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Denial of a Non-Cited Violation Involving the Qualification of Class 1E Electrical Equipment and Backfit Claim Proposing the NRC Action Constitutes a Plant-Specific Backfit
	ML17355A493
Person / Time
Site:	Sequoyah
Issue date:	12/21/2017
From:	James Shea; Tennessee Valley Authority
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	CNL-17-068
	Download: ML17355A493 (25)
	v • d • e

Tennessee Valley Authority, 1101 Market Street, Chattanooga, TN 37402 CNL-17-068 December 21, 2017 10 CFR 50.4 10 CFR 50.109 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Sequoyah Nuclear Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-77 and DPR-79 NRC Docket Nos. 50-327 and 50-328

Subject:

Denial of a Non-Cited Violation Involving the Qualification of Class 1E Electrical Equipment and Backfit Claim Proposing the NRC Action Constitutes a Plant-Specific Backfit

Reference:

Letter from NRC to TVA, Sequoyah Nuclear Plant - NRC Evaluation of Changes, Tests, and Experiments and Permanent Plant Modifications Inspection Report 05000327/2015007 and 05000328/2015007, dated September 14, 2015 On July 31, 2015, the Nuclear Regulatory Commission (NRC) completed an inspection at Sequoyah Nuclear Plant (SQN) for Evaluation of Changes, Tests, and Experiments and Permanent Plant Modifications as documented in the above reference. NRC inspectors documented four non-cited violations (NCV) of very low safety significance (green) and one Severity Level IV NCV.

In accordance with 10 CFR 50.4 and the NRC Enforcement Policy, Tennessee Valley Authority (TVA) hereby submits its basis for why NCV 05000327, 328/2015007-05, Failure to Identify Qualification Criteria Associated with Class 1E Electrical Component Static Performance Characteristics, (SQN NCV) as documented in the above Reference, should not have been issued.

TVAs position is that the SQN NCV, as discussed in the Enclosure, represents a new NRC Staff position that appears to significantly expand the equipment qualification requirements for SQN by requiring SQN to establish qualification criteria for design life and certain performance characteristics for Class 1E molded case circuit breakers (MCCBs) in mild environments, contrary to the Commissions regulation in 10 CFR 50.49(c)(3), regulatory guidance, industry standards, and SQNs licensing basis. SQNs equipment qualification program for Class 1E MCCBs in mild environments is consistent with the Commissions regulations, guidance, and SQNs licensing basis.

U.S. Nuclear Regulatory Commission CNL-17-068 Page 2 December 21, 2017 Following receipt of the reference noted above, TVA did not initially dispute the SQN NCV because TVA's understanding was that the issue raised by the SQN NCV would be addressed by the NRC generically in an NRC Regulatory Issue Summary (RIS) and because TVA was informed that Region II would revisit the SQN NCV upon completion of this RIS addressing equipment service life issues. TVA actively engaged with the industry and the NRC in an attempt to appropriately resolve the issue raised in the SQN NCV. TVA personnel participated in public meetings and provided comments on the draft RIS since 2015. On September 14, 2017, TVA participated in a public meeting with the NRC Committee to Review Generic Requirements (CRGR) to provide comments on the draft RIS. On October 17, 2017, the CRGR issued a letter to the NRC Executive Director for Operations and recommended that the draft RIS not be issued. TVA is now submitting this denial and Backfit Claim setting forth the reasons that the SQN NCV should not have been issued, and making a backfit claim to the NRC Staff if the SQN NCV is not withdrawn.

If the NCV is not withdrawn, this letter provides a Backfit Claim for the SQN NCV because NCV 05000327, 328/2015007-05 is a new NRC Staff position that would greatly expand the requirements for equipment qualification in mild environments. As discussed in the Enclosure, the NRC Staff is required to conduct a backfit analysis for new staff positions as required by 10 CFR 50.109(a)(3). That backfit analysis must demonstrate that the backfit would lead to a cost-justified, substantial increase in public health and safety before the new NRC Staff position can be imposed on SQN. The Enclosure describes the basis for denying NCV 05000327, 328/2015007-05 and the Backfit Claim.

