ML20027A724
| ML20027A724 | |
| Person / Time | |
|---|---|
| Issue date: | 01/21/1982 |
| From: | Danielle Sullivan NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | Arlotto G Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20027A669 | List:
|
| References | |
| FOIA-82-426, RTR-REGGD-01.089, RTR-REGGD-1.089 NUDOCS 8202090416 | |
| Download: ML20027A724 (3) | |
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D. F. Sullivan, Acting Chief Electrical Enginaering Brar.ch, cET, MS
SUBJECT:
BACKGROUtic Ir;F0FaTIOJ 0.! PfsGPOSEU REVISIO;! TO REGULATOP.Y i
GUILZ l.fS, "Ei.VII;d..;:EUTIL QUld.IFICATIOi! 0F ELECTRIC equip"EHT FOR f:bCLEAR PONER PL/c!TS" 4
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j This cemorandu:n is intended to provido you ;;ith certain background inforTaation regarding Pmposed Revision 1 to Regulatory Guide 1.S9. In 1
i viou of our coc:.:iteent to the Comission, the publication of the Pmposed Revision 1 to R.G.1.39 is being expedited.
Regulatory Guide 1.09.vas first issue) in i:ovaher 1974.
It endorses, with appropriate supplcientary caterial, IEEE Standard 323-1974. Experience in icipler.enting the guide and the standard has shoun that rore detailed guicance is essential. This additional cuidance was develoN! by the tiRC staff and was published in a "For Coment" issue of f:UREG-053d, "Interir.1 Staff Position on Environre.ntal Qualification of Safety-Related Electric Equip.mont." Proposed Revisica 1 to R.G.1.0 incor, crates the guidance provided in 'lOREG-0568, taking into account the com.ents received during the coment period.
The guide was foniarded on June 25, 1931, to the Technical Editing Section of the Pmgram and Administrative Services Branch for editing, printing, and publication for public coment. The background infcr: ration on how cajor cor.raents frora line offices were resolved, significcnt changes subseouent to staff review, why the particular impler.cntation schedule was chosen, and tile results of the ACRS review of the guide are provided below. A copy of the guide, including the Value/ Impact Statement, is enclosed.
Coment Resolution There were no significant cor:::ents fro:.1 the staff requiring resolution.
i Sicnificant Chanr'es Subsecuent to Staff P.cview 1.
Position C.1 was added which provides that additional equipr: eat, other than equipuent essential to r:itignting the consequences of an accident, should be qualified for accident conditions if its r.ulfunction or failure due to accident conditions will negate the safety function g
of safety mimnt.
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Position C.3 :tas radified to state that analysis cay be c.cceptable Ji if testing is impractical because of size.linitations, or by the
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state of the art, or if the equipment was purchased prior to i
May 23, 1000.
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Position C.O.d was rodified in apprerriate areas to include 1% of the reaininq fissica creduct eclics as cart of the tource tem.
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A paragraph was added in the discussion section to provide a basis 4
for not granting in Fusition C.4.d(12) a gencral exerption from
'I radiation qualification testing for equipment exposed to low-level j
radiation.
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Position C.S.a was added which provides that equipment located in a 1::
mild environment is not required to te qualified by test. The i
meaning of " mild environment" was also provided.
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Position C.9 was added which provides guidance for the qualification
- j of replacement parts.
7.
The implementation section was expanded to provide guidance as to how the guide should be applied depending upon the licensing commitment of each plant. The application of the guide to replacement cocponents 4
or spare parts is included.
8.
Old Appendix 8 (which provided a rodel for environmental qualifications for LOCA and !!SLS accidents) was deleted. The guidance for such analysis is provided by references to appropriate sections of iiUREG-0300, " Standard Review Plan."
9.
Old Appendix C (which provides a generic temperature profile for qualification) was deleted. The profile has not been sufficiently justified.
- 10. Old Appendix D (new Appendix B which provides sample calculations and methodology for detemining radiation dos ~e for qualification) was updated by the Accident Analysis Branch of fiRR.
- 11. New Appendix 0, " Thermal and Radiation Aging Degradation of Selected Materials," was added to provide guidance in the aging requirement of equipment qualification.
- 12. New Appendix E, " Typical Equipment / Function for Accident Mitigation,"
was added to provide guidance as to what equiptent is considered to be essential, hence requiring qualification.
t ACRS Review The proposed revision of the guide was forwarded for ACRS review and concurrence for issuance for consnent on June 17, 1981.
It was reviewed by the ACRS Electrical Systems Subcomittee on July 22, 1931. The Subcomittee deferred concurrence until the full ACRS reviewed the y
guide. I ACRS reviewed the guide and concurrenceifor issuance for public
.,,,,,,,g.' corants was given on August 7,1931'.
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l Guy A. Arlotto 3
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Comission Review l
A draft copy of the Regulatory Guide (craf t J4 hted 11/05/G1) *:2::
j subnitted to the Connissic:ters (c.c:o frca *cgar.:sl to Co.afssi,c r !Narr.a
.j da:cd 11/0;/L1) for ir.forcatiren f r. ccrm-tien uith SECY-Cl-FM.
