ML18241A369

NEI Presentation Operability Public Meeting August 30, 2018

ML18241A369
Person / Time
Issue date:	08/30/2018
From:	Joseph Holonich NRC/NRR/DLP/PLPB
To:
Holonich J, NRR/DLP, 415-7297
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Download: ML18241A369 (24)

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ENTRY CRITERIA FOR THE OPERABILITY DETERMINATION PROCESS NRC PUBLIC MEETING August 30, 2018

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Purpose

• Describe the Entry Criteria for the Operability Determination Process

- Examples will be used for:

Illustrating each of the criteria

Integrated examples to illustrate the entire process 2

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Background

• At a RUG III workshop held in May 2015, Operability Determination Process issues that were commonly encountered were discussed 3

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Inconsistencies in Current Guidance Inspection Manual (IMC) 0326 is not consistent in defining the conditions that warrant an Operability Determination IMC-0326 uses the following terms to describe the conditions when an Operability Determination should be performed:

- Page 1-reasonably indicating a degraded or nonconforming condition

- Page 6 - Potential degraded/nonconforming conditions

- Pages 5 & 8 - Actual degraded/nonconforming conditions

- Page 6 - Presumption of operability has been lost

- Pages 5 & 8 - Operability called into question 4

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Current Industry Situation

• Typical site performs some type of Operability Assessment roughly two to ten times per day or more

- ODP entry occurs thousands of times per year

- Includes any assessment of an SSCs functional capability

• Rarely, if ever, is a previously undetected inoperability uncovered

• The proposed revision to the ODP entry criteria is intended to address this situation 5

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Industry Solution NEI process defines the entry criteria of the Operability Determination Process based on the Technical Specification definition of Operability

- Definition of Operable solely addresses functions

- Operability is the responsibility of the licensee The Operability Process will be entered when all of the Three Required Criteria are satisfied

- SROs always will retain the option of requesting ODs

- All conditions continue to be assessed 6

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Three Required Criteria 1.

The deficient condition must affect a TS SSC installed in an operating unit.

A TS SSC is an SSC that has a functional impact on either:

o a specified safety function or o

a required and necessary support function 2.

The deficient condition must have a functional impact on the SSC. This includes the ability to perform required functions under postulated, off-normal design conditions.

3.

The functional impact of the deficient condition must be substantive (i.e. non-trivial).

Substantive means:

o The functional impact is observable or o

The deviation from as-designed values is more than 10%

7

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First Criterion 8

The deficient condition must affect a TS SSC installed in an operating unit.

A TS SSC is an SSC that has a functional impact on either:

• a specified safety function or

• a required and necessary support function Comments/Details Includes the SSCs design, which will involve engineering. Practically, it is most commonly:

• Calculations

• Purchase and/or design specifications Documentation deficiencies that may result in altered design requirements to possibly allow for either purchase of a different SSC or altered operation.

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Examples That Would Not Satisfy the First Criterion

• Vendor information associated with an SSC not installed

• Design information errors with no potential for either altering a design specification or the SSCs operation

• For example, drawing or database errors

• Procedure formatting issues

• An SSC with no relationship to any specified safety function or a required and necessary support function 9

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Examples That Would Satisfy the First Criterion Procedure issues that involve the execution of procedural steps, including procedural quality and/or completeness An SSC with any relationship to any specified safety function or a required and necessary support function A problem with a TS SSC has been discovered at a similar site within the nuclear industry. The problems presence has been confirmed on the unit.

Design information errors with a potential for either altering a design specification or the SSCs operation 10

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Second Criterion 11 The deficient condition must have a functional impact on the SSC. This includes the ability to perform required functions under postulated, off-normal design conditions.

Comments/Details If this Criterion is not satisfied, it describes issues that provide no direct evidence regarding the functional status of an installed SSC.

No direct evidence is intended to mean:

There is no observable functional effect under any condition.

No evidence or indication that a functional impact would be manifest under off-normal/accident conditions.

Situations that could represent a problem indicate the need for further investigative work rather than an OD.

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Examples That Would Not Satisfy the Second Criterion The absence of an aspect of Quality Assurance does not mean that a functional problem is present. (Could versus Does)

Deficiencies in design of non-TS testing programs. (e.g.

Preventative testing program does not follow vendor recommendations.)

Deficient and/or missing radiographs of welds Minor deficiencies in design documentation, including missing calculations.

