ML20027B948
| ML20027B948 | |
| Person / Time | |
|---|---|
| Issue date: | 06/30/1982 |
| From: | Aggarwal S NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | Stello V NRC |
| Shared Package | |
| ML20027A669 | List:
|
| References | |
| FOIA-82-426 NUDOCS 8209300394 | |
| Download: ML20027B948 (30) | |
Text
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pa neou UNITL3 STATES
,,g jo, NUCLEAR REGULATORY COMMISSION y
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JUN 3 01982 MEMORANDUM FOR:
V. Stallo H. Denton R. DeYoung R. Minogue G. Cunningham P. Norry FROM:
Satish K. Aggarwal Office of Nuclear Regulatory Research
SUBJECT:
RESPONSE TO MR. CHILK'S MEMORANDUM PERTAINING TO SECTION 50.49 TO 10 CFR PART 50, " ENVIRONMENTAL QUALIFICATION OF ELECTRIC EQUIPMENT IMPORTANT TO SAFETY FOR NUCLEAR POWER PLANTS" Enclosed for your review is a draft of Commission Paper and the " final draft" of the subject rule. This version incorporates the Commission directives, as outlined in the draft Comission Paper.
Since I plan to obtain Office Directors' concurrence on July 12, 1982, I will appreciate receiving your coments by July 9,1982.
/.'
}hl Satish K.&ShUtQl$
Aggarwal Office of Nuclear Regulatory Research Enclosures :
1.
Draft Comission Paper.
2.
Federal Register Notice (Final Rule),
cc w/ encl:
S. Hanauer R. Mattson W. Besaw I
J. Felton J. Taylor D. Ross G. Arlotto W. Anderson I
D. Sullivan l
R. Vollmer l
W. Johnston l
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DRAFT For:
The Consnissioners From:
William J. Dircks Executive Director for Operations
Subject:
FINAL RULE, "ENVIRONENTAL QUALIFICATION OF ELECTRIC EQUIPMENT IMPORTANT TO SAFETY FOR NUCLEAR POWER PLANTS"
Purpose:
To revise the Final Rule based on the Conmission j
directives [ Staff Requirement Memorandum (SRM)] dated June 25, 1982 from Mr. Chilk to Mr. Dircks.
Discussion:
Based on SRM dated June 25, 1982, Enclosure 1, Notice of Final Rulemaking, SECY-82-207A dated June 9, 1982, has been modified as follows:
1.
The title of the final rule has been changed to read " Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants." The statement of considerations (pages 5 and 6 of Enclosure 1) has also been modified as directed.
2.
Paragraph 50.49(c) (pages 18-19 of Enclosure 1) pertaining to the scope has been appropriately modified.
3.
Two options in the area of replacement parts have l
been included (see paragraph 50.49(1) - page 26 l
of Enclosure 1).
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4.
A new paragraph has been added to page 5 of to indicate that there is no relazation i
of the requirements of CLI 80-21, except as noted.
Contact:
Satish K. Aggarval, RES 443-5946 i
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The Commissioners 2
5.
Category I requirements (IEEE 323-1974) will apply to nuclear power plants for which the construction permit safety evaluation report was issued after July 1,1974 (Comanche Peak and later plants). (See page 4 of Enclosure 1.)
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The codified portion of the final rule does not make any distinction between Category I and Category II requirements of NUREG-0588. Methods of implementation which are too prescriptive are contained in Standard Review Plan and R.G.1.89.
The Director, NRR, will insure that operating licenses will not be granted for Comanche Peak.and later plants unless they satisfy the requirements of IEEE 323-1974 (Category I of NUREG-0588).
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6.
The requirement to qualify equipment located inside the containment, which is needed to complete one path of achieving and maintaining a cold shutdown "I
condition following design basis events, has been added to the final rule (see page 18 of Enclosure 1),
as an option.
s.f Enclosed is a list of operating plants who have
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stated in their submittals, that one train of equipment i
i to accomplish cold shutdown has been qualified.
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l ali NRC staff has made no evaluation of their claims.
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(Enclosure 2.)
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8 The Comissioners 3
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7.
SECY-82-207A dated June 9,1982, incorporates all corments received at the June 1,1982 Comission
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meeting on this subject.
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Staff suggests that Enclosure 2. Analysis of Public i
Coments, will be revised alter the Comission has voted on this rule and made decisions on (1) replacement parts and (2) qualification of equipment needed for cold shutdown. The revised analysis of public comments can be revised and resubmitted to the Comission within one day subsequent to the majority decision.
Scheduling:
Affirmation of this rule as early as possible.
l William J. Dircks Executive Director for Operations
Enclosures:
1.
Federal Register Notice (Final Rule) 2.
List of operating plants - Cold Shut Requirement ( k NRR)
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NUCLEAR REGULATORY C0f41ISSION 10 CFR Part 50 Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants AGENCY: Nuclear Regulatory Commission.
ACTION:
[ Proposed] Final rule.
SUMMARY
- The [Neciear-Regefatory] Commission is [preposing-te] amendi_ng n
its regulations applicable to nuclear power plants to clarify and strengthen the criteria for environmental qualification of electric equipment imoortant to safety.