During j
tha Cc'--ission's entiiv: on ll/10h:1, the propose:d rule, Section 53.40 J
to 10 CFR 50, and R.G. l. S (craft). tere di casie.!.
tenlei.entation
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1 The ir.plecentation section was written to confom to the requircoents of 3
IE Bulletin 79-018, dated January 14, 1900; Supplement 79-010, dated i
February 29, 1980; generic letter to SEP plants, dated February 15, 1980; j
the Cor.:,aission's eMrarandeu ar.d Order (CLI-CO-El), dated iiay 23, 1930; and the Commission's mennrandum dated January 8.1982.
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- b. N LG v. c. N D. F. Sullivan, Acting Chief l
Electrical Engineering Branch Division of Engineering Technology
.s Office of !!uclear Regulatory Research cc:
R. B. Minogue D. F. Ross L. C. Shao D. F. Sullivan S. K. Aggarwl g M
Distribution:
R-2513 Circ /Chron EEB Subj. E5028 EEB r/f s
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Dircks Cornell Ytr, CY:MINOGUE ARLOTT0/SHA0 FILE
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ROSS D. SULLIVAN GILLESPIE A
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uw omers or Denton DEBEVOISE & LIBERMAN Shapar 1300 SEVENTCCNTH STW ggt, N w.
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TELtpwowc WO4 Ss7-esco j
February,11, 1982 1
Honorable Nunzio J. Palladino Chairman U. S. Nuclear Regulatory j
Commission j
Washington, D.C.
20555
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Re:
Proposed Rulemaking Regarding the Environmental Qualification of Class IE E=uipment
Dear Mr. Chairman:
'l On June 22, 1981, we filed a Petition with the Commission on behalf of a utility industry group seeking an extension of i
the June 30, 1982, deadline regarding environmental qualifica-tion of Class IE equipment.
That deadline had been imposed on licensees with operating power reactors by Orders dated October 24, 1980.
The Commission has now directed the NRC Staff to prepara a proposed rule extending the deadline and prescribing..
generic requirements for environmental qualification of Class IE equipment.
See SECY-81-603 and 81-603A dated October 20, 1981 and November 4,1981, respectiively.
i In our letter to you of December 9, 1981, we requested.
(1) that the comment period for any proposed rule published on this issue be 90 days, and (2) treatment of the deadline extension matter separate from the remainder of the proposed rule and resolution of the deadline matter on an expedited i
schedule.
The rationale for the latter request was that the deadline extension relates to the Orders now on the dockets of individual licensees and thus requires early action.
On the other hand, the complexity and importance of the proposed rule dictates that it may and should be developed on a more deliberate schedule,- after careful consideration of the sub-stantial public comments it is certain to evoke.
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OF Or approp.' action -----------SECY-82-132 A 4*7
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.3 The Commission did not acknowledge or respond to our
.I request.
On January 20, 1982, the proposed rule was published
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covering both the deadline matter and the technical substance f
of the rule, with a 60-day comment period.
Fct the reasons
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set forth below, we respectfully renew both requests.
Extension of Comment Period The NRC Staff has stated that due to the interrelati'on between the proposed rule 'on environmental qualification of class IE equipment and draft Regulatory Guide 1.89, " Environ-mental Qualification of Electrical Equipment for Nuclear Powered Plants," the two would be published concurrently'for coraent.
SECY-81-603 (October 20, 1981).
Review of the draft Regulatory Guide is necessary to understand the pro-posed regulatory scheme and thus provide meaningful comment 4
on the proposed rule because the Guide will explain the
" methods acceptable to the NRC staff" for compliance with the proposed. rule.
Id.
However, while the proposed rule has been published, tee draft Guide has not..
Incidentally, we have attempted unsuccessfully on several occasions to obtain i
a copy of the draft Regulatory Guide in order to perform an evaluation of the proposed rule and draft Guide together.
In view of the delay in publishing the draft Regulatory Guide, and because the proposed rule raises comp, lex and important. issues (including new considerations such as qualification of one train to cold shutdown), we. again request that the comment period on the proposed rule be extended.
We believe that the period should coincide with the comment period for the proposed Regulatory Guide or, at a minimum,
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i should.be extended for 30 days.
Decoupling the Deadline Issue In accordance with the October 24, 1980 orders, the operating' license of each plant requires compliance with 8
interim requirements regarding environmental qualification of Class IE equipment by June 30, 1982.
It is clear that this deadline cannot be met and was unrealistic in the first place.
t It is also clear that substantial issues will be raised in the notice and comment phase of the rulemaking.
We assume j
that the Commission and the Staff will seriously consider and l
address these comments in their deliberations on the proposed rule, as they are required to do by the Administrative Procedure Act.
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- 1 So postured, it is virtually certain that the rulemaking j
proceeding will not be completed by June 30, 1982.
To d
continue to retain that deadline on individual plant licenses in the face of kriowledge that the deadline cannot be met and q:l will not be timely relieved by the rulemaking is unnecessary, inappropriate and contrary to sound regulatory practica.
Thus, we again request that the June 30, 1982 deadline be addressed now, separate from the. longer-t rm rulemaking.
Sincard I/
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Nichol.
S,. Reynolds
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' Commissioner Gilinsky cc:
a Commissioner Ahearne Commissioner Bradford Commissioner Roberts i
Secretary Chilk William J. Dircks /
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