No indication of functional issues associated with:

Non-safety-related SSCs (e.g.. Commercial grade gaskets) installed in safety-related applications Issues initiated by the 10 CFR 21 process 12

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Examples That Would Satisfy the Second Criterion Design documentation deficiencies that result in altered requirements Any indication of functional issues associated with:

Non-safety-related SSCs (e.g.. Commercial grade gaskets) installed in safety-related applications Issues initiated by the 10 CFR 21 process with indication of functional issues Procedure deficiencies that would prevent successful performance of a required TS function Megger reading of a motor winding deviating from design values 13

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Examples That Would Satisfy the Second Criterion Missing washers and/or wrong size nuts on a pipe hanger Corrosion on a structural steel member An SSC has exhibited a reduction in reliability that exceeds the site-specific monitoring standards In every instance, the common thread is that the issue reflects some type of actual problem with an installed TS SSC.

14

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Third Criterion 15 The functional impact of the deficient condition must be substantive (i.e. non-trivial).

• Substantive (more than trivial) means:

• The functional impact is observable or;

• The deviation from as-designed values is more than 10%

Comments/Details This Criterion acknowledges that SSCs are designed, licensed, and installed with substantial margins. It includes consideration of design errors resulting in functional impact.

If not satisfied, the issue would have the following characteristics:

The issue is manifest at functional level beneath that described in the UFSAR There is no functional effect observable under any condition No evidence or indication that a functional impact would be manifest under off-normal/accident conditions.

If the installed margin is amenable to an estimate, the margin loss is estimated to be approximately 10% or less

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Examples That Would Not Satisfy the Third Criterion

• Megger reading of a motor winding deviating by less than 10%

from design No unexplained motor symptoms

• Non-compliance with a code of construction (excluding ASME code class 1) of less than 10%

• Deviation from a parameter specified by the design, including EQ-related, by 10% or less

• Calculation error with results deviating by 10% or less For example, timing of safety injection timing did not properly account for loading of condensate pumps. Total condensate pump load is less than 10% of transformer design loading 16

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Examples That Would Satisfy the Third Criterion Cut electrical or instrument cable Any indication of functional issues associated with:

Non-safety-related SSCs (e.g.. Commercial grade gaskets) installed in safety-related applications Issues initiated by the 10 CFR 21 process Missing or improper pipe hanger components with local indication of physical instability Megger readings deviating from design values by more than 10%

Calculation error with results deviating by 10% or more e.g. Timing of safety injection timing did not properly account for loading of condensate pumps Total condensate pump load is more than 10% of transformer design loading 17

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Summary Flowchart 18 The deficient condition must affect a TS SSC installed in an operating unit.

A TS SSC is an SSC that has a functional impact on either:

• a specified safety function or;

• a required and necessary support function The deficient condition must have a functional impact on the SSC. This includes the ability to perform required functions under postulated, off-normal design conditions.

The functional impact of the deficient condition must be substantive (i.e. non-trivial).

All Yes indicates that an Operability Determination is Required Any No indicates that an Operability Determination is Not Required

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Illustration of Examples 19 Non-safety related (NSR) Containment cooler fails Used to maintain containment pressure within specified limits

1. 1

1. 2

1. 3 No N/A N/A NSR gasket installed in ECCS discharge piping discovered during an audit

1. 1

1. 2

1. 3 Yes No N/A NSR gasket installed in ECCS discharge piping discovered following a plant walkdown identification of a leak

1. 1

1. 2

1. 3 Yes Yes Yes

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Illustration of Examples (cont.)

20 Vendor-recommended tests not performed on Safety-Related relays in an ECCS system

1. 1

1. 2

1. 3 Yes No N/A Vendor-recommended tests on Safety-Related relays in an ECCS system has failed in an undetected manner in the past

1. 1

1. 2

1. 3 Yes Yes Yes A steam trap that drains the steam supply to the turbine driven AFW pump governor is flooded

1. 1

1. 2

1. 3 Yes Yes Yes

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Illustration of Examples (cont.)

21 Important ECCS Operating Procedure steps are out of sequence

1. 1

1. 2

1. 3 Yes Yes Yes ECCS Operating Procedure steps are vague and could allow improper operation

1. 1

1. 2

1. 3 Yes No N/A Calculation error found resulting in a required ECCS pump flow increasing from 280 GPM to 290 GPM

1. 1

1. 2

1. 3 Yes Yes No

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Summary The revised entry criteria (Three Required Criteria) provides a more consistent entry process linked to the Technical Specification definition of Operability There is no change to the conduct of an ensuing Operability Determination due to the application of the Three Required Criteria 22

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Look Ahead The next meeting will focus on the NRC providing feedback on the Operability Determination Process Entry Criteria.

In a future meeting we will present the definition of Specified Safety Function (SSF)

- The Operability Determination Process is oriented around SSF 23

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QUESTIONS / DISCUSSION 24