ML26016A536
| ML26016A536 | |
| Person / Time | |
|---|---|
| Site: | 99902075 |
| Issue date: | 02/11/2026 |
| From: | James Smith Licensing Processes Branch |
| To: | Damaris Marcano Licensing Processes Branch |
| Shared Package | |
| ML26016A537 | List: |
| References | |
| EPID L-2024-TOP-0030, AMS-CABLE-TR-0 | |
| Download: ML26016A536 (0) | |
Text
Enclosure AUDIT REPORT
SUMMARY
FOR THE REVIEW OF ANALYSIS AND MEASUREMENT SERVICES CORPORATIONS TOPICAL REPORT AMS-CABLE-TR-0, CONDITION MONITORING METHODOLOGY FOR LIFE EXTENSION AND AGING MANAGEMENT OF ELECTRICAL CABLES DOCKET NO. 99902075 EPID L-2024-TOP-0030
1.0 BACKGROUND
By letter dated August 20, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24233A208), as supplemented on December 4, 2024 (ML24339B787), Analysis and Measurement Services Corporation (AMS, the applicant) requested review of a topical report (TR) on a condition monitoring methodology for aging management of electrical cables. This methodology may provide a means to extend the service life of electrical cables as installed in nuclear facilities by helping to quantify the aged condition of cables, provide information to make objective decisions about cable repair and replacement schedules, satisfy plant life extension requirements, and improve on the time-based approaches currently used to determine cable lifetime.
By email dated March 11, 2025 (ML25066A189), the U.S. Nuclear Regulatory Commission (NRC) staff accepted the TR for review (ML25066A190). The audit plan (ML25169A155) was issued on June 23, 2025, via email (ML25169A152). The audit began with an entrance meeting between the NRC staff and AMS on July 1, 2025, and ended with an exit meeting on September 30, 2025. The NRC staff performed the audit in accordance with the audit plan and Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-111, Regulatory Audits, Revision 2, dated December 2024 (ML24309A281).
2.0 REGULATORY AUDIT BASES TR AMS-CABLE TR-R0 would be applicable to safety and non-safety related electrical cables governed by Title 10 of the Code of Federal Regulations (10 CFR) 50.49, Environmental qualification of electric equipment important to safety for nuclear power plants, 10 CFR 50.65, Requirements for monitoring the effectiveness of maintenance at nuclear power plants, and 10 CFR Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants.
According to 10 CFR 50.49, licensees are required to establish a program for environmentally qualifying certain electric equipment that is relied upon to remain functional during and following design basis events to ensure the integrity of the reactor coolant pressure boundary; the capability to shut down the reactor and maintain it in a safe shutdown condition; or the capability to prevent or mitigate the consequences of accidents.
According to 10 CFR 50.65, licensees are required to monitor the performance or condition of structures, systems, or components (SSCs) against licensee-established goals, in a manner sufficient to provide reasonable assurance that these SSCs can fulfill their intended functions.
Part 54 of 10 CFR governs the issuance of renewed operating licenses and renewed combined licenses for nuclear power plants and include all SSCs relied on to comply with 10 CFR 50.49.
3.0 REGULATORY AUDIT OBJECTIVES The objective of this audit was to better understand, via an independent evaluation, the technical bases used to develop the cable condition monitoring methodology proposed in the TR and how the methodology could be consistently and conservatively applied and implemented. The NRC staff reviewed supporting documents, as discussed in Section 4.0 of the audit plan, to determine if additional information will require docketing to develop and support conclusions for the NRC staffs safety evaluation of the TR.
The NRC staff conducted both in-person and virtual audits that included comprehensive technical discussions and demonstrations of test techniques to help the staff gain a better understanding of the condition monitoring methodology.