Specific qualification methods currently contained in national standards, regulatory guides, and certain NRC publications for equipment c
qualification have been given different interpretations and have not had the legal force of an agency regulation. This amendment [The propesed
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refe-wouid] codifyies the[se] environmental qualification methods and l
criteria that meet the [and-ciarify-the] Commission's requirements in 4
this area.
p' EFFECTIVE DATE:
[UPON publication in the Federal Register]
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[ BATES: Eemment period expires (60 days after pebiieation in the Federa4 Register 3 Somments received after ------------ wiii be considered if it is practical to de so-but asserance of consideration cannet be given except as to comments received on er before this date; i
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ABBRESSES: Written comments and suggestions may be mafied to the l
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Secretary of the Eemmission-Attention: Becketing and Service Branch-1 e-
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[7590-01]
e W:5: Neeiear Regulatory Semmission; Washington; B:E 60555; or hand-delivered to the Eemmission's Public Secument Reem at 1717 H Street NW ;- Washington;- B E:; between the hours of 8:30 arm-and 4:45 p m en normal work days:] '
FOR FURTHER INFORMATION CONTACT: Satish K. Aggarwal, Office of Nuclear Regulatory Research, [Eiectrient Engineering Branch;] U.S. Nuclear' Regula-tory Commission, Washington, D.C. 20555, Telephone (301)443-5946.
SUPPLEMENTARY INFORMATION:
1 Previous Notice On January 20, 1982, NRC oublished in the Federal Recister a notice of crocosed rulemaking on environmental qualification of electric eouio-ment for nuclear power olants (47 FR 2876). The comment period exoired March 22, 1982. A total of 69 comment letters raisino 10 major issues were received by April 6, 1982. An additional 10 comment letters were received by April 21, 1982. but no new issues were raised. The major issues are discussed below.
Nature and Scope of the Rulemakino Nuclear power plant equipment important to safety must be able to perform [the] its safety functions throughout its installed life. This requirement is embodied in General Design Criteria 1, 2, 4, and 23 of Appendix A, " General Design Criteria for Nuclear Power Plants," to 10 CFR
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l Part 50, " Domestic Licensing of Production and Utilization Facilities"; in i
Criterion III, " Design Control," ;nd Criterion XI, " Test Control," of l
Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel I
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1' Reprocessing Plants," to 10 CFR Part 50; and in paracraph 50.55a(h) of 10 CFR Part 50, which incorporates by reference IEEE 279-1971,1,2
" Criteria for Protection Systems for Nuclear Power Generating Stations."
This requirement is applicable to equipment located inside as well as outside the containment.
-t The NRC has used a variety of methods to ensure that these general requirements are met for [ safety grade] electric equipment important to j
safety.
Prior to 1971, qualification was based on the fact that the electric components were of high industrial quality. For nuclear plants
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licensed to operate after 1971, qualification was judged on the basis of IEEE 323-1971. For plants whose Safety Evaluation Reports were issued since July 1,1974, the Commission has used Regulatory Guide 1.89, j
" Qualification of Class 1E Equipment for Light-Water-Cooled Nuclear I
l Power Plants," which endorses IEEE-323-1974,2 "IEEE Standard for Qualifying Class IE Equipment for Nuclear Power Generating Stations,"
subject to supplementary provisions.
Currently, the Commission has under way a program to reevaluate the qualification of electric equipment in all operating nuclear power plants.
As a part of this program, more definitive criteria for environmental
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qualification of electric equipment important to safety have been developed by the NRC. A document entitled " Guidelines for Evaluating Environmental l
Qualification of Class 1E Electrical Equipment in Operating Reactors" (00R Guidelines) was issued in November 1979.
In addition, the NRC has r
' Incorporation by reference approved by the Director of the Office of Federal Register on January 1,1981.
2 Copies may be obtained from the Institute of Electrical and Electronics Engineers, Inc., 345 East 47th Street, New York, N.Y. 10017.
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4 issued NUREG-0588, " Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment," which contains two sets of criteria: the first for plants originally reviewed in accordance with IEEE 323-1971 and the second for plants reviewed in accordance with IEEE 323-1974.
By its Memorandum and Order CLI-80-21 dated May 23, 1980, the Commission directed the staff to proceed with a rulemaking on environ-mental qualification of safety-related equipment and to Iddress the ques-tion of backfit. The Commission also directed that the 00R Guidelines and NUREG-0588 form the basis for the requirements licensees and appli-cants must meet until the rulemaking has been completed. This [ proposed]
rule is [generafiyt-hssedqq he-requirementes ef.the-DMTioroHperet4my
-Reesters]- DORhuidelines and NUREG-0588.
The Commission recognizes the cualification efforts of the industry as a result of CLI-80-21. Therefore, s
the rule provides relief to operating nuclear oower olants (see caracraoh'
( k)of the final rule.).
Requalification of electric eouipment in accordance l
with this rule will not be required for equioment qualified or beino l
l aualified in accordance with 00R Guidelines or NUREG-0588 orovided the qualification of electric equipment has commenced orior to [ insert effec-tive date of this amendment]. Those nuclear power plants that are currently under review and are qualifying se#a*y-c':trd electric equipment in accordance with NUREG-0588 (Category I or II) will satisfy the,reouire-ments of this rule. Category I requirements (IEEE 323-1974) acoly to i
nuclear power plants for which the construction permit safety evaluation reoort was issued after July 1,1974, and Cateaory II requirements l
(IEEE 323-1971) acoly to nuclear oower plants for which the construction permit safety evaluation recort was issued orior to July 1,1974.
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The dates soecified in this rule for comoletion of environmental y
1*M7hrnt /C W I
oualification of ea#=+"--c':t:f> electric eouioment apply to all licensees and aoolicants and supersede any date previously imposed. No changes to licenses or technical soecifications are necessary to reflect these new completion dates.
The final rule orovides no relaxation of recuirements contained in Commission Memorandum and Order CLI-80-21, except as follows:
(1) Oualification of electric ecuipment located in mild environment.
