ML19208C840
| ML19208C840 | |
| Person / Time | |
|---|---|
| Issue date: | 08/06/1979 |
| From: | Kammerer C NRC OFFICE OF CONGRESSIONAL AFFAIRS (OCA) |
| To: | Ribicoff A SENATE |
| Shared Package | |
| ML19208C841 | List: |
| References | |
| NUDOCS 7909270559 | |
| Download: ML19208C840 (2) | |
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m e..,_m The Honorable Abraham Ribicoff IJnited States Senate Washington, D.C. 20510
Dear Senator Ribicoff:
On July 12, 1979, you asked for our connents on a letter you received from Mr. D. R. Lynch, Vice President of Sigma Instnaments, Inc.
In that letter, Mr. Lynch expressed his displeasure with the guidance that has been promulgated for qualifying equipment intended for use in nuclear power plants.
He suggests that the law be revised to allow the NRC to install and operate a system similar to that developed by the military for qualification of this type of equipment.
We understand Mr. Lynch's frustration with the difficulties experienced
'by equipment suppliers in qualifying their equipment for nuclear power plant service.
Equipment qualification for nuclear service has been a rapidly evolving field and the lack of specific requirements continues to work a hardship on equipment suppliers.
We have concluded, however, that a direct application of military product qualification procedures is not the best answer. The military is involved it.1 the procurement of a large variety of systems and equipment and their components.
Many of the components are used in a large number af systems and equipments, and this consideration is factorea inte military s;>ecifications.
The NRC is only concerned th safety related systems of nuclear power plants, and with r i to equipment qualification, the specific concern is whether the systems and their components will perform their safety functions under reactor accident condMions.
A further difference in needs results from the role of the military as a purchaser of equipment vs NRC's role as a safety regulator.
The nueds of the military result in a number of military specificatton requirements of interest only to a purchaser of equipment.
The are:a where the needs of the military and NRC are similar is that of providing qualification requirements that are specific enough to assure tha:t systems and equipment will perform their intended functions.
C0ur goal is to provide system safety requirements that address equipment qualifications specifically enough to permit reactor plant owners and designers to develop component procurement specifications that are unambiguous with regard to qualification requirements.
The NRC's effort to develop more specific equipment qualification requirements has been hamperec by a number of diff-icult technical
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problems.
Progress has been made in recent years by NRC, technical societies, and the nuclear industry in areas such as accelerated aging, accident simulation, and separate effects testing vs combined effects testing. We believe the progress made in equipment qualification has resulted in increased reactor safety.
These changes, however, have been disruptive for equipment suppliers, but because the direction has been toward more specific requirements, the long term effect should be positive.
The NRC staff plans to issue an interim position on equipment qualifications this month.
This document should aid reactor plant designers in understanding NRC requirements, but it will not be as specific as we intend our final position to be.
We will send Mr. Lynch a copy of the interim position.
We are continuing our efforts to make our equipment qualification requirements more specific. We intend to contact Mr. Lynch to explore further his ideas in the subject.
One approach being explored is for NRC, with assistance from the industry, to establish several classes of environments and service conditions for qualifying safety equipment.
This has the potential for reducing the number of corbinations of conditions presently used for equipment qualification, but would result in some equipment being qualified for more severe environments than it will experience in service.
Equipment purchasers could then include only the appropriate environ ental and service classification in their purchase specifications rather than specifying detailed, plant-specific conditions as is now the case.
We also believe that the development and use by industry of an independent qualifications test laboratory could simplify the qualification process and enhance product quality.
We are continuing to assess such approaches as we deveImp our position on the qualification issue.
I hope you find these comnents useful.
If I can be of further assistance, please contact me.
Sincerely, f
WJ Carl (on Ka;
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trer. Director 2/' Office of L 4gr3ssional Affairs o hh UI) 4s I N I, ,9 ; ; ; [ y (1
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