rigorous c.'Iteria stated by the 00R Guidelines and NUREG-0588 Cat. 11 versus the criteria stated by NUREG-0588 Cat.1 (e.g.. aging, j
synergistic and dose rate effects) i b.
adequacy of existing programs to assure continued equipment qualification, including qualification beyond the established i
qualified life given the different qualification standards acceptability of the Regulatory Guide 1.89 exemptions to
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equipment upgrade requirements criteria for acceptable versus unacceptable aging a
degradation need for walkdown, inspection and additional testing adequacy of existing justifications for continued operation allowed under Generic letter 88-07 l
3.2 Mrppf.AndW_f3r J. RichA.td19n. A. 1hadani. L. itt19u40d._Hlantti_.f COB
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Untchf teld. " Draf t Olscussion Pacer en Eaulement Qualif RAU.o.n_._Lgr Lg.tme RenenAl (T AC No. 81534)." October 29. 1991 j
A draft discu.. ton paper was prepared by the License Renewal Project Directorate (POLR) staff for extending the qualified life of electrical equipment.
Comments from other organizations within the NRC were being solicited on the paper prior to proceeding with further discussions with the Nin lear Management and Resources Council (NUMARC).
The discussion paper 1
inntained the following information and staff views:
1 Changes to the qualification criteria for the renewal term are le' ended to take advantage of current EQ knowledge and in particulai. focus on 10 or age-related degradation unique to Ilcense renewal.
While E0 age-related degradation occurs during the term of the current operating license, the effects are expected to be different in character or magnitude during the period of extended operation.
[0 programs cannot be considered to be effective prograns without a
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determination that age-related degradation will be adequately managed af ter the curr ent term.
The 00R Guidelines and NUREG 0588 did not address in detail all areas of qualification..inte certain areas were not well understood at the time.
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f or example, the effects of aging, sequential versus simultaneous testing. synergistic effects, dose rate, and the potential for combustible r,as and chlorlde formation in equipment containing organic materials have subsequently been evaluated in more deta11.
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i Components qualified to the 00R Guidelines or to NUREG-0588 Cat. !! were not required to be pre-aged before type testing, and synergistic and dose rate effects were not required to be addressed.
Since many components were qualifted by pre-aging using irradiation at i
high dose rates of 0.1 to 1 Mrad /hr, the possibility of oxygen diffusion effects having minimized polymer degradation shoJ1d be addressed to ensure adequate margin.
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Augmented inspection may be warranted to address and detect the presence of component age-related degradation.
Pp.t oLt.Alhan t
ll.swd on the information contained in this memorandum, the following issues and concerns were identified for further consideration by the staff:
adequacy of qualification methodology for establishing inillal a.
cualification, including differences between the less rigorous criteria stated by the DOR Guidelines and NUREG-0538 Cat. 11 versus the criteria stated by NUREG-0588 Cat. I aging sequential versus simultaneous testing synergistic effects dose rate effects combustible gas and chlorine formation effects oxygen diffusion effects h.
adequacy of existing prograins to manage aging age rriated degradatton unique to license renewal augmented inspection may be warranted to address and detect 3
the presence of component age-related degradation.
1.3 O gIgadum for D Crutchfield from A. Thadant.
- Draft Discussion PancI on laulnment.Qua ification for Licente Renewal (1AC No. 81534)."
()ecember 10.199 l The Division of Systems fechnology (DST) provided its comments on the subject i
draft discussion paper. While DST was generally in agreement with the position that was presented, it was pointed out that recent expertence at Watts Bar and Browns Ferry indicated that electric cables may become damaged
,l during installation.
It was also pointed out that cables that are damaged during installation may not be detected during normal operation.
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l Ppten dal Issu u Based nn the information contained in this memorandum, the following issue was identified for further consideration by the staff:
effects of installation, maintenance and surveillance practices on equipment qualification 4-
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j 3.4 Memorandum for P. Shemanski from J. Vora. "E0 for License Renewal."
February 5. 1992 The Of fice of Research (RES) provided its comments on the Draft Discussion Paper on Equipment Qualification for License Renewal.
RES was supportive of the paper. but indicated that some improvement was needed.
