ML24306A115
| ML24306A115 | |
| Person / Time | |
|---|---|
| Issue date: | 11/05/2024 |
| From: | Aida Rivera-Varona Division of Operating Reactor Licensing |
| To: | Hashemian H AMS Corp |
| References | |
| EPID L-2024-TOP-0030 | |
| Download: ML24306A115 (1) | |
Text
November 05, 2024 H. M. Hashemian President and Chief Executive Officer Analysis and Measurement Services Corporation 9119 Cross Park Drive Knoxville, TN 37923
SUBJECT:
ANALYSIS AND MEASUREMENT SERVICES CORPORATION -
SUPPLEMENTAL INFORMATION NEEDED TO COMPLETE ACCEPTANCE REVIEW OF TECHNICAL REPORT CABLE TR-R0, CONDITION MONITORING METHODOLOGY FOR LIFE EXTENSION AND AGING MANAGEMENT OF ELECTRICAL CABLES (EPID L-2024-TOP-0030)
H. M. Hashemian:
By letter dated August 20, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24233A208), Analysis and Measurement Services Corporation (AMS) submitted a topical report (TR) for Condition Monitoring Methodology for Life Extension and Aging Management of Electrical Cables. The proposed report would describe a condition monitoring methodology to extend the service life of electrical cables as installed in nuclear facilities. The purpose of this letter is to provide the results of the U.S. Nuclear Regulatory Commission (NRC) staffs acceptance review of this report. The acceptance review is performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review. The acceptance review is also intended to identify whether the application has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant.
In accordance with Office of Nuclear Reactor Regulation (NRR) Office Instruction (OI) LIC-500, Topical Reports, the technical staff conducts a completeness review using the project management and technical reviewer criteria in NRR OI LIC-109, Acceptance Review Procedures. OI LIC-109 states that non-acceptance derives from certain provisions of Title 10 of the Code of Federal Regulations (10 CFR) 2.101, Filing of application.
H.
The NRC staff has reviewed your application and concluded that it did not provide technical information in sufficient detail to enable the NRC staff to complete its detailed review and make an independent assessment regarding the acceptability of the proposed report in terms of regulatory requirements for the protection of public health and safety and the environment. The NRC staff identified that the following information was needed to begin its technical review:
Many of the proposed condition monitoring methods are the same as those used in NUREG/CR-6704, Assessment of Environmental Qualification Practices and Condition Monitoring Techniques for Low-Voltage Electric Cables, Volumes 1 and 2 and NUREG/CR-7300, Radiation Accident Dose and Simulated Loss-of-Coolant Accident Test of Low Voltage Cables. The technical assumptions and findings within the TR appear to conflict with the NRCs findings contained within these NUREG documents.
More information is necessary to understand how the methodology and testing techniques are different than the information and conclusions in these NUREGs. For example, according to NUREG/CR-7300, the purpose of the NIST and Kinectrics projects were to assess the effectiveness of 8 condition monitoring methods to track cable aging and perform condition-based qualification. Based on the findings from the NIST and Kinectrics projects, except for the Elongation-At-Break condition monitoring method, no single condition monitoring method was found to be suitable for condition based-qualification for cables. Furthermore, of the 3 electrical condition monitoring methods assessed during the NIST project, none resulted in meaningful trending or tracking of the aging and condition of the cables. Thermogravimetric Analysis (TGA) and Fourier-Transform Infrared Spectroscopy (FTIR) also were found to not trend or demonstrate the ability to track the aging of the cables during the NIST project.
Table 4.5 in the AMS document lists the basis for the periodic test intervals, but the bases are not specific and lack adequate technical justification to justify the intervals.
The NRC staff needs additional information on the details and assumptions used to determine the appropriate test interval.
The TR provides minimal details as to the baseline condition of the unused vintage cables used to develop the methodology. The TR states mild environment storage for several decades. The NRC staff needs additional information to understand the baseline condition of the unused vintage cables. For example, what the environmental conditions were, whether the cables were moved/manipulated while stored, etc.
Section 6.1, LIMITATIONS OF THE METHODOLOGY, states that it does not provide a means of extrapolating [condition monitoring] testing results to predict when cables will reach their end-of-life. The NRC staff requests clarity on the limitations of the method as this statement contradicts other sections of the report using these tests to assess end of cable lifetime.
Section 6.2, APPLICATION-SPECIFIC ACTION ITEMS, infers that other methodologies could be used in lieu of the methodology contained in the AMS TR Section 4. The NRC requests clarity on these statements, as this TR should be limited to the methodology and technical basis contained within the TR and not expand to ideas or concepts outside of the TR.
H.
Section 7.3.4 states The AMS methodology as described in this TR aligns with the recommendations identified NUREG/CR-7000. The NRC staff needs additional details to understand how the methodology will provide an accurate, conservative assessment of the condition of an entire length of cable spanning different plant environments, as discussed in NUREG/CR-7000, Essential Elements of an Electric Cable Condition Monitoring Program.
To make the application complete, the NRC staff requests that AMS supplement the application to address the information requested in this letter within 30 days of the date of issuance of this letter, as discussed with your staff during the acceptance review conference call. This will enable the NRC staff to begin its detailed technical review. If the information responsive to the NRC staffs request is not received by the above date, the application will not be accepted for review pursuant to 10 CFR 2.101, and the NRC will cease its activities associated with the application. If the application is subsequently accepted for review, you will be advised of any further information needed to support the NRC staffs detailed technical review by separate correspondence.
If you have any questions, please contact the AMS Project Manager, Jeffery Smith at Jeffery.Smith@nrc.gov.
Sincerely,
/RA/
Aida Rivera-Varona, Deputy Division Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
ML24306A115 OFFICE NRR/DORL/LLPB/PM NRR/DORL/LPLB/LA NRR/DEX/ELTB/SEE NRR/DEX/ELTB/BC NAME JSmith DHarrison MMcConnell JPaige DATE 11/1/2024 11/1/2024 11/4/2024 11/4/2024 OFFICE NRR/DORL/LLPB/BC NRR/DEX/DD NRR/DORL/DD NAME GGeorge TMartinezNavedo ARiveraVarona DATE 11/04/2024 11/4/2024 11/5/2024