(2) Uograding the cualification of replacement parts.*
[The 6emmission's Memorandum and Order Eti-80-El directed that the envirenmentai qualification of efectrie equipment in operating nuefear power piants be compfeted b'y dene-30; 198E: However; en September-ES; 1981; the Sommission eensidered the petition (5ESY-81-4863 to extend this deadline The proposed rule covers the same efectric equipment as EEI-80-Ei and impiements SESY-81-486 by incorporating the extensien dates recommended by the 6hairman in his memorandum-dated September-307-1981.
Included in the preposed ruie is a requirement that each heider of er each applicant for a 44 cense to operate a nuciear power piant identify and quaiify the eiectric equipment needed to complete one path of achieving and maintaining a cold shutdown condition: The Sommission specifically requests comment on this preposed additional requirement;]
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The scope of the [preposed] final rule [does-not-include-aii-efectric i
equipment-important-to-safety-in-its-verious gradations of-importance:--it]
[incindes] covers that portion of equipment important to safety commonly a
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" Delete or retain depending upon the option on replacement parts approved l
by the Commission.
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referred to as " safety-related" (which Commission interorets as essentially
" Class 1E" equipment defined in IEEE 32}-1974) [er 864 ass-iEu-equipment in-fEEE-nationai-standerd--s] and some additional non-Class 1E equipment I
and systems whose failure under extreme environmental conditions could f
prevent the satisfactory accomplishment of safety functions by accident-mitigating equipment. Safety-related structures, rystems and components are those that are relied upon to remain functional durina and following desion basis events to assure (1) the intecrity of the reactor coolant pressure boundary, (2) the capability to shutdown the reactor and maintain it in a safe shutdown condition, and (3) the capability to prevent or miti-cate the consequences of accidents which could result in notential offsite exposures comoarable to the cuidelines of 10 CFR Part 100. Desion basis events are defined as conditions of normal ooeration, includina antici-pated coerational occurrences, design bas'is accidents, external events,
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and natural phenomena for which the plant must be desianed to assure functions (1) through (3) above. Also covered in the scooe of the final rule is ce_rtain postaccident monitoring equipment specified as " Category 1 and 2" in Regulatory Guide 1.97," " Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions Durina and Following an Accident" (Revision 2).
Included in the [ proposed] final rule are specific technical require -
i ments pertaining,to (a) qualification parameters, (b) qualification methods, and (c) documentation. Qualification parameters include temperature, pres-sure, humidity, radiation, chemicals, and submergence. Qualification methods include (a) testing as the principal means of qualification and (b) analysis and operating experience in lieu of testing. The [ proposed] final rule would requires that the qualification program include synergistic effects, aging, 6
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[7590-01]
margins, radiation, and environmental conditions. Also, a record of qualifi-cation must be maintained. Proposed Revision 1 to Regulatory Guide 1.89,
[is being revised te] which has been issued for public comment, will describe methods acceptable to the NRC for meeting the provisions of this [ proposed]
rule and [te] will include a list of typical equipment covered by it [a-draft of-the proposed]. Revision 1 [is-being published-for public comment-concur-rently with-the proposed-ruie-] to Regulatory Guide 1.89 will be issued after resolution of oublic comments.
[Aise-incinded-in-the proposed-ruie-is-a-requir+ menti-which-is-consis-tent-with-Eemmissien-Memorandum-and-Order 7-Ehi-80-Ei;-for-submission of an analysis-by-ficensees-to-ensure-that-the piant-can-be-safety-operated pending-cempietion-of-the environmentai qualification-of eiectrie-equip-ment:--The-Eemmission-expects-that;-for each-of-the-current 4y-operating power piantsi-this-analysis-and-its evaication-by-the-NRS-staff-wf44-be-compieted weii-in-advance-of-the-effective-date of-this-ruie --if-the licensees of-operating power piants-faii-to provide-these-analyses-in-a timeiy-manner;-the-Eemmission expects-the-NRE-staff-to-take-the appre-priate-steps-te require-that-the-information-be provided-and-to enforce compiiance-with-this requirement:--This-requirement-has-been-included-in this prope' sed-ruie-to provide-a-reguiatory-basis-for-enforcement:]
NRC will generally not accept analysis alone in lieu of testing.
Experience has shown that q'ualification of equipment without test data may not be adequate to demonstrate functional operability during design basis event conditions. Paragraoh 50.49(f) orovides four. methods for qualifica-tion. Testing will be preferred. Justification for qualification of any of the remaining three methods must meet NRC aooroval. To ensure intecrity
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of a testing orogram, the same Diece of equioment must be used throughout the complete test secuence.
[ A n alys i s -may-be-acc ept abl e-i f-t es ti ng-of-t he equipment-is-impracticaf-because-of-size 7-or-timitation-due-to-the-state of-the-art---The proposed-ruie-takes-inte-consideration-the prior quaii-fication-history-of-the-operating power-piants:--For-exampie7-the proposed ruie-recognices-that-for-those pierts-which-are-not-committed-to-either IEEE-SES-1971-or-fEEE-SES-1974-for equipment qualification;-end-have-been tested-oniy-for-high-temperature pressurei-and-steamT-some equipment-may not-need-to-be-tested-again-to-ineinde-ether-service-conditions-such-as radiation-and-chemical-sprays --The qualification-of-equipment-fo--these service-conditions-may-be-established-by-analysis ]
The [ proposed] final rule [wonid] requires that each holder of an operating license provide a list of electric equipment important to safety previously qualified based on testing, analysis, or a combination thereof and a list of equipment that has not been qualified. These lists and t.he schedule for completion of equipment qualification [wonid-have-te] must be submittec [ written] h [ Insert a date 90 days after the effective date of this aniendment]. [ruier EHoweverv-this-time period-wiii-be-adjested-dering-the-finai-ruie-making process-to-a44ew-reasonsbie-time-for-ficensees-to evaluate-NR6's-safety-reviews-that-are-currently-underway.]