Aside from clerical and administrative Improvements. RES indicated that more definitive i
explanations were needed on what constituted an adequate " supporting analysis" j
and what an acceptable " conservatism" was. Also, additional discussion on i
" hot spots" and treatment of localized anomalies attributable to installation errors or improper maintenance or age-related degradation was needed.
i Pplential issues Based on the information cuntained in this memo: andum, the following issue was j
identified for further consideration by the staff:
adequacy of existing programs for addressing " hot spots."
localized anomalies attributable to installation errors, improper maintenance and age related degradation.
i 3.5 MrJ1!En Minutes Prepared by S. Carf auno (NRC Consultn1L_"[,qttpina f
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Q nl_1fication for License Renew 61." March 19. 1992 A meeting involving NRC staff (including its consultant. 5. Carfagno) was held on March 18. 1992, to discuss the above stated subject.
The following information was included in the meeting minutes:
Safety related equipment for older plants was qualified in accordance with the 00R Guidelines or NUREG 0588. Cat. II. which did not require the age conditioning of specimens prior to testing for seismic and LOCA tendurance.
This was cited as a major concern.
The (.able qualification process does not address " weak links" such as hot spots, long overhangs, and damage due to installation or maintenance.
It may be appropriate for licensees to Institute surveillance procedures to address " weak links" for the license renewal period.
i The license renewal process may provide an opportunity to review the i
adequacy of current LOCA testing in which test durations of 10 to 30 days are sometimes used to demonstrate satisfactory performance of equipment for periods of up to one year.
I While the current " accelerated aging" methodology using Arrhenius technt ues may possibly account for thermal effects, it does not address l
the effects of long term exposure to moisture.
A point to consider is that some PRAs show that safet y (:an be maintained even if c ert ain component s f all af ter several tjays of au ldent ospasure.
even though the riesign basis may be that they remain available f or periods of up to one year of accident exposure.
Potent 1st researt.h needs that were discussed int luded:
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(a) investigation of the acceptability of butyl rubber insulation inside containment in view of its reversion under irradiation: (b) comparison of the properties of cables removed from older plants with the properties of new cables subjected to age conditioning equisalent to the age of the naturally aged cables; (c) conducting LOCA tests in accordance with current qualification practice on cables that were qualified on the basis of 00R or NUREG-0588. Cat. II: (1) identification of weak links; and (e) establishing weak link surveillance procedures.
Potential Issues Based on the information contained in these meeting minutes, the following issues were identified for further consideration by the staff:
PRA implications /need for screening criteria
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b.
adequacy of qualification methodology for establishing initial qualification. including differences between the less rigorous criteria stated by the 00R Guidelines and NUREG-0588 Cat. 11 versus the criteria stated by NUREG-0588 Cat. I age conditioning (especially for older plants) test duration used to establish long-term qualification long-term exposure to moisture b.
adequacy of existing programs to manage aging augmented inspection may be warranted to address weak links such as hot spots, long overhangs, and damage due to installation or maintenance activities c.
aging of Butyl rubber d.
potential research topics LOCA testing of naturally aged 00R/NUREG-0588 Cat.11 cables l
identification of " weak links"/ condition monitoring needs i
3.6 NUREG-lL99. Section F-2.0.
- Environmental Oualificalion of ElettyLq
[QU.ts unL_1c utlant in License flenewal." Snotember 1992 (Draf t 2) l Ihe staff's Branch Technical Position (BTP) discussed background information i
related to E0 and established specific criteria to be imposed for license d
renewal.
The BTP was essentiall se att on to Isau ehnya), y the draf t discussion paper that wan prepared hi ihn nnd Inn > thu Vnsition tnnL Lhu LU rnqutruments l
st.t M in thu fx)R (,uidelines and in fiURLG-0588 for Category 11 equipment were in,uffictent for license renewal purposes due to shortcomings in methodology i
rniated to:
(1) preaging of components. (2) maintaintet margins, and (3) consideration of synergistic effects.
It was the staff's view that licensees
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should demonstrate that NUREG-0588 Category I criteria have been satisfied for the ranewal term.
The following additional views were also expressed:
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" Sound reasons to the contrary" that may have been established l
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previously for not using replacement equipment that satisfies the i
criteria in Regulatory Guide 1.89, Revision 1, will not automatically be j
accepted.
Specific guidance for demonstrating equipment qualification by reanalysis, similarity, type testing, and by ongoing experience for the j
j renewal term was provided.