There are no regulatory commitments contained in this submittal. If you have any questions, please call Michael McBrearty, SQN Site Licensing Manager at (423) 843-7170.

J W. Shea ice President, Nuclear Regulatory Affairs and Support Services

Enclosure:

Denial for Violation Documented in NRC Inspection Report 05000327, 328/2015007 and Backfit Claim cc: (Enclosure)

Director of the Office of Nuclear Reactor Regulation (NRR)

Director of the Office of Enforcement Regional Administrator - Region II NRC Branch Chief - Region II NRC Senior Resident Inspector - Sequoyah Nuclear Plant NRC Project Manager - Sequoyah Nuclear Plant

ENCLOSURE TENNESSEE VALLEY AUTHORITY DENIAL FOR VIOLATION DOCUMENTED IN NRC INSPECTION REPORT 05000327, 328/2015007 AND BACKFIT CLAIM E-1

ENCLOSURE DENIAL FOR VIOLATION DOCUMENTED IN NRC INSPECTION REPORT 05000327, 328/2015007 AND BACKFIT CLAIM TABLE OF CONTENTS Executive Summary I. NRC NON-CITED VIOLATION 05000327, 328/2015007-05: Failure to Identify Qualification Criteria Associated with Class 1E Electrical Component Static Performance Characteristics II. DENIAL AND BACKFIT CLAIM, NRC NON-CITED VIOLATION 05000327, 328/2015007-05 is a New Staff Position Which Requires a Backfit Analysis

1. Background

2. SQN Licensing and Design Basis 2.1 SQN Updated Final Safety Analysis Report (UFSAR) 2.2 Regulatory Requirements and Applicable Guidance

3. TVA Position - Establishing Performance Characteristics 3.1 NRC Statement 3.2 TVA Position 3.3 SQN Procurement Process

4. TVA Position - Establishing Qualification Criteria 4.1 NRC Statement 4.2 TVA Position 4.3 SQN Preventive Maintenance and Testing

5. Change in NRC Staff Position Requires a Backfit Analysis

6. Conclusion

7. References E-2

ENCLOSURE DENIAL FOR VIOLATION DOCUMENTED IN NRC INSPECTION REPORT 05000327, 328/2015007 AND BACKFIT CLAIM Executive Summary On July 31, 2015, the Nuclear Regulatory Commission (NRC) completed an inspection at Sequoyah Nuclear Plant (SQN) for Evaluation of Changes, Tests, and Experiments and Permanent Plant Modifications as documented in Inspection Report 05000327/2015007 and 05000328/2015007, dated September 14, 2015. NRC inspectors documented a non-cited violation (NCV) of very low safety significance (green) involving the failure to identify qualification criteria associated with Class 1E electrical component static performance characteristics (SQN NCV).

The violation specifically involved safety-related Class 1E replacement breakers located in mild environments at SQN installed under Design Change Notices (DCNs) 23085 and 23082.

The breakers from DCN 23085 are molded case circuit breakers (MCCBs) for the normal and alternate supply to the 480 Volt (V) Essential Raw Cooling Water (ERCW) Motor Control Centers (MCCs); the replacement breaker was necessitated by equipment obsolescence. The breaker from DCN 23082 is a MCCB associated with the 480V reactor vent boards that feed the ice condenser air handling units; the replacement breaker was evaluated as equivalent to the original breaker.

Tennessee Valley Authority (TVA) has reviewed the broad base of regulatory requirements and guidance and related industry standards as well as the SQN plant specific licensing basis; e.g. 10 CFR 50.49, NUREG-0800, RG 1.89, GL 82-09, and relevant IEEE standards. The applicable SQN Supplemental Safety Evaluation Reports (SSERs), as developed and approved by the Office of Nuclear Reactor Regulation (NRR) during original licensing, approved the SQN program and its alignment to the above regulations, standards, and guidance. TVAs review of the current SQN program found it to be consistent with the SSER approved program as originally reviewed and approved by NRR. Based on this review, TVA concluded that SQN programs and processes for qualification of Class 1E electrical equipment in mild environments are appropriate and consistent with SQN licensing basis, and regulatory requirements and guidance. Therefore, based on the understanding of and adherence to the program as originally approved, the SQN NCV represents a new NRC Staff position and new regulatory requirement.

