ML20027D796

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Forwards Draft Proposed Rulemaking 10CFR50.49 & Revision 1 to Reg Guide 1.89,Task Rs 042-2, Environ Qualification of Electric Equipment Important to Safety for Light Water Cooled Nuclear Power Plants
ML20027D796
Person / Time
Issue date: 06/17/1981
From: Minogue R
NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
To: Fraley R
Advisory Committee on Reactor Safeguards
Shared Package
ML20027A669 List:
References
FOIA-82-426, RTR-REGGD-01.089, RTR-REGGD-1.089 CLI-80-21, NUDOCS 8211100069
Download: ML20027D796 (22)


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CENTRAL FILE JUN 17 IS3I RES SUBJ CHRON CIRC MEMORANDUM FOR: Raymond F. Fraley, Executive Ofrector EEB r/f Advisory Committee on Reactor Safeguards EEB Subject E502P R. Minogue FRG4:

Robert B. Minogue, Director D. Ross Office of Nuclear Regulatory Research L. Shao K. Goller

SUBJECT:

1.

PROPOSED RULEMAKING, SECTION 50.49 0F 10 CFR PAP.T 50, W. Morrison

" ENVIRONMENTAL AND SEISMIC 00ALIFICATION OF ELE A. Hintze EQUIPMENT IMPORTANT TO SAFETY FOR NUCLEAR PO W. Johnston 2.

PROPOSED REVISION 1 TO R.G.1.89, "EhVIRONiiENTAL MN QUALIFICATION OF ELECTRIC EQUIPMENT IMPORTANT T Arlotto G

i FOR LIGHT-WATER-COOLED NUCLEAR PONER PLANTS =

POR Enclosed for the Subco'mmittee on Regulatory Activities and the Electrical Systons Subcomittee are 20 copies of proposed Rulenaking package (Subject iten 1) and 20 copies of Revision 1 to R.G.1.89 (Subject item 2).

staff is proposing to clarify and strengthen the requircaents, in the Rule, The HRC and recommendations, in the Guide, for environmental qualification of elec-i tric equipnent important to safety.

committees an opportunity 'to comment on both the proposed rule and theT l

regulatory guide.

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Com tston and 0 der CLI-80-21 dated Mayreposed action with regard to 23, 1980.

The pi iposed Rule and proposed Revision 1 to R.G.1.89 will be issued l

for public comments.

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DAnvrood F. RoS58-E Robert B. Minogue, Director y

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Enclosures:

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Section 50.49 of 10 CFR Part 50 o., y 2.

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MEMORANDUM FOR: Raymond F. Fraley, Executive Director d

Advisory Committee on Reactor Safeguards j

FROM:

Robert B. Minogue, Director Office of Nuclear Regulatory Research

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SUBJECT:

1.

PROPOSED RULEMAKING, SECTION 50.49 0F 10 CFR PART '50, j

" ENVIRONMENTAL AND SEISMIC QUALIFICATION OF ELECTRIC EQUIPMENT IMPORTANT TO SAFETY FOR NUCLEAR POWER PLANTS" i

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PROPOSED REVISION 1 to R.G. 1.89, " ENVIRONMENTAL l

QUALIFICATION OF ELECTRIC EQUIPMENT IMPORTANT TO j

L SAFETY FOR LIGHT-WATER-COOLED NUCLEAR POWER PLANTS" i

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Enclosed fMD ' the Subcc.T.T.ittcc cc. Reynlatory f ctiv ii.ies end the Electrical SJ5'NE % hec-itte are } copies of proposed Rulemaking package (Subject item 1) and W copies (of Revision 1 to R.G.1.89 (Sub-h jectitem2). The NRC staff is-proposing to clarify and strengthen the requirements, in the Rule, and recommendations, in the Guide, for environmental qualification of electric equipment important to safety 4

, -The proposed action witn regard to the Rule has been nTandated by 6 Commission and Order CLI-80-21 dated May 23, 1980.