Equipment in the environmental qualification program should be subjected to a one-time only inspection or a series of inspections designed to i
i identify and assess areas that can potentially shorten the demonstrated qualified life.
1 l
Following the staff's presentation of the BTP to the Advisory Committee on Reactor Safeguards (ACRS) on September 16 and on October 8,1992, Dr. Carfagno I
(NRC consultant) provided comments pertaining to the ACRS discussions in letters dated September 17 and October 9,1992 (respectively).
These letters
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provided additional background information and indicated that in the early days of E0 (before IEEE 323-74), thermal aging was somewhat arbitrary and not i
based on the Arrhenius methodology. Nonetheless, it was Dr. Carfagno's recollection that age conditioning was conducted and that the early cable qualification programs included substantial radiation exposure (typically 50 j
4 Mrad as the 40-year dose and 150 Mrad as the accident dose).
Dr. Carfagno also indicated that questions may remain as to the adequacy of the D0R LOCA tests that were conducted and that even today there remain technical questions 4
concerning the justification for LOCA acceleration (i.e., the use of excess margin in the LOCA tests to simulate post-accident service periods longer than e
the test duration).
While it was Dr. Carfagno's recollection that the
~i adequacy of DDR LOCA tests was checked during the NRC's EQ review, he was not certain whether the evaluation criteria were consistent with the present technical knowledge.
Dr. Carfagno pointed out that cables are only one i
component in the long list of equipment important to safety and that data demonstrating the insignificance of aging on other components are most likely not available.
The ACRS provided its view of the staff's arna9spq (ITP {n q Ip}
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- lhillh 19 I T Dil 019119r 11,1991:
1l19 ER.i ILidll:Altid llidt lliu uu not be issue or pub ic comment until the following matters were addressed:
(a) an analysis of the risk importance of F0 during the renewal period should be completed, and (b) the effects of fire-r. '.irdant coatings on the aging of i
l electric cabins shnuld be ovaluaterf, Patential Issues A
liased on the information contained in the staff's draft BiP and the related enrrer.pnndence discussed Above, the following luuns were Identifled for turther consideration by the staf f:
l a.
adequacy of DDR Guidelines and NUREG-0588 Cat. 11 criteria preaging margins synergistic effects 1 i W +!S
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b.
adequacy of 00R LOCA testing l
use of excess margin to justify shortened post-accident test duration c.
adequacy of E0 for components other than cables i
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effects of fire-retardant coatings j
e.
risk importance of EQ i
i f.
adequacy of existing programs to assure continued equipment i
qualification p
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acceptability of the Regulatory Guide 1.89 exemptions to
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equipment upgrade requirements 1
need for walkdown, inspection and additional testing 4
j 3.7
" Low-Voltace Environmentally-Oualified Cable license Renewal Industry Report." March 1993 (Revision 11 i
i This industry report (IR) was prepared under the direction of the Nuclear j
Management and Resources Council (NUMARC) Nuclear Plant Life Extension l
(NUPLEX) working group.
Funding and development of this project was supplied i
by the United Stated Department of Energy and managed through Sandia National Laboratories.
l The NUPLEX study was limited to low-voltage cables (i.e., less than 1000 volts) that are environmentally qualified per the provisions of 10 CFR 50.49 and related regulatory guidance documents and industry standards.
The scope of the study included factory splices and factory. insulation rework, component and panel internal wiring, and ancillary cable-related hardware such as electrical or pressure connectors, terminal blocks, and splices between field cable and equipment extension leads. Cable using polyimide (e.g., Kapton) and j
Butyl rt.bber insulations were excluded from the study since Kapton has unique characteristics and Butyl rubber exhibits a unique response to aging (i.e., it
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softens rather than embrittles). Mineral insulated cables were also excluded g
from the study since the insulation and jacket materials are not organic and c
their construction is unique.
Finally, cables used in pulse-type applications b-(e.g., digital transmission circuits and some neutron monitoring circuits) j i
were excluded from the study since cable impedance could be an important ES design characteristic for these cables. Aside from the cable types, cable j
g degradation due to the following shortcomings were also excluded from this l
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study:
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$k f6 design non-conformanco (e.g., mechanical damage caused by misapplication a
j or improper installation);
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unintended long-term submergence during normal plant operation; j
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unintended exposure to chemical attack (e.g., boric acid leakage or j
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decontamination activities); and i
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The study expressed the view that these degradation mechanisms are plant-l i
specific and would be evaluated by a utility at the time of discovery.