As discussed above, SQN is in compliance with its approved licensing basis consistent with applicable Commission guidance, standards, and regulations, and SQNs design basis is in compliance with the Commissions regulations. The replacement breakers at issue were procured in accordance with TVA specifications and standards for safety-related electrical equipment, including environmental and seismic qualification requirements appropriate to equipment located in mild environments. As part of the review of DCNs 23085 and 23082, TVA determined that, consistent with the original breakers, the replacement breakers are not susceptible to significant degradation because they are installed in mild environments (as defined in 10 CFR 50.49(c)(3)), and, therefore, a qualified life is not required to be established, provided that the breakers are procured and maintained appropriately for the application. The replacement breakers were determined to be functionally equivalent to the originally installed breakers. The breakers are maintained and tested in accordance with the SQN breaker program, consistent with licensing and design requirements for safety-related Class 1E breakers located in mild environments.

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ENCLOSURE DENIAL FOR VIOLATION DOCUMENTED IN NRC INSPECTION REPORT 05000327, 328/2015007 AND BACKFIT CLAIM TVA believed that the issue related to qualification criteria associated with Class 1E electrical component static performance characteristics would be addressed through a Regulatory Issue Summary (RIS), Disposition of Information Related to the Time Period that Safety-Related Structures, Systems or Components are Installed. On September 14, 2017, TVA participated in a public meeting with the NRC Committee to Review Generic Requirements (CRGR) to provide comments on the draft RIS. On October 17, 2017, the CRGR issued a letter to the NRC Executive Director for Operations and recommended that the draft RIS not be issued due to the risk of unintended backfit and the potential to cause backfit problems during implementation of the inspection program. Consequently, TVA is submitting a denial of the NCV and requests that the NRC withdraw the NCV. Should the NRC not withdraw the NCV, TVA is concurrently submitting a backfit claim so that the NRC Staff, in accordance with 10 CFR 50.109, Backfitting, and the policy reflected in NUREG-1409, Backfitting Guidelines, will review the NRC Staff position in the SQN NCV as a plant-specific backfit. As a backfit, the NRC Staff cannot impose the position until it has performed the required backfitting analysis pursuant to 10 CFR 50.109(a)(3) and determined the backfit is justified.

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ENCLOSURE DENIAL FOR VIOLATION DOCUMENTED IN NRC INSPECTION REPORT 05000327, 328/2015007 AND BACKFIT CLAIM I. NRC NON-CITED VIOLATION 05000327, 328/2015007-05: Failure to Identify Qualification Criteria Associated with Class 1E Electrical Component Static Performance Characteristics NRC Inspection Report 05000327, 328/2015007, dated September 14, 2015, states non-cited violation (NCV) 05000327, 328/2015007-05 as follows (emphasis added):

10 CFR Part 50, Appendix B, Criterion III, Design Control, stated, in part, that Measures shall be established for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of the structures, systems and components. Contrary to the above, since 2013, the licensee failed to establish measures for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of the structures, systems and components. Specifically, the licensee failed to establish measure for the selection and review for suitability of static and dynamic performance characteristics used in the design and qualification of Class 1E electrical equipment. Because the finding was of very low safety significance (Green) and was entered into the licensees corrective action program as CR 1064785, this violation will be treated as an NCV consistent with section 2.3.2 of the NRC enforcement policy. This violation is identified as NCV 05000327, 328/2015007-05, Failure to Identify Qualification Criteria Associated with Class 1E Electrical Component Static Performance Characteristics.

In describing this violation, NRC Inspection Report (IR) 2015-007, also stated, The inspectors identified that the licensee did not establish qualification criteria for design life, and [t]he inspectors determined that, the static and dynamic performance characteristics over normal service conditions described conditions related to shelf life and design life.