[The proposed-rule-wiii-codify-the-6ammission's-current-requirements for-the-environmentai qualificatien-of eiectrie-equipment --epen publica-tion-of-a-finai-rufeT-the-98R guidelines-and-NOREG-0588 wi44-be withdrawn-]
The general requirements for seismic and dynamic qualification for electric equipment are contained in the General Design Criteria.
Further guidance is orovided in Regulatory Guide 1.100, " Seismic Qualification of Electric Equipment for Nuclear Power Plants'" (Revision 1) and NUREG-0800, 8
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" Standard Review Plan."
[Pending-deveiopments-of-speciffe-requirements in-this area;-the generai-requirements wi H -continue-to-appfy-] NRC is considering to include [ expansion-of-the-scope-of-this-ruie-to-ineinde additionai] dl, electric equipment important to safety and the recuire-ments for seismic and dynamic cualification of electric eouipment [This matter-wiH-be-the-subject-of] in future rulemaking.
[Additionai-views of-Eemmissioner-Bradford---Eemmissioner-Bradford believes-that-the proposed-deadHne-fsecond-refueHng-outage-after March-Si;-19823-for quaHfication-is-much-too-reiaxed; given-the-fact that-ficensees and-the-NRE-have-been-aware-of-the problems-in-this-area since-1978---The proposed-desdHne-extends-as-much-as-two-and-one-half ye ars - b eyo nd-the-d u n e-30;-1983 - date-by-whi eh-the-Atomi c-i ndu s tri ai-Ferum concinded-that-neariy-aH-electricai equipment-could-be quaHfied.
Given-the-more generous-deadiine;-he-afso-believes-that-the ruie-shocid have-contained-requirements-fer-seismic-and-dynamic quaHfication---Whife the generai-design-eriteria contain-requirements-in-this area;-elarifica-
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tion-new wouid-ensure-that equipment-to-be-replaced-in-the-near-term-wiH not-have-to-be-ripped-out-in-a-few years-because-it-was-not properiy seis'iricaHy quaHfiedt Eemmissioner-6Hinsky-has agreed with-these-views-]
Comments'On The Proposed Rule l,,-
The Commission received and considered the comments on the orooosed rule contained in the 69 letters received from the public by Aoril 6,1982.
Cooies of those letters and a staff response to each comment are available for public inspection and cooying for a fee at the Commission's Public Document Room at 1717 H Street NW., Washington, D.C.
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The major issues raised by the comments and NRC staff resoonses are as follows:
(1) Seismic and Dynamic Qualification - Paragraph 50.49(a)
Issue: Seismic and dynamic Qualifications are an integral part of environmental qualification.
It is therefore inappropriate to codify these recuirements separately.
Response
Electric equipment at operatino nuclear oower plants was generally cualified for environmental and seismic stresses separately, i.e., by usina separate prototypes for environmental and seismic qualifi-cation tesi;s. The Commission has decided, after considerable deliberation, 7Ae iss.<e of.ceas,wk cad cy>,e>mc fu C$ca.km to pursue U h at a future date throuch the issuance of an advance notice of orooosed rulemaking. A future seismic rule may not require retesting for environmental stresses because a single prototype was not used during the original cualification.Y(2)
Scoce - Cold Shutdown e
Requirement - Paragraph 50.49(c)
Issue: The rule introduces a ne.s requirement to qualify "eouio:aent needed to complete one path of achieving and maintaining a cold shutdown condition." A change of this magnitude, at this advanced stage of the industry's qualification effort, most certainly introduces significant t
new costs and obligations with no demonstrated imorovement in safety.
Response: The Commission acrees that this requirement may introduce significant costs. The licensing basis of the majority of operating reactors does not recuire that all electric equipment and systems neces-sary to bring the reactor from normal operatino conditions to cold shut-down be designed to Class lE standards. Therefore, to recuire that all plants environmentally qualify the electric eouioment and systems needed i -
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to complete one path of achieving and maintaining a cold shutdown condi-tion may require the uocradino of a significant amount of eouipment and
' systems that do not currently meet Class lE standards for coerating reactors. However, electric ecuipment and systems necessary to shut down the reactor and maintain it in a safe shutdown condition are reouired to meet Class 1E standards and therefore would be covered by the rule.
The Commission is currently studying the recuirements for shutdown decay heat removal under Unresolved Safety Issue (USI) A-45.
The overall purpose of A-45 is to ovaluate the adecuacy of current licensing require-ments to ensure tnat failure to remove shutdown decay heat does not pose an unacceptable risk.
Under A-45 a comprehensive and consistent set of shutdown cooling reouirements for existing and future plants are being develooed. The final resolution of A-45 is cresently scheduled for October 1984.
The Commission believes it would [nnt]* be premature at this* time to impose the requirement to environmentally cualify electric ecuipment and systems necessary to achieve and maintain cold shutdown orior to the final resolution of A-45.
Therefore, this reouirement is [not]*
i included in the final rule.
(3) Scope - Ecuipment in a Mild Environment - Paragraoh 50.49(c)
Issue: The rule makes no distinction between eouipment lccated in a harsh or mild environment. The stresses for eauipment in a mild environment are less severe than for those in a harsh environment.