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The proposed Rule and proposed Revision 1 to R.G. 1.89 will be issued forpubliccomments.g N

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MEMORANDUM FOR: Raymond F. Fraley, Executive Dir ctor Advisory Committee on Reactor, Safeguards

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FROM:

Robert B. Minogue, Director /

Office of Nuclear Regulatory earch PROPOSED RULEMAKINGT'I'

SUBJECT:

1.

SECTION 50.49 0F 10 CFR PART 50, 3

" ENVIRONMENTAL 9UALIFICATION OF ELECTRIC EQUIPMENT IMPORTANT TO SAFETY FOR NUCLEAR POWER PLANTS"

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2.

PROPOSED REVISION 1 TO R.G.1.89, JQUALIFICATION 0F ELECTRIC EQUIPMENT IMPORTANT T SAFETY FOR Q

LIGHT-WATER-COOLED NUCLEAR POWER PLANTS" s

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Enclosed for use of the Subcommittee on Regulatory Activities and the Electrical Systems Subcommittee are 15 copies of proposed Rulemaking package (Subject item 1) and 15 copies of Revision 1 to R.G.1.89 (Subject item 2). The NRC staff is pr6 posing to clarify and strengthen the requirements, in the Rule, and recommendations, in the Guide, for environmental qualification /of electric equipment important to safety.

The proposed action with r! gard to the Rule has been mandated by the Commission and Order CLI-8'0-21 dated May 23, 1980.

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The proposed Rule and prdposed Revision 1 to R.G.1.89 will be issued for public comments.

///

Robert B. Minogue, Director Office of Nuclear Regulatory Research

Enclosures:

1.

Section 50.4 of 10 CFR Pt. 50 2.

Rev. 1 to R.

1.89 cc:

H. Denton T. Murley R. Matts n G. Knig ton R. Voll er J. Kni t

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10 CFR Part 50 DCMESTIC LICENSING OF PRODUCTION AND UTILIZATION FACILITIES Environmental and Seismic Qualification of Electric Equipment Important to Safety for Nuclear Power Plants AGENCY:

U.S. Nuclear Regulatory Commission.

ACTION:

Proposed Rule.

SUMMARY

The Nuclear Regulatory Commission is proposing to amend its regulations applicable to nuclear power plants to clarify and strengthen the criteria for environmental and seismic qualification of electric equip-ment important to safety.

Specific qualification methods currently con-tained in national standards, regulatory guides, and certain NRC publica-tions for equipment qualification have been given different interpreta-tions and have not had the legal force of an agency regulation.

The pro-posed rule would codify these qualification methods and otherwise clarify the Commission's requirements in this area.

DATES:

Comment period expires (60 days atter notice in Federal Register).

Comments received after expiration date will be considered if it is practical.to do so, but assurance of consideration cannot be given except as to comments received on or before this date.

ADDRESSEES:

Written comments and suggestions may be mailed to the Secretary of the Commission, Attention:

Docketing and Service Branch, U.S. Nuclear Regulatory Commission,-Washington, D.C. 20555, or hand 1

Enclosure "A"

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delivered to the Commission's Public Document Room at 1717 H Street NW.,

Washington, D.C., between the hours of 8:30 a.m. and 4:45 p.m. on normal work days.

FOR FURTHER INFORMATION CONTACT:

Satish K. Aggarwal, Office of Nuclear Regulatory Research, Electrical Engineering Branch, U.S. Nuclear Regula-tory Commission, Washington, D.C. 20555, Telephone 301-443-5946.

SUPPLEMENTARY INFORMATION: Nuclear power plant equipment important to safety must be capable of maintaining functional operability under all

~1 conditions postulated to occur during its installed life.

This require-ment is embodied in General Design Criteria 1, 2, 4, and 23 of Appendix A,

" General Design Criteria for Nuclear Power Plants," to 10 CFR Part 50,

" Domestic Licensing of Production and Utilization Facilities"; in Cri-terion III, " Design Control," and Criterion XI, " Test Control," of Appen-dix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," to 10 CFR Part 50; and in 10 CFR 6 50.55a(h), which incorporates by reference IEEE 279-1971,* " Criteria for Protection Systems for Nuclear Power Generating Stations." This requirement is applicable to equipment located inside as well as outside containment.