TVA Position TVAs position is that 10 CFR Part 50, Appendix B, Criterion III, Design Control, was appropriately applied to the design, selection and installation of the safety-related molded case circuit breakers described in the violation. The replacement breakers described in the NCV are functionally equivalent to the original breakers installed in the plant, and comply with the same design requirements as the original breakers. Consistent with the original breakers, once installed, station surveillance and preventive maintenance programs, through implementing procedures, provide continued review of the circuit breakers for suitability and quality. This practice is consistent with SQNs approved licensing basis, and with long-established NRC rules and guidance for safety-related electrical equipment located in mild environments, and with industry practice for such equipment. The NRC finding effectively treats safety-related electrical equipment located in mild environments similarly to the treatment of such equipment located in a harsh environment. The NRC finding requires the replacement breakers to satisfy a different requirement than the original breakers; i.e., the requirements for equipment installed in harsh environments. 10 CFR Part 50.49, establishes requirements for environmental qualification of electrical equipment important to safety for nuclear power plants, and 10 CFR Part 50.49(c) specifically states, [r]equirements for (1) dynamic and seismic qualification of electric equipment important to safety, (2) protection of electric equipment important to safety against other natural phenomena and external events, and (3) environmental qualification of electric equipment important to safety located in a mild environment are not included within the scope of this section.

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ENCLOSURE DENIAL FOR VIOLATION DOCUMENTED IN NRC INSPECTION REPORT 05000327, 328/2015007 AND BACKFIT CLAIM When TVA replaced the subject equipment described in the SQN NCV, the procurement specifications were consistent with the procurement specifications for the original equipment during initial plant licensing. TVAs program for safety-related equipment located in a mild environment is consistent with the NRC position/requirements delineated in Generic Letter 82-09.(GL 82-09), Question and Answer (Q&A) 4, which was issued during promulgation of the rule specified in 10 CFR Part 50.49, Environmental Qualification of Safety Related Electrical Equipment. GL 82-09, Q&A 4 states:

Q. Can periodic surveillance, testing and maintenance programs adequately demonstrate qualification of electrical equipment in mild environments?

A. For existing equipment located in mild environments, equipment environmental qualification can be adequately demonstrated and maintained by the use of the following three programs:

1. A periodic maintenance, inspection, and/or replacement program based on sound engineering practice and recommendations of the equipment manufacturer which is updated as required by the results of an equipment surveillance program;

2. A periodic testing program to verify operability of safety related equipment within its performance specification requirements (system level testing of the type typically required by the plant technical specifications may be used); and

3. An equipment surveillance program which includes periodic inspections, analysis of equipment and component failures, and a review of the results of preventive maintenance and periodic testing programs.

For replacement and new equipment, the licensee must also establish and document the environmental design basis for the equipment locations. The purchase specifications must reflect those design basis environmental conditions that are bounding for all applicable equipment locations.

The Statements of Consideration for the 10 CFR 50.49 rule (48 FR 1983) further note that, [t]he final rule does not cover the electric equipment located in a mild environment. The Commission has concluded that the general quality and surveillance requirements applicable to electric equipment as a result of other Commission regulations, including 10 CFR Part 50, Appendix B (see for example, Regulatory Guide 1.33, Quality Assurance Requirements (Operation),

Revision 3) are sufficient to ensure adequate performance of electrical equipment important to safety located in mild environments. Since it has been concluded that no further environmental qualification requirements are needed for such equipment provided they fully satisfy all other applicable regulations, the Commission has determined that no additional requirements are necessary with respect to electric equipment located in mild environments in order for licensees to satisfy, with respect to such equipment, existing license conditions or technical specifications calling for qualification of safety-related electric equipment in accordance with DOR Guidelines or NUREG-0588.