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Response: The final rule does not cover the electric eouionent located in a mild environment. The Commission has concluded that the general cuality and surveillance requirements applicable to electric equipment as a result of other Commission regulations, includina 10 CFR Part 50, Appendix B (see for example, Regulatory Guide 1.33, " Quality Assurance Program Requirements (Operation)," Revision 3) are sufficient to ensure adeouate performance of electric equipment important to safety located in mild environments. Since it has been concluded that no further environmental cualification requirements are needed for such equipment pro-vided they fully satisfy all other applicable reculations, the Commission has determined that no additional reouirements are necessary with respect to electric equipment imoortant to safety located in mild environments in order for licensees to satisfy, with respect to such eauipment, existing license conditions or technical specifications calling for cualification of safety-related electric equipment in a'ccordance with 00R Guidelines or NUREG-0588.
(4) Scope - Previous Qualification Efforts - Paragraph 50.49(c)
Issue: The rule does not recognize that operating olants have just completed qualification of equipment to the DOR Guidelines or NUREG-0588.
Without such recognition, industry efforts, manpower, and billions of dollars will ao down the drain.
Response: The final rule has been expanded to alleviate this concern.
See Paragraph 50.49(k).
j (5) Humidity - Paraaraph 50.49(e)(2)
Issue: The effects of time-dependent variations of relative humidity during normal operation cannot be considered for all eouioment. There are no detailed standards for how this type of testing should be performed.
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Response: The Commission acrees. Humidity variations durino normal operation are difficult to predict.
It has not,been demonstrated that the time-dependent variation in humidity will oroduce any differences in degradation of electric equipment. The words " Time-dependent variation of relative" have been deleted from Paracraph 50.49(e)(2).
(6) Acing - Paracraph 50.49(e)(5)
Issue: The requirement that ongoing Qualifications be done using e
" prototype equipment naturally aced" is overly restrictive. Use of accelerated acina to define a qualified life is not technically feasible.
Response: Preconditioning by accelerated acing is technically feasible for simple electric eouipment for plant life and for comolex electric equioment for shorter designated life. Commission recognizes that state-of-art technology will be utilized in any aging orocram.
Reference to qualified life has been deleted from caragraph 50.49(e)(5).
(7) Marcins - Paraaraoh 50.49(e)(8)
Issue: The marcins applied in addition to known conservatisms lead to excessive stress that could lead to failures of equipment in unrealis-tic Qualification tests.
Response: The Commission agrees. This requirement could have caused excessive margins. The paracraph has been modified to recognize conserva-l tism that can be quantified.
t (8) Analysis and partial test data - Paragraph 50.49(f)(4)
Issue:
If partial type test data that adequately support the analytical assumptions and conclusions are available, their analysis I
should be allowed to extrapolate or interpolate these results for equionent, recardless of purchase date.
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Response: The Commission agrees. Reference to " purchase date" has been deleted.
(9) Requirement for a central file - Paracraph 50.49(j)
Issue: The requirement for a central file should be deleted since it is not cost effective and has no safety benefit.
Response: The Commission agrees. This requirement has been subject to different interpretations. A record of qualification must be main-tained in an "auditable form" but not necessarily in a central file, for the entire period during which the covered item is installed in a nuclear power plant. Recordkeepino requirement of 10 CFR Part 50 Apoendix B must be met. Certain records can be kept at the vendors shop.
(10) Justification of contin'ued operation for operatino olants.
Issue: The requirement to submit justification for the continued i
operation of operatinc olants should be deleted since this.information has been previously submitted to NRC.
Response: This reouirement has been satisfactorily met and i
Paragraph 50.49(j) of the proposed rule bas been deleted in its entirety j
from the final rule.
In addition, Paragraph 50.49(a) of the proposed rule has been deleted from the final rule since it is too prescriptive.
It will be included in Regulatory Guide 1.89.
Effective Date:
This rule is effective upon publication in the Federal Register.
l Th Co.....b;i a hn determined that-th '~nal-rui: :hoth-teke-
- n.. J ; a Le effect-upon-publication. becausa..it r.alieves. a restrictionsundersetr-r section.(d)(1-)..of.Section-,553. of the Administrative Procedure-Act.-Thtr-i 14 3
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b :: :: 211 nnaratinq_rametne 14ranesee :
r"-*= a t ': und;. a a
.o June-50, 196c, uvadi;ne Lu uumulei.
- n"#--- ca+2' :: l ' 'i c:t i - -' e =f ats-related--electric.eouioment - ^c ## r '. im n..wl;..nt: tic : hed"1^
=e o
explaine h e,.succ.1=a+e- *h4A date_a e s gives licens :;
oum.
.....I tir: to-cc-saiet; envirc...T. ntc4-ouati'ic:tica e#
eef^+y--^'=+^d al art ric
.eonica:..:." I cdf#ti:n,'the Commission finds that there is good cause--
pursuant t' subsection (d)(3) of Section 553--to make the rule's reouire-ments eff. ;ive upon publication. The first licensee actions ur. der the rule are n7,, required until 90 days after the effective date of the rule.
This 90-day 03riod is intended to include the statutory 30 days and allow 60 additional days to make the submittal reouired by Paragraoh 50.49(g) of the rule. The overall effect of making the rule effective on oublication is to relieve licenseesr-of--the-June 30, 1982,- dead 11 ne anr to-provi-de.-a-sufficient Derted after-the effecttve-date. of the rule-forticensees--
to achieve comolfance witit-the-near-term rioufrements of~~tNe W
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Paperwork Reduction Act The [preposed] final rule contains recordkeeping requirements that are subject to review by the Office of Management and Budget (OMB). As ecd.
required by P.L.96-511, thise peepened rule [wi++-be] was submitted to eg
^
OMB for clearance of the recordkeeping requirements 've'3 ##0" "I_'
A Regulatory Flexibility Statement In accordance with the Regulatory Flexibility Act of 1980, 5 U.S.C.