The NRC has used a variety of methods to ensure that these general requirements are met for electric equipment important to safety.

For the oldest plants, qualification was based on the fact that the electric components were of high industrial quality.

For nuclear plants after 1971, qualification was judged on the basis of IEEE 323-1971.

For

" Copies may be obtained from the Institute of Electrical and Electronics Engineers, Inc., 345 East 47th Street, New York, N.Y. 10017.

2 Enclosure "A" 9

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'j 6/17/81 plants whose Safety Evaluation Reports were issued after July 1,1974, the Commission has used' Regulatory Guide 1.89, " Qualification of Class 1E Equipment for Light-Water-Cooled Nuclear Power Plants," which endorses IEEE 323-1974,* "IEEE Standard for Qualifying Class 1E Equipment for

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Nuclear Power Generating Stations," subject to supplementary provisions.

Currently, the Commission has underway a program to reevaluate the qualification of electric equipment important to safety in all operating nuclear power plants.

As a part of this program, more definitive criteria 3

for environmental qualification of electric equipment have been developed j

by the NRC staff.

A document entitled " Guidelines for Evaluating Environ-mental Qualification of Class 1E Electrical Equipment in Operating Reac-tors" (DOR Guidelines) was issued in November 1979.

In addition, the NRC staff has 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 accord-ance with IEEE 323-1971 and the second for plants reviewed in accordance 1

with IEEE 323-1974.

2 By its Memorandum and Order (CLI-80-21) dated May'23, 1980, the Commission directed the staff to proceed with a rulemaking on environ-V' mental qualification of safety grade equipment and to address the ques-tion of backfit.

The Commission also directed that the 00R Guidelines and NUREG-0588 form the requirements licensees and applicants must meet until the rulemaking has been completed.

This proposed rule is based on the requirements o,~ the 00R Guide-L lines and NUREG-0588 and is intended to codify explicitly the Commissiori's 3

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requirements for the environmental and seismic qualification of electric equipment important to safety.

Technical areas addressed include (a) testing as the principal means of qualification, (b) analysis and operating

.j experience in lieu of testing, (c) ongoing qualification, (d) accelerated aging, (e) synergistic effects, (f) test parameter envelopes, (g) source

,1 terms, (h) margins, (i) documentation, and (j) backfit requirements.

Regu-l latory Guide 1.89 is being revised to describe methods acceptable to the

.j NRC staff for meeting the provisions of the rule; a draft of the proposed ij revision is being published for public comment concurrently with the pro-

,l posed rule.

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Upon publication of a final rule, the 00R guidelines and NUREG-0588 will be withdrawn.

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 promulgated, l

will not have a significant economic impact on a substantial number of small entities.

This proposed rule affects the method of qualification of electric equipment by utilities.

Utilities do not fall within the 1

definition of a small business found in Section 3 of the Small Business Act, 15 U.S.C. 632.

Additional testing required under this rule will generate business for small entities engaged in environmental testing.

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, notice is hereby given that adoption of the following amendment to 10 CFR Part 50 is contemplated.

1 4

Enclosure "A"

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i A new 5 50.49 is added to read as follows:

5 53.49 Environmental and seismic qualification of electric equipment important to safety for nuclear power plants.

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(a) Each holder of and applicant for a license to operate a nuclear power plant shall establish a program for qualifying all electric equip-ment important to safety as defined in paragraph (b) of this section.

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'l (b) Electric equipment important to safety means those electrically i

operated, actuated, or energized components necessary for the proper operation of systems important to safety as defined in Appendix A to this part.

Such systems include systems required to mitigate the consequences of an accident and those systems whose failure or malfunction could cause an accident or cause an accident in process to worsen.

Included are (1) systems required for reactivity control, (2) systems required for reactor and process system heat control, (3) systems required for con-tainment isolation, (4) systems required for maintaining containment L

integrity, (5) systems required for preventing significant release of radioactive material to the environment, (6) instrumentation essential for operator action in accomplishing (1) through (5), and (7) equipment that could fail in such a manner that the failure would prevent the '

l proper operation of equipment important to safety, cr mislead the operator.