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ENCLOSURE DENIAL FOR VIOLATION DOCUMENTED IN NRC INSPECTION REPORT 05000327, 328/2015007 AND BACKFIT CLAIM TVAs review showed evidence that TVA complies with its approved licensing basis, and with the NRC staff position established in GL 82-09, Q&A 4, and is consistent with the Statements of Consideration for 10 CFR Part 50.49 published at 48 FR 1983 associated with safety-related electrical equipment in a mild environment. For the replacement equipment described in the SQN NCV, the purchase specification reflected those design basis environmental conditions that are bounding for the equipment location.

In IR 2015-007, the NRC introduced a new staff position/interpretation regarding requirements for safety-related equipment located in a mild environment; specifically with respect to the NRCs interpretation that static and dynamic performance characteristics require specification of a shelf life and design life. This interpretation effectively extends the rules for safety-related equipment located in harsh environments to safety-related equipment located in mild environments. This new position conflicts with existing NRC rules and guidance specifically for equipment located in mild environments. The NRC violation described in IR 2015-007 conflicts with the staff position delineated in GL 82-09, and establishes new requirements for safety-related equipment located in a mild environment.

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ENCLOSURE DENIAL FOR VIOLATION DOCUMENTED IN NRC INSPECTION REPORT 05000327, 328/2015007 AND BACKFIT CLAIM II. DENIAL AND BACKFIT CLAIM, NRC NON-CITED VIOLATION 05000327, 328/2015007-05 is a New Staff Position Which Requires a Backfit Analysis

1. Background

On May 7, 2015, NRC issued Task Interface Agreement (TIA) 2014-01 concerning inspections conducted during 2012 and 2013 at Monticello, D.C. Cook, and Palisades where NRC inspectors identified several safety-related structures, systems, or components (SSCs) in mild environments installed for periods greater than the period of time specified in vendor correspondence, vendor manuals, or Certificates of Compliance. The TIA specified that all SSCs require a determination of how long an installed SSC can be relied upon to perform its safety function.

On September 14, 2015, NRC issued Non-Cited Violation (NCV) 05000327, 328/2015007-05 documented in Inspection Report 05000327, 05000328/2015007 (SQN NCV) for SQN. The violation specifically involved safety-related Class 1E replacement breakers located in mild environments at SQN installed under Design Change Notices (DCNs) 23085 and 23082. The breakers from DCN 23085 are molded case circuit breakers (MCCBs) for the normal and alternate supply to the 480 Volt (V) Essential Raw Cooling Water (ERCW) Motor Control Centers (MCCs). The breaker from DCN 23082 is a MCCB for the 480V reactor vent boards that feed the ice condenser air handling units. During and after the onsite inspection at SQN, NRC Staff repeatedly referred to the staff position established in TIA 2014-01 to support the violation, and as a basis for not treating the issue as an Unresolved Item.

In an October 6, 2015, phone call with NRC Region II, SQN was granted an extension for providing a response to the NRC from the original 30-day response period to November 13, 2015. At that time, SQNs intent was to deny the NCV.

On October 1, 2015, the NRC rescinded TIA 2014-01 with the intent of developing a Regulatory Issue Summary (RIS) to communicate the NRC Staffs positions on service life. Even though TIA 2014-01 had been rescinded, the Nuclear Energy Institute (NEI) submitted a letter to the NRC on October 20, 2015 with subject, Industry Position on the Role of Vendor Recommendations for Service Life of Safety-Related Components, that documented the industrys concerns with regulatory positions taken in TIA 2014-01. One of these concerns was that TIA 2014-01 appeared to change existing NRC positions on preventative maintenance requirements for safety-related equipment in mild environments. The letter submitted by NEI directly addressed the issue raised by the SQN NCV.

TVA discussed the SQN NCV with NRC Region II on November 3, 2015. The following individuals participated: TVA Vice President - Licensing, Senior Manager - Fleet Regulatory Operations, NRC - Director of Reactor Safety, Region II and NRC - Director of Reactor Projects, Region II. During the discussions, NRC indicated that, even if TVA did not deny the SQN NCV, NRC Region II would reexamine the SQN NCV after the agency completed its review of the October 20, 2015 NEI letter and issued the RIS. Following the discussions, a decision was made by TVA to delay submitting a formal letter contesting the SQN NCV at that time and work with the industry on review of the RIS to address the SQN NCV. TVA likewise decided not to contest or submit a clarification letter that had been drafted regarding the SQN NCV because TVA believed that the SQN NCV would be resolved through the RIS and that Region II would then reexamine the SQN NCV. TVA actively engaged with industry and the NRC on service life issues and development of the service life RIS.