605(b), the Commission hereby certifies that this rule [--if promeigated-]
will not have a significant economic impact on a substantial number of small entities. This [ proposed] final rule affects the method of qualifica-tion of electric equipment by utilities. Utilities do not fall within the 15
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[7590-01]
definition of a small business found in Section 3 of the Small Business Act, 15 U.S.C. 632.
In addition, utilities are required by the Commission's Memorandum and Order CLI-80-21, dated May 23, 1980, to meet the requirements contained in the 00R " Guidelines for Evaluating Environmental Qualification of Class 1E Electrical Equipment in Operating Reactors," (November 1979) and NUREG-0588, " Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment," which form the basis of this
[ proposed] rule. Consequently, this rule codifies existing requirements (and imposes no new costs or obligations on utilities).*
List of Subjects in 10 CFR Part 50 Antitrust, Classified information, Fire orevention, Intergovern-mental relations, Nuclear power plants and reactors, Penalty, Radiation protection, Reactor siting criteria, Reporting requirements.
Pursuant to the Atomic Energy Act of 1954, as amended, the Energy Reorganization Act of 1974, as amended, and section 553 of title 5 of the United States Code, [netice-is-hereby given-that-adeption-of-the] the following amendment to Title 10, Chaoter I, Code of Federal Regula-tions, Part 50, [10-EFR-Part-50-is-centempiated] is published as a docu-ment subject to codification.
l 10 CFR Part 50 1.
The authority citation for Part 50 continues to read as follows:
AUTHORITY: Secs. 103, 104, 161, 182, 183, 189, 68 Stat. 936, 937, 948, 953, 954, 955, 956, as amended (42 U.S.C. 2133, 2134, 2201, 2232,
" Delete if qualification requirement for cold shutdown equipment is included in the final rule.
~
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[7590-01]
H 2233, 2239); secs. 201, 202, 206, 88 Stat. 1243, 1244, 1246 (42 U.S.C.
'j 5841,5842,5846), unless otherwise noted.
{
Section 50.78 also issued under sec. 122, 68 Stat. 939 (42 U.S.C.
2152). Sections 50.80-50.81 also issued under sec. 184, 68 Stat. 954, 1j as amended (42 U.S.C 2234). Sections 50.100-50.102 issued under
.a sec. 186, 68 Stat. 955 (42 U.S.C. 2236).
.4 For the purposes of sec. 223, 68 Stat 958, as amended (42 U.S.C.
l 2273), SS50.10(a), (b), and (c), 50.44, 50.46, 50.48, 50.54, and 50.80(a) j are issued under sec. 161b, 68 Stat. 948, as amended (42 U.S.C. 2201(b));
SS50.10(b) and (c) and 50.54 are issued under sec. 161i, 68 Stat. 949, as amended (42 U.S.C. 2201(i)); and SS50.55(e), 50.59(b), 50.70, 50.71, 50.72, and 50.78 are issued under sec. 1610, 68 Stat. 950, as amended (42 U.S.C 2201(o)).
2.
A new 5 50.49 is added to read as follows:
S 50.49 Environmental qualification of electric equipment imoortant to safety for nuclear power plants.
(a) Requirements for seismic and dynamic qualification of electric equipment important to safety are not included in this section. Also not inclLded are the requirements for electric equipment important to safety j
located in a mild environment. A mild environment is'an environment i }
that would at no time be significantly more severe than the environment that would occur during normal olant operation including during anticipated operational occurrences.
l,{
(b) Each holder of or each applicant for a license to operate a nuclear power plant shall establish a program for qualifying the electric l
-A equipment as defined in paragraph (c) of this section.
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(c) Electric equipment and systems important to safety covered by this section are safety related electric eouipment and systems as defined in paracrapn (c)(1) and some additional electric equipment whose failure i
?
under extreme environmental conditions could orevent the satisfactory accomplishment of safety functions by accident mitiqatino equioment.
i
[inciade electric-equipment-and-systems-that-are-essentia4-to-emergency I
{
reac tor-s hutdewn-- co nt ai nment-i s oi nti on--reactor-core-cocii ng-- and j
containment-and-reactor-heat-removai or-that are-otherwise-assential l
in preventing significant-release-of-radioactive-material-te-the-environ-ment---incieded-is-equipment-fi)-that performs-the-above-functions-auto matically--ff3-that-is-used-by-the-operator-to perform-these-functions manually--and-fS)-whose-failure-can prevent-the-satisfactory-accomplish-ment-of-ene-or-more-of.-the-above-s afety-functions- [Also included is equipment located in containment which is needed to complete one path s ka. ~
y,
- n. f:~o s c. s ~5
- s of achieving and maintaining a cold shutdown condition.]* (1) Safety-a related electric eculoment and systems are those eauioment and systems relied upon to remain functional during and following design basis events to assure (1) the integrity of the reactor coolant pressure boundary, (2) the capability to shut down the reactor and maintain it in a safe shutdown condition, and (3) the capability to prevent or miticate the consequences of accidents which could result in potential offsite expo-sures comoarable to the in CFR Part 100 quidelines. Design basis events are defined as conditions of normal operation includina anticipated coera-tional occurrences, design basis accidents, external eve-ts, and natural phenomena for which the plant must be designed to assure functions (1) through (3) above. Soecifically, electric equipment and systems that are essential to emergency reactor shutdown, containment isolation, reactor i
" Delete, if appropriate, after the Commission has made a decision.
