ML18354A862

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Periodic Review Rg 1.89
ML18354A862
Person / Time
Issue date: 12/20/2018
From:
NRC/RES/DE
To:
Eudy M
Shared Package
ML18354A856 List:
References
Download: ML18354A862 (2)


Text

Regulatory Guide Periodic Review Regulatory Guide Number: 1.89, Revision 1

Title:

Environmental Qualification of Certain Electric Equipment Important to Safety for Nuclear Power Plants Office/division/branch: RES/DE/ICEEB Technical Lead: Thomas Koshy Staff Action Decided: Revise

1. What are the known technical or regulatory issues with the current version of the Regulatory Guide (RG)?

Revision 1 of RG 1.89, Environmental Qualification of Certain Electric Equipment Important to Safety for Nuclear Power Plants, was issued in June 1984. Rev. 1 of RG 1.89 endorsed the use of the Institute of Electrical and Electronic Engineers (IEEE)

Standard (Std.) 323-1974. The IEEE updated this standard in 1983, 2003 and then again in 2016. However, the NRC did not endorse IEEE Std. version 1983 and 2003.

In 2016, the IEEE Standard was issued as a joint logo International Standard with International Electro-technical Commission (IEC) IEC/IEEE 60780-323:2016, Nuclear Facilities-Electric Equipment important to safety--Qualification. The joint standard describes principles, methods, and procedures for qualifying, maintaining, and extending qualification, as well as updating qualification, of Class 1E equipment and interfaces that are to be used in nuclear power plants, including components or equipment of any interface whose failure could adversely affect any Class 1E equipment. In addition, the joint standard incorporates the approach on condition-based qualification to be utilized for extending qualified life for the license renewal period.

Revision 1 of RG 1.89 and the 2016 joint standard do not address the need to reassess and extend the qualified life of electrical equipment to avoid common-cause failures of the safety-related equipment when it is required to perform its safety function in a harsh environment. Therefore, a revision to the RG should take this into account.

Furthermore, Rev 1 of RG 1.89 is based on the source term information in Technical Information Document (TID) 14844, Calculation of Distance Factors for Power and Test Reactor Sites, dated 1962. Since then, the NRC staff has developed new source term guidance that better characterizes the anticipated source term in containment.

This new source term guidance is documented in NUREG-1465, Accident Source Terms for Light-Water Nuclear Power Plants - Final Report, issued in February 1995.

A RG revision should also reference the regulations in 10 CFR 50.67, Accident source term.

To verify the implementation of 10 CFR 50.49, Environmental qualifications of electric equipment important to safety for nuclear power plants, the NRC conducted inspections during 2017 and 2018 under the Reactor Oversight Program. There were several issues raised from the environmental qualification (EQ) inspections. The NRC staff is working with the industry to clarify existing staff positions. Draft Questions and

Regulatory Guide Periodic Review Answers regarding Unresolved Issues can be found in the Agencywide Document Access and Management System (ADAMS) under Accession No. ML18145A072 entitled, FAQs Draft Regarding Environmental Qualification 5-24-18. Any new/revised regulatory positions developed would be included in a revision of RG 1.89.

2. What is the impact on internal and external stakeholders of not updating the RG for the known issues in terms of anticipated numbers of licensing and inspection activities over the next several years?

The impact of not updating this RG would be continued identification of unresolved issues in plant inspections, which involve significant NRC staff resources and industry resources to address. Not updating the RG would also prevent the staff and industry from gaining efficiencies from using integrated guidance that is currently distributed in license renewal and other interim staff guidance, as well as efficiencies from condition monitoring that could be adopted in new and supplemental test programs to support extended plant operation.

The impact for not updating this RG with respect to revised source term information is not as significant since the NRC staff has issued revised information in NUREG-1465 and new requirements in 10 CFR 50.67 to better characterize the anticipated source term in containment. However, updating this RG would provide new applicants a readily available reference to all the applicable documents for the environmental qualification program.

3. What is an estimate of the level of effort needed to address identified issues in terms of full-time equivalent (FTE) and contractor resources?

NRC staff requires approximately 0.5 FTE to integrate the distributed guidance in license renewal and subsequent license renewal, including clarification to staff positions resulting from the EQ inspection experience, and to complete the technical evaluation.

The resolution of industry comments would incur an additional 0.5 FTE to support the issuance of the final regulatory guide. No contractor support is anticipated.

4. Based on the answers to the questions above, what is the staff action for this guide (Reviewed with no issues identified, Reviewed with issues identified for future consideration, Revise, or Withdraw)?

Revise.

5. Provide a conceptual plan and timeframe to address the issues identified during the review.

The NRC staff is conducting a review of the subject IEC/IEEE 60780-323:2016 joint standard. The draft RG is anticipated to be developed by 2nd quarter of fiscal year (FY) 2019 and issued for public comment by the 4th quarter of FY2019.

NOTE: This review was conducted in December 2018 and reflects the staffs plans as of that date. These plans are tentative and are subject to change.