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ENCLOSURE DENIAL FOR VIOLATION DOCUMENTED IN NRC INSPECTION REPORT 05000327, 328/2015007 AND BACKFIT CLAIM Between December 2015 to present, the NRC issued preliminary drafts of the service life RIS, and held public meetings to solicit industry and public feedback. TVA actively participated in the industry efforts regarding the development of the RIS in order to support resolution of this generic industry issue regarding regulatory requirements for electrical equipment in mild environments. The most recent NRC public meeting was conducted on September 14, 2017, during which NEI (including a representative from TVA) presented the industrys position. On October 17, 2017, the CRGR issued a letter to the NRC Executive Director for Operations and recommended that the draft RIS not be issued.

The timeline table below provides a synopsis of the above discussion chronologically.

Service Life Interaction Timeline Date Activity May 7, 2015 NRC issues TIA 2014-01 September 14, 2015 SQN receives NCV for safety-related Class 1E components in mild environments October 1, 2015 NRC rescinds TIA 2014-01 October 6, 2015 Teleconference between NRC Region II and TVA regarding response to SQN NCV October 20, 2015 NEI submits letter to NRC regarding concerns with rescinded TIA 2014-01 November 3, 2015 Discussions between NRC Region II and TVA (addressed SQN NCV)

December 9, 2015 NRC issues preliminary draft of RIS 2016-XX on Service life January 20, 2016 NRC Public Meeting on preliminary draft RIS 2016-XX May 10, 2016 NRC issues revised draft RIS 2016-XX for public comment June 1, 2016 Initial meeting of NEI Service life Focus Group to develop comments on draft RIS June 23, 2016 NEI Service life Focus Group meeting to finalize comments July 18, 2016 NEI submits draft RIS comment letter to NRC July 21, 2016 NEI RITF meeting October 19-20, 2016 NEI RITF and RIWG meetings October 31, 2016 NRC issues draft RIS comment resolutions November 18, 2016 NEI Service life Focus Group to review NRC comment resolutions November 30, 2016 RUG II meeting February 2, 2017 NEI RIWG meeting September 14, 2017 NRC CRGR Public Meeting Regarding Draft RIS October 17, 2017 CRGR recommends the RIS not be issued E-9

ENCLOSURE DENIAL FOR VIOLATION DOCUMENTED IN NRC INSPECTION REPORT 05000327, 328/2015007 AND BACKFIT CLAIM Based on the above, TVA is submitting the backfit claim with respect to the SQN NCV with an explanation of why the NCV should not have been issued.

2. SQN Licensing and Design Basis 2.1 SQN Updated Final Safety Analysis Report (UFSAR)

The licensing basis for SQN is delineated in the SQN UFSAR, which references NRC Regulatory Guide (RG) 1.89, and Institute of Electrical and Electronics Engineers (IEEE) standards IEEE 323-1971 and IEEE 323-1974. The UFSAR identifies equipment and systems subject to 10 CFR 50.49 and the SQN implementing procedures for environmental qualification.

For Engineered Safety Features (ESF) equipment located in a mild environment, the SQN UFSAR Section 3.11.2.3, Environmental Design of ESF Components, states:

ESF Systems and RPS components have established industrial ratings equal to or in excess of the required environmental capabilities. These environmental capabilities are demonstrated by testing or by appropriate analyses. The 10 CFR 50.49 scope equipment is addressed under the harsh environment qualification program (see Section 3.11.2.4).

Qualification of other equipment important to safety is addressed by design/purchase specifications, functional requirements, and associated environmental conditions. Periodic maintenance and surveillance adequately demonstrates qualification of equipment in mild environments.