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core cooling, and containment and reactor heat removal or that are other-wise essential in preventing significant release of radioactive material to the environment.
(d) The applicant or licensee shall prepare a list of aii imierk J Ar M s
rei;;edelectricequipmengcoveredbythissection. [snd-maintain-it-in en auditabie-forms---This-4ist-of-equipment-must--as-a-minimum--inciade-]
In addition, the acolicant or licensee shall include the following information for electric eouipment important to safety in a cualification file:
(1) The performance specifications [and structurai-integrity-require-ments] under conditions existing [during-nermai-and-abnormai-eperation-and]
during and following design basis events.
[an d-af te rwards-and-the-i engths-of the periods-dering-which-the-integrity-mast-be-maintained-]
(2) [The-range-ef] The voltage, frequency, load, and other electrical characteristics for which the performance specified in accordance with paragraph (d)(1) of this section can be ensured.
(3) The environmental conditions, including temperature, pressure, humidity, radiation, chemicals, and submergence [and-the predicted-varia-tiens-of-these environmentai-conditions-with-time] at the location where the equipment must perform as specified in accordance with paragraphs (d)(1) and (2) of this section.
i*
(e) The electrical equipment qualification program must include l
the following:
(1) Temoerature and Pressure. The time-dependent temperature and pressure at the location of the electric equipment important to safety must be established for the most [ limiting] severe [of-the-applicable postulated-accidents] design basis events durino or following which this 19
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[7590-01]
equipment is reouired to remain functional. This time-dependent tempera-ture and oressure must be used as the basis for the environmental qualifi-cation of electric equipment imoortant to safety.
(2) Humidity.
[ Time-dependent-variations-of-relative] Humidity during normal operation and design basis events must be considered.
(3) Chemical Effects. The composition of chemicals used must be at least as severe as that resulting from the most limiting mode of plant operation (e.g., containment spray, emergency core cooling, or recircula-tion from containment sump).
If the composition of the chemical spray can be affected by equipment malfunctions, the most severe chemical spray environment that results from a single failure in the spray system must be assumed.
(4) Radiation. The radiation environment must be based on the type of radiation the total dcse [and-dese-rate-of-the-radiation environment]
2 expected during normal operation over the installed life of the equipment,
[ pius] and the radiation environment associated with the most' severe design bdsis event during or following which the equipment is required to remain functional, including the radiation resulting from recirculating fluids for equipment located near tne recirculating lines and including dose-rate effects.
(5) Aging. Equipment qualified by test must [practicabie] be e
preconditioned by natural or artificial (accelerated) aging to its installed end-of-life condition.
[Eiectromechanicai equipment-mest-be o p e rate d-to-the-mechani c ai-wea r-a nd-ei eet ri c ai-d egrad ati e n-e x p e ct e d-d e ri n g its-installed-fifer] If Where preconditioning to an installed end-of-life condition [a qualified-fife-equai-te-the-instailed-fife] is not [possibie]
practicable and technically meaningful, the equipment may be preconditioned
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[7590-01]
to a shorter [qua+ified] designated life. The equipment must be replaced or refurbished at the end of [its qualified] this designated life unless ongoing qualification [of] demonstrates [ prototype-equipment-naturaffy-aged in piant-service-show--by-artificiai tging-and-type-testing] that the item nas additional [ qualified] life.
(6) Submergence (if subject to being submerged).
(7) Synergistic Effects.
[The preconditioning-and-testing-of-equip-ment-must-consider-known] Synergistic effects must be considered when these effects are [known] believed to have a significant effect on equipment performance.
(8) Margins. Margins must be applied to account for production variations and inaccuracies in test instruments. These margins are in addition to [ margins-applied-during-the-derivatien-of-the environmentai conditions-] any conservatisms apolied during the derivation of environ-mental conditions unless these conservatisms can be quantified and shown to centain aporooriate margins.
(f) Each item of electric equipment important to safety must be qualified by one of the following methods:
(1) Testing an fdentical item of equipment under identical conditions j
or under similar conditions with a succorting analysis to show that the equipment to be qualified is acceotable.
l (2) Testing a similar item of equipment with a supporting analysis to show that the equipment to be qualified is acceptable.
i (3) Experience with identical or similar equipment under similar conditions with a supporting analysis to show that the equipment to De qualified is acceptable.
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[f43-Anaiysis-in-iieu-of-testing-in-the-following-cases-:
fi3--if-type-testing-is prefuded-by-the physical-size-of-the-equip.
ment-or-by-the-1 tate-of-the-artr]
,(_4),
[ffi3 By] A,nalysis in combination with partial type test data
[which] that supports the analytical assumptions and conclusions. [;-if the-equipment purchase order was exeented prier-to-May-237-1980.
(g3--if an-item-of-efectrie-equipment-is-to-be quaiffied-by-test--
(13--The-acceptance-criteria-must-be-estabfished prier-to-testing-f23--The-tests-must-be-designed-and-conducted-to-demonstrate-that the-equipment-can perform-its-required-function-as-specified-in-accord-ance with paragraph-fd3f13-of-this-section-for-sii-conditions-es-speci-fied-in-accordance-with paragraphs-fd3(E3-and-(33-of-this-section---The test proffie-ferg ; pressureT-temperature 7-radiation-vs:-time 3-must incinde-margins-as-set-forth-in paragraph-fe3fB3-of-this-section-(33--The-test proffie-must-be either-fi)-a-single profiie-that enveiops-the environmentai-conditions-resciting-frem-any-design-basis event-during-any-mode-of piant-operation-fe g T-a profile-that envelops the-conditions produced-by-the postuinted-spectrum-of-main-steamiine break-fMStB3-and-foss-of-cooient-accidents-ft0EA33-er-fii3-separate pre-fifes-for-each-type-of-event-fe g : separate profiles-for-the-MSES-acci-dents-and-for-t06As);
(43--The-same piece-of equipment-mest-be-used-throughout-the-compiete I
test-sequence-under any given profile-]
[fh3] M Each holder of an operating license issued prior to (insert l
the effective date of this amendment) [must,] shall, by (insert a date i
l 90 days after the effective date of this amendment), identify the. electric equipment imoortant to safety already qualified to [the provisions of-this e
i' 22
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[7590-01]
ruie] and submit a schedule for the cualification to the orovisions of this rule [ testing] or replacement of the remaining electric equipment iroortant to safety. This schedule must establish a goal of final environ-mental qualification by the end of the second refueling outage after March 31, 1982. The Director of Nuclear Reactor Regulation may grant requests for extensions of this deadline to a date no later than November 30, 1985, for specific pieces of equipment if [such] these requests are filed on a timely basis and demonstrate good cause for the I
extension, such as procurement lead time, test complications, and instal-
.i lation problems. In exceptional cases, the Commission itself may consider and grant extensions beyond November 30, 1985, for completion of environ-mental qualificatiun.
[(i3] (h) Each licensee shall notify the Commission of any signifi-cant equipment qualification problem that may require extension of tha completion date within [30] 60 days of its discovery.
[(j)--For-the-eentinued-operatien-of-a-nuciear pianti each-heider-of an-operating-iicense-issued prier-to-the-effective-date-of-this-ruie-shafi perform-an-analysie-to-ensure-that-the piant-ean-be-safeiy-operated pending compietion-of-the-environmentai qualification---The-detailed-analysis-for each equipment-type-with-sppropriate-justification-mast-be-submitted-te l,
Birector-of-Nuetear-Reseter-Reguistory-by-finsert-the-effective-date-ef the-ruie)-and-must-ineinde--where-appropriate-consideration-of:
(13--Accompiishing-the safety-function-by-some-designated-afternative l
equipment-that-has-been-adequately qualified-and-satisfies-the-singie i
l faiiure-criterien-if-the principai-equipment-has-net-been-demonstrated-te N
be-faily qualified-a.
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[7590-01]
(23--The-vaiidity-of partiai-test-data-in-suppert-of-the-original qualification-(33--timited-use-of-administrative-controis-over-equipment-that-has not-been-demonstrated-to-be-fai+y quaiffied-(43--6ompletion-of-the safety-function prior-to exposure-to-the-ensa-ing-accident environment-and-the-subsequent-failure of-the-equipment-does not-degrade-any-safety-function-or-misfeed-the-opeptor-(53--No significant-degradation-of-any-safety dunction-or-misiesding of-the-operator as-a-rescit-of-failure-of equipment under-the-accident environment-]
[(k)] Q1 ' The applicant for an operating license that is granted on or after [ insert the effective date of this amendment] but prior to November 30, 1985, [must] shall perform an analysis to ensure that the plant can be safely operated pending completion of environmental qualifi-cation.
[in-accordance with paragraph-fj)-ef-this-section-except-that this-analysis] This analysis must be submitted to the Director of Nuclear l
Reactor Regulation for consideration prior to the granting of an operating license and must include, where acoropriate, consideration of:
(1) Accomolishing the safety function by some designated alternative equipment if the princioal equipment has not been demonstrated to be fully Qualified.
(2) The validity of partial test data in support of the original qualification.
(3) Limited use of administrative controls over equipment that has I
not been demonstrated to be fully qualif 3
(4) Comoletion of a safety function orior to exposure to accident environmentakresultingfromadesignbasiseventanothesubseouent 24 e.g.
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[7590-01]
failure of the eouipment does not degrade any safety function or mislead the operator.
(5) No significant dearadation of any safety function or misleading of the operator as a result of failure of equipment inder the accident j
environment resultina from a desian basis event.
[63],(1), A record of the qualification includina documentation in paracraph (d) of this saction must be maintained in [a-centrai-file]
an auditable form for the entire period durina which the covered item is installed in the nuclear power plant or is stored for future use to permit verification that each item of electric equipment important to safety covered by this section (1) is qualified for its application and (2) meets its specified perfo,rmance requirements when it is subjected to the conditions predicted to be present when it must perform its safety function up to the end of its qualified life.
(k) Licensees are not required to qualify electric equipment important to safety in accordance with the requirements of this rule provided the following conditions are met:
(1) The operatino license for the nuclear power plant was issued prior to [ Insert effective date of this rule] and has the existina license conditions or technical specifications that require electric equipment to be qualified according to " Guidelines for Evaluatina Environmental Qualification of Class 1E Electrical Equipment in Operatina Reactors,"
l November 1979, or NUREG-0588 (For Comment version), " Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment" and (2) Qualification of electric equipment important to safety commenced prior to [ insert effective date of this rule].
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(1) Replacement parts installed after November 30, 1985 must be cualified in accordance with the provisions of this section.
_OR*
Replacement parts cualified in accordance with 00R Guidelines or NUREG-0588 prior to the effective date of this rule are not.oouired to be recualified.
Dated at this day of
, 1982.
For the Nuclear Regulatory Commission.
4 Samuel J. Chilk Secretary of the Commission
" Delete the option not approved by the Commission.
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