ML19257B455
| ML19257B455 | |
| Person / Time | |
|---|---|
| Issue date: | 11/20/1979 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19257B448 | List: |
| References | |
| REF-GTECI-0000, REF-GTECI-A-24, REF-GTECI-AC, REF-GTECI-EL, TASK-A-24, TASK-OR SECY-79-677, NUDOCS 8001160284 | |
| Download: ML19257B455 (3) | |
Text
ENCLOSUME I SEci-JV-U9 For_:
The Comissioners Thru:
Office of the Executive Director for Operations From:
H. R. Denton, Director, Office of Nuclear Reactor Regulation
Subject:
INFORMATION REPORT - UNRESOLVED SAFETY ISSUE A-24
Purpose:
To inform the Comissioners of the issuance for comment of NUREG-0588, " Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment", as the staff resolution for Unresolved Safety Issue (USI) A-24.
Discussion:
In SECY 79-409A dated September 28, 1979, I stated nty intention to transmit to the Comission an information report upon completion of each USI.
In addition to transmitting the NUREG report providing the staff's generic resolution of the issue, this infomation report includes the staff's plans for implementing the positions presented in the NUREG.
Enclosed you will find copies of the "For Comment" edition of NUREG-0588, entitled " Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment." This document provides the staff's resolution of this generic issue.
It provides the NRC staff's technical positions on selected areas of environmental qualification, and provides guidance and describes methods which, when implemented, will ensure compliance with the Comission's requirements. The areas addressed include requirements for establishing the service conditions, for areas inside and outside containment, to which equipment should be qualified; the selection of the qualification methods to be used for the equipment in these areas; and the preparation of qualification documentation. This report also defines the applicability of these positions to the different vintage plants undergoing a review for a construction permit or an operating license.
NUREG-0588 does not apply directly to plants currently operating.
The Division of Operating Reactors (DOR) has developed a separate set of guidelines to assist the Office of Inspection and Enforce-ment (IE) in the review of the responses to Bulletin 79-01.'
These guidelines were discussed during the July 11, 1979 Comission briefing on IE Bulletin 79-01. They address the same aspects of environmental qualification as are covered in NUREG-0588, and were formulated to assist in the identification of potentially inadequate qualification of equipment at operating plants. Once equipment is so identified, resolution of the qualification adequacy will be developed by DOR. The staff goal is to use the NUREG-0588 whenever possible to resolve open issues from the IE reviews that use the D0R guidelines.
Copies of the DOR Guidelines and NUREG-0588 will be forwarded to all licensees.
Contact:
A. Szukiewicz x27387 1750 247 soonno 2fV
The Comissioners.
' Task Action Plan A-24 was established to review generically
Background:
industry's implementation of the qualification criteria defined in IEEE Std. 323-1974, IEEE Standard for Qualification of Class IE Equipment for Nuclear Power Generating Station.
Ini tially, the topical reports from the NSSS suppliers and major balance of plant (BOP) designers were to be evaluated; however, only the NSSS suppliers have comitted to provide the generic reports while the B0P designers opted for providing the information in the individual SAR applications. The initial reviews of the topical reports revealed wide variation in their scope and quality. As a result, Task Action Plan A-24 was modified to include the development of an NRC interim position (i.e.,
NUREG-0588) describing methods acceptable to the staff for meeting the requirements of IEEE Std. 323-1974 and to terminate Task A-24 at the completion of this position.
The review of the topical reports will be performed in conjunction with the specific lead-plant review schedules.
In addition to the positions related to IEEE Std. 323-1974 NUREG-0588 includes positions regarding methods acceptable to the staff for meeting the requirements of IEEE Std. 323-1971. This earlier standard is used by the staff as a basis for assessing the adequacy of qualification of equipment in i
plants that received their t.'nstruction permits prior to July 1974 (some of which are arrently in the operating license review stage). These positions supplement the requirements found in the 1971 and the 1974 versions of the IEEE Std. 323 and will be used together with these standards as the basis for reviewing the topical reports and the lead-plant specific infonnation on all license applications.
Implementation:
In implementing the positions described in NUREG-0588, the staff will require the following:
8 For all OL applicantions the applicants will be required to document in their FSAR the degree to which their qualification programs conply with the staff's positions described in NUREG-0588, and their bases for deviations.
. Deviations from those positions will be addressed in the SERs and their supplements.
In addition, the staff plans to modify slightly its '
implementation of IEEE Std. 323-1974.
Regulatory Guide 1.89, issued in November of 1974, requires that all CP applications for which a staff Safety Evaluation Report was issued after July 1,1974, should comply with the requirements of IEEE Std. 323-1974.
It has been staff -
practice to require that all other applicants comply with IEEE Std. 323-1971. This continues to be the staff practice with the following exceptions:
1750 248
.[Comissioners. g'I 0 Equip:..ent which would normally be qualified in accordance r gementation:
e fContinuci)-
with IEEE Std. 323-1971, but which has not yet ur.dergone qualification testing, should be qualified in accordance with IEEE Std. 323-1974.
In implementing this guidance, the staff will use IEEE Std. 323-1974 and.the provisions of Sections 2 through 5 of the Category I positions described in NUREG-0588 in assessing the adequacy of all equipment purchased six months from the date of i'ssuance of NUREG-0588.
The service conditions developed in accordance with Section 1, Category II of NUREG-0588 may be used in meeting this requirement.
i e Beginning 12 months from the date of issuance of NUREG-05BP equipment which must undergo requalification testing should also be qualified in accordance with IEEE Std. 323-1974 and the provisions of Sections 2 through 5 of Category I positions j
described in NUREG-0588. The service conditions developed j
in accordance with Section I, Category II may be used in meeting this requirement.
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The staff plans to' issue NUREG-0588 for a 60-day public comr.ent
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peric2 and has prepared, for transmittal to the Office of the Secretary, the information necessary for a Federal Register j
i Notice regarding the issuance. A copy of the Notice is enclosed.
At the completion of the 60-day period, the staff will evaluate the comments received and, if needed, will issue a mpplement or revision to NUREG-0588. The target for issuing the supplement or revision is late April 1980.
Concurrent with this public comment, we will submit NUREG-0588 for review by the staff's Regulatory Requirements Review
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Comittee and the Advisory Comittee on Reactor Safeguards.
l Because of the need to review and resolve any comments received from the public, we do not anticipate full implementation of i
I these requirements until May 1980. However, in the interim, the positions described in NUREG-0588 are being used as guidance to the staff in reviewing applicant's qualification programs.
Copies of the document will alv be forwarded to the applicable Congressional Comittees for their reviewe 9'
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-Harold R. Denton, Director Office of Nuclear R actor Re 1 ti f
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