ML20004E367
| ML20004E367 | |
| Person / Time | |
|---|---|
| Issue date: | 03/09/1981 |
| From: | Gregg H NRC OFFICE OF STANDARDS DEVELOPMENT |
| To: | |
| Shared Package | |
| ML19252A551 | List: |
| References | |
| FOIA-81-97, TASK-OS, TASK-SC-138-1 NUDOCS 8106120089 | |
| Download: ML20004E367 (7) | |
Text
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i REQUESTOR Z. R. Rosztoczy EXT.28035 ORGANIZATION NRR TASK LEADER H. I. Gre99 INIT 1
_ BR. CHIEF W. F. Anderson INIT tu) 4 TASK l' UMBER SC 138-1 Dy[PA NUMBER 1111
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TASK DGR' PTION (100 CHARACTERS)
Develop Reg. on Qualif. of Mech. Equip. via Adv. Notice of Rulemaking Process TASK PRIORITY ' A TASK TYPE __
START DATE Jan 14. 1981-ESTIMATED COMP DATE Sept. 30, 1981 to issue ANF TASK ACTION ADD x DELETE CHANGE TRANSFER
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INTO HOLD OUT OF HOLD NEW TASK NO. SC 138-1 EFFECTIVE DATE OF ACTION March 9.1981 WORKING DAYS SLIPPAGE
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COGNIZANT INDIVIDUALS DIVISION APPROVAL DATE NRR C. Hofmayer DE HMSS IE W. R. Rutherford DRRRI l
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SD APPROVAL: _ T1. H. I. bregg
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DATE COMMENTS This is the task initiatio'n for developing a regulation on qualification of l
mechanical equipment via an advance notice of rulemaking.
The draft preliminary Value/ Impact Statement is attached.
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ADVAf1CE fl0TICE OF PROPOSED RULE!!AKlfiG; I;ECHArilCAL, EQUIPl1EfiT QUAllFICAT10ft Prepare Prelim. Value/ Impact Statenent & TIF 3-10 -81 TIF Approved 3-30-81 Initial A!;R Draft Complete 4-30 -81 Prelim. Interoffice Concurrence C(urplete 5-30'-81 Resolution of Comments Complete 6-25 81 Final A!;R Complete 6-30 81 FII:AL Af;R Concurrence Complete 7-30-81 Submit to ED0/Connission 8-15 -81 AfiR Published in Federal Register 9-30 -81 S
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2/23/81 A Q DRAEI PRELIMINARY VALUE/IMPACI SIAIEMENI E02 i
REVISION 10 10 CER 50 QUALIEICAIIONDEMECHANICALEQUIPMENIIMPORIANI10SAEEIY 1.
PROPOSED ACIION 1.1 Description Issue an Advance Notice of Rulemaking (ANR) as the first step in devel-oping a regulation to require applicants and licensees of nuclear power plants to qualify mechanical equipment important to safety.
1.2 Need A memorandum from H. R. Denton, Director of NRR, to R. B. Minogue, Director of OSD, dated September 2,1980, defined the need and requested a single rule-making to include environmental qualification of electrical equipment, indepen-dent equipment qualification testing and laboratory accreditation, and qualifi-cation of both electrical and mechanical equipment.' Ihe response memorandum from R. B. Minogue, Director of 050, dated October 3, 1980, recommended separate rulemakings and.an attempt to consolidate them at a later date.
Subsequent discussions were held with Z. R. Rosztoczy, Chief of Equipment Qualification Branch, and verbal agreement was reached to proceed with a separate rulemaking for qualification of ' mechanical equipment.
Additional background which defines a need for this rulemaking is, there are mechanical equipment problems in nuclear power plants.
Ihe large number of continuing monthly Licensee Event Reports (LEHs) of valve and pump problems is evidence of mechanical equipment problems, and substantiates the need for the proposed regulation.
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H. I. Gi egg: i p
\\d,$1) 3/10/81 A Recent directives and undertakings are aimed at electrical equipment quali-s fication.
NRR is preparing an HRC Equipment Qualification Program Plan which will soon be issued.
This program plan includes both electrical and mechanical equipment qualification and will also include t:... rulemaking.
Current requirements for equipment qualification aren't clectly defined and are located under topic headings other than qualification.
The proposed regulation will clearly identify the equipment qualification requirement and provide for incorporation of detailed requirement as they are developed.
2.
VALUE/ IMPACT 2.1 NRC Equipment qualification should reduce the number of equipment problems and provide additional ensurance of safety in new and operating plants.
The regulation will provioe a consistent basis for staff review of con-struction and operating permits.
Cost savings will be obtained in terms of reduced manhours and the licensing process will be accelerated.
- 2. 2 Other Government Agencies Other government agencies, such as the Department of Energy, could be impacted if they have test facilities which could be used, are requested to develop facilities, or are requested to perform subcontracting work related to equipment qualification.
There will also be impact on a government agency such as TVA, since this agency is also an applicant or licensee.
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2.3.1 Applicants and Licensees Equipment qualification should reduce the number of equipment problems and unscheduled shutdowns.
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A clearly identified requirement for equipment qualification will elimi-t nate nisunderstanding and licensing delays.
There could be significant impact since facilities capable of testing the largest size equipment'are not available.
If test facilities have to be cun-structed the cost impact will be magnified.
Backfitting costs could be significant if tests of equipment of the same design as existing installed equipment fails qualification.
2.3.2 Manufacturers Equipment manufacturers would depend on the licensee's or private test facilities and cons'ultants to perform and evaluate qualification requirements.
The manufacturers could be severely impacted due to the unknown expense.
They may choose not to bid or they may furnish equipment at the licensee's risk.
2.4 Public Public safety would be improved due to equipment qualification.
There would be an increased level of confidence in the industry.
3.
TECHNICAL APPROACH 3.1 Alternatives There are many ways to qualify equipment.
Some alternatives are -
(1) qualification testing of actual equipment; (2) qualification testing by (1), in combination with analysis; (3) qualification testing by (1), in combination with similar usage i
experience; or (4) qualification testing of smaller size of similar design equipment, in combination with tests of actual size equipment or tests of sub-parts of actual size equipment.
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H.I. Gregg:rp 2/20/81 A Additional alternatives and suggestions will be requested of industry
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and the public in the ANR.
A discussion and decision on the technical approach will be made after all comments are reviewed and evaluated.
4.
PROCEDURAL APPROACH 4.1 Alternatives The need for a regulation for mechanical equipment qualification has been recognized, and consideration was given to the procedural alternatives of -
(1) issuing a proposed rule; (2) issuing an advance notice of rulemaking before issuing a proposed rule; or *
(3) holding a public meeting to obtain information before issuing a proposed rule.
4.2 Discussion This regulation has significant impact potential, many technical alterna-tives, and possibility for controversies.
There is a shortage of published mechanical equipment qualification national standards, Regulatory Guides, and test facilities for large size equipment. Many issues are undecided and the need exists to obtain industry and public input.
e 4.3 Decision An advance notice of rulemaking is considered a necessary prerequisi.te before developing the proposed rule, and is selected as the means to ' notify industry and the public of the proposed rule and obtain their early participa-tion in its development.
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STATUTORY CONSIDERATIONS 5.1 NRC Authority The requirements for equipment qualification are presently embodied in many different sections of 10 CFR Part 50, and in one case'in 10 CFR Part 100, under topic headings other than qualification.
This rulemaking will expand and l
clarify existing requirements and make them visible.
l 5.2 Need for NEPA Assessment The proposed action is not a major action, as defined by paragraph 10 CFR 51.5(a)(10), and does not require an environmental impact statement.
This will be reconsidered after the ANR comments are received.
6.
RELATIONSHIP TO OTHER EXISTING OR PROPOSED REGULATIONS OR POLICIES This proposed rule is closely related to the rulemakings currently going forward on (1) electrical equipment qualification and (2) accreditation of laboratories that perform qualification testing.
This proposed rule relates to the TMI-2 Lessons Learned and Action Plan requirements of, qualification and testing of BWR and PWR safety and relief l
l valves, and PWR block valves.
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CONCLUSION l
An advance notice of rulemaking will be prepared as the first step in f.he development of a regulation on qualification of mechanical equipment important l
to safety in nuclear power plants.
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