As described in this enclosure, the SQN UFSAR prescribes qualifying ESF equipment located in a mild environment that is consistent with industry-accepted practices, and NRC requirements and guidance. The SQN UFSAR, Section 8.1.5 states:

Although the design of the electric power system for the Sequoyah Nuclear Plant preceded the publication of several of the standards and regulatory guides referenced below, it is TVA's belief that the design meets the intent of those standards and guides.

The standards and guides listed in the SQN UFSAR include IEEE 279-1971, IEEE 308-1971, and IEEE 323-1971, which SQN applied to the MCCBs described in the SQN NCV. Equipment qualification requirements from each of these IEEE standards are provided below.

IEEE 279-1971, Criteria for Protection Systems for Nuclear Power Generating Stations, Section 4.4, discusses equipment qualification as follows: Type test data or reasonable engineering extrapolation based on test data shall be available to verify that protection system equipment shall meet, on a continuing basis, the performance requirements determined to be necessary for achieving the system requirements.

IEEE 308-1971, Criteria for Class 1E Electric Systems for Nuclear Power Generating Stations, Section 4.7, discusses equipment qualification as follows: Each type of Class 1E electric equipment shall be qualified by analysis, successful use under similar conditions, or by actual test to demonstrate its ability to perform its function under normal and design basis events.

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ENCLOSURE DENIAL FOR VIOLATION DOCUMENTED IN NRC INSPECTION REPORT 05000327, 328/2015007 AND BACKFIT CLAIM IEEE 323-1971, Qualifying Class 1 Electric Equipment for Nuclear Power Generating Stations, Sections 3, 5.1, and 5.2, discusses equipment qualification as follows: Each type of equipment is qualified for its application. Type test data shall contain equipment specifications, identification of specific features to be demonstrated by the type test, test program outline (typically includes service conditions and design basis event conditions to be simulated, static and dynamic performance characteristics, etc.), and test results. Service conditions are defined as environmental, power and signal conditions expected as a result of normal operating requirements, expected extremes in operating requirements and postulated conditions appropriate for the design basis events of the station.

2.2 Regulatory Requirements and Applicable Guidance The NRCs requirements with respect to environmental qualification are set forth in 10 CFR 50.49. 10 CFR 50.49, Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants, establishes qualification requirements for equipment only in non-mild environments. Of note, 10 CFR 50.49(c)(3) states:

Requirements for environmental qualification of electric equipment important to safety located in a mild environment are not included within the scope of this section. A mild environment is an environment that would at no time be significantly more severe than the environment that would occur during normal plant operation, including anticipated operational occurrences.

In addition, the NRC guidance in NUREG-0800, Standard Review Plan, Revision 3, March 2007, Section 3.11, Environmental Qualification of Mechanical and Electrical Equipment, states for mild environments:

For electrical and mechanical equipment located in a mild environment, acceptable environmental design can be demonstrated by the "design/purchase" specifications for the equipment. The specifications must contain a description of the functional requirements for a specific environmental zone during normal environmental conditions and anticipated operational occurrences.

A well-supported maintenance/surveillance program, in conjunction with a good preventive maintenance program, is sufficient to ensure that equipment that meets the design/purchase specifications is qualified for the designed life. Compliance with 10 CFR 50.65, "Requirements for monitoring the effectiveness of maintenance at nuclear power plants," and associated guidance in Regulatory Guide 1.160 are sufficient to provide reasonable assurance that environmental considerations established during design are reviewed every refueling outage and maintained on a continuing basis to ensure that the qualified design life has not been reduced by thermal, radiation, and/or cyclic degradation resulting from unanticipated operational occurrences or service conditions. Modification to the replacement program and/or replacement of equipment should be based on the review of maintenance/surveillance data.

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ENCLOSURE DENIAL FOR VIOLATION DOCUMENTED IN NRC INSPECTION REPORT 05000327, 328/2015007 AND BACKFIT CLAIM Design specifications will be discussed in Section 3.3.

Generic Letter 82-09.(GL 82-09), Question and Answer (Q&A) 4, states: