Re-establishing EQ regulatory compliance for a boric acid release event

In the event of a minor but extended duration boric acid release event at a commercial nuclear power facility, numerous inspections, assessments and refurbishment activities would be required prior to restart to assure acceptable structural integrity and equipment operability. One of these activities would consist of restoring compliance of the plant's Environmental Qualification (EQ) Program to 10 CFR 50.49 "The EQ Rule". This paper describes a point-by-point approach to restoring compliance for such a boric acid release event by rigorously considering all twelve paragraphs of the EQ rule using a re-compliance "building block" summary or matrix. The twelve paragraphs were broken down into eighteen distinct elements. It was determined that no actions were required for showing compliance to twelve of the eighteen elements. However, salient efforts are required to restore and demonstrate compliance for the remaining six elements.