4.0 AUDIT DISCUSSION Summary of Information in the Application:
AMS-CABLE-TR-0, Condition Monitoring Methodology for Life Extension and Aging Management of Electrical Cables, describes a condition monitoring methodology that could potentially extend the service life of electrical cables installed in nuclear facilities. The methodology could also help quantify the aged condition of cables, provide information to make objective decisions about cable repair and replacement schedules, satisfy plant life extension requirements, and improve upon time-based approaches currently used to determine cable lifetime.
Audit Activities:
During the audit, the NRC staff interviewed the applicants staff and reviewed documentation contained in the TR and provided by the applicant via a secure SharePoint site. The NRC staff performed two onsite audits at the applicants facility in Knoxville, TN where AMS staff discussed the history and development of the TR and performed demonstrations of test techniques that could be used for implementing the proposed methodology. During the two in-person and numerous virtual audit breakout sessions, the NRC staff discussed clarifying audit questions with AMS and other representatives, and documentation/responses provided by AMS.
Section 5.0 of this report lists the documents that were reviewed by the NRC staff and were found to be relevant to the TR. These documents were identified during the NRC staff review of the TR.
5.0 DOCUMENTS REVIEWED Document No.
Document Title Revision/Version DOE Report No.
DE-NE0008855/AMS Report No.
DOE2209R0 Development of Cable Aging Acceptance Criteria for Nuclear Facilities 09/29/2022 INPO AP-913 Equipment Reliability Process Description Revision 4 IEC TS 61244-1 Determination of long-term radiation ageing in polymers - Part 1: Techniques for monitoring diffusion-limited oxidation Edition 2 NA Figure 4.10.xlsx Uploaded 07/01/2025 NA Figure 4.2.xlsx Uploaded 07/01/2025 NA Figure 4.3.xlsx Uploaded 07/01/2025 NA T test - FTIR.xlsx Uploaded 06/30/2025 NA Figure 4.3 Discussion.docx Uploaded 07/01/2025 NA Figure 4.4.xlsx Uploaded 07/01/2025 NA Figure 4.4 Discussion.docx Uploaded 06/30/2025 NA t test - IR.xlsx Uploaded 06/30/2025 NA Figure 4.5.xlsx Uploaded 07/01/2025 NA Figure 4.5 Discussion.docx Uploaded 06/30/2025 NA Figure 4.7.xlsx Uploaded 07/01/2025 NA Figure 4.7 Discussion.docx Uploaded 07/01/2025 NA Figure 4.9.xlsx Uploaded 07/01/2025 NA Figure 4.9 Discussion.docx Uploaded 06/30/2025 NA Table 4.2.docx Uploaded 07/01/2025 NA Table 4.3.docx Uploaded 07/01/2025 NA Table 4.4.docx Uploaded 06/30/2025 NA Table 4.5.docx Uploaded 07/01/2025 6.0 TEAM AND REVIEW ASSIGNMENTS The audit team consisted of the following NRC staff:
NAME ASSIGNMENT DIVISION BRANCH Matthew McConnell Senior Electrical Engineer Division of Engineering and External Hazards (DEX)
Long-Term Operations and Modernization Branch (ELTB)
Lois James Senior Project Manager Division of Operating Reactor Licensing (DORL)
Licensing Projects Branch (LLPB)
Jeffery Smith Project Manager DORL LLPB The AMS audit team consisted of the following staff:
NAME AFFILIATION Casey Sexton AMS Trevor Toll AMS Ryan OHagan AMS Gary Harmon AMS Spencer Feuerstein Enercon Ron Wise Contech Engineered Solutions, Inc.
7.0 CONCLUSION
The audit accomplished the objectives and goals listed in Section 3.0 of the audit plan by allowing direct interaction with AMS technical experts and their consultants. The NRC staff was able to obtain clarification on multiple questions and witness demonstrations of the proposed methodology. The clarifications and demonstrations allowed the NRC staff to gain a better understanding of the TR. Based on the information reviewed during this audit, the AMS staff submitted an update to the TR for review (ML25279A025). The NRC staff does not intend to issue any request for additional information following this audit.