Based on a review of nuclear power plant operating experience, relevant laboratory
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data and related experience in other industries, the following age-related degradation mechanisms were selected for consideration in this IR:
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changes in low-volatage electrical properties of insulation materials; embrittlement of cable insulation materials;
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conductor / shield corrosion; 1
j loss of fire-retardants from insulation and Jacket matertals; i
j embrittlement of cable Jacket materials; i
j corona degradation and breakdown phenomena; and i
1 water and electrical trees in insulation materials.
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Of the cable degradation mechanisms that were considered, the IR concluded i
that the only "potentially significant" degradation mechanisms included:
(a) embrittlement of cable insulation materials and (b) embrittlelment of cable Jacket materials if the jacket is credited for beta radiation shielding, if i
i electrical shield isolation is important, if the jacket is bonded to the j
insulation, or if the physical integrity of the Jacket is necessary for qualification of cable connectors and splices.
The study concluded that:
(a) l current and acceptable programs for managing insulation and Jacket embrittiement include reevaluatlon, requalification, and replacement strategies; and (b) no further evaluation of cable insulation and jacket j
cmbrittlement for the purposes of license renewal is required when i
reevaluation or requalification establishes qualification for the renewal term.
Potential Issun
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Based on the information contained in the industry report on cable i
degradation, the following issues were identified for further consideration by the staff i
adequacy of existing programs to assure continued equipment a.
i qualification l
Insulation and Jacket embrittlement design non-conformances unintended long-term submergence exposure to chemical attack (e.g., boric acid Icakage, decontaminstinn acttvitlos) b.
adequacy of E0 for certain spectric applications polylmide insulation (Kapton)
Butyl rubber insulation
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mineral usol insulation coaxial cable 4
bonded jackets l
4.0 CONCLUSION
S Extentive work has been completed by both the NRC staff and by the nuclear industry in attempting to establish a technical position on EQ for the license renewal term.
The previous efforts in this regard proved to be very helpful in identifying potential EQ issues, and it is difficult to argue that.these issues are not applicable to the current license term for operating reactors.
The specific issues identified during this review are listed below and will be j
addressed in the staff's final report (EQ-TAP Action item 3 9):
l adequacy of the qualification methodology for establishing initial a.
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qualification, including consideration of the differences between the criteria stated by the 00R Guidelines and NUREG-0588 Cat. 11 versus the more rigorous criteria stated by NUREG-0588 Cat. I 3
age conditioning (especially for older plants) margins i
synergistic effects j
sequential versus simultaneous testing j
dose rate effects combustible gas and chlortne formation effects oxygen diffusion effects long-term exposure to moisture 1
test duration used to establish long-term qualification l
use of excess margin to justify shortened post-accident test l
duration during DOC LOCA testing l
b.
adequacy of existing programs to assure continued equipment 1
qualification, including qualification beyond the established qualified life given the different qualification standards l
criteria for acceptable versus unacceptable aging degradation.
effects of installation, maintenance and surveillance practices on equipment qualification i
identification and treatment of " hot spots," lont; overhangs, l
insulation and jacket embrittlement, unintended long-term submergence, exposure to chemical attack (e.g., boric acid leakage, decontLnination activities), and localized anomaltes l
attributable to installation errors, improper maintenance and age-related degradation need for walkdown, inspection and additional testing to address and detect the presenti of component degradation (age-related and l
other) adequacy of existing justifications for continued operation allowed under Generte Letter 88-07 acceptability of the Regulatory Guide 1.89 exemptions to equipment upgrade requirements age-related degradation unique to license renewal i
r.
effcct of ftre-retardant coatings on EQ i
d.
adequacy of EQ for certain specific appilcations I
l polyimide insulation (Kapton)
Butyl rubber insulation 1
mineral wool insulation j
bonded jackets
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coaxial cable e.
adequacy of EQ for components other than cables I
f.
PRA impitcations/need for EQ screening criteria 9
risk importance of EQ j
h.
potential research topics 1
LOCA testing of naturally aged DOR /NUREG-0588 Cat. !! cables j
tdentification of " weak links"/ condition monitoring needs t
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