(c) A list of all electric equipment important to safety shall be prepared and maintained in a central file.

This list shall, as a minimum, l

include:

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(1) The performance characteristics (such as accuracy and

~i response time) and integrity requirements under conditions existing during normal and abnormal operation, during the containment test, and J

during design basis events and afterwards and the times that integrity a

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i (2) The range of voltage, frequency, load and other electrical characteristics for which the performance specified in accordance with paragraph (c)(1) of this section can be ensured.

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(3) The environmental conditions, including temperature, pressure, humidity, radiation, chemicals, submergence, vibration, and seismic forces and their predicted variations with time, at the location where the equipment must perform as specified in accordance with para-graphs (c)(1) and (2) of this section.

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(d) The qualification program shall include the following:

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i (1) Known Synergistic Effects.

j (2) Aging.

Equipment qualified by test shall, where practi-cable, be preconditioned by natural or artificial (accelerated) aging to its " installed end-of-life condition." Aging considerations based on f

seismic and dynamic loads shall include a justifiable number of operating l

basis earthquakes and other dynamic (cyclic) loading effects.

Electro-l mechanical equipment shall be operated to simulate the expected mechanical wear and electrical degradation.

This shall be the qualified life for the l

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equipment.

Where preconditioning to a qualified life equal to the installed life is not possible, qualification to a shorter qualified life shall be performed.

Such equipment shall be replaced at the end of its qualified life unless ongoing qualification of prototype equipment naturally aged in plant service shows, by artificial aging and type testing, that the item has additional qualified life.

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'(3) Margins.

Quantified margins shall be applied to account for production errors and test instrument errors.

These margins shall be 1

in addition to margins applied during the derivation of the plant parameters.

(4) Temperature and Pressure.

The time-dependent temperature and pressure at the location of the equipment shall be established for the most limiting of the applicable postulated accidents and shall be used as the basis for the environmental qualification of electric aquip-i ment important to safety.

(5) Humidity.

Time-dependent variations of relative humidity during riormal operation and design basis events shall be considered.

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(6) Chemical Effects. The composition of chemicals used shall be equivalent to or more severe than that resulting from the most limit-l ing mode of plant operation (e.g., containment spray, emergency core cool-ing, or recirculation).

If the composition of the chemical spray can be

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affected by equipment malfunctions, the most severe chemical spray environment that results from a single failure in the spray system shall a

be assumed.

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(7) Radiation.

The radiation environment shall be based on the type of radiation and the dose and dose rate of the radiation environ-ment expected during normal operation over the installed life of the equipment plus the radiation environment associated with the most severe design basis event during or following which the equipment is required to remain functional, including the radiation resulting from recirculat-1 ing fluids for equipment located near the recirculating lines.

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.I (8) Submergence (if subject to being submerged).

(9) Seismic and Vibratory loads.

(i) Equipment shall be subjected to the forces resulting from one operating basis earthquake and one safe shutdown earthquake.

Other vibratory loads occurring during both normal operation and accidents shall be included.

(ii) Loads resulting from anticipate'd operational occurrences

_'j or accidents shall be combined with the seismic loads-in an appropriate manner.

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l (iii) The characteristics of the applicable input motion j

shall be specified by response spectra, time history, or other means if appropriate.

(e)

Each item of electric equipment important to safety shall be qualified by one of the following methods:

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8 Enclosure "A"

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(1) Testing an identical item of equipment.

i (2) Testing a similar item of equipment with a supporting analysis to show that the equipment to be qualified is acceptable.

(3) Experience with identical or similar equipment under

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similar conditions with a supporting analysis to show that the equipment

1 to be qualified is acceptable.

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(4) Analysis alone, subject to the approval of the NRC staff Ij in the following cases--

i (i) Type testing is precluded by the physical size of the equipment or by the state-of-the-art;

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(ii)' prototype equipment is not available; (iii) The equipment was installed prior to May 23, 1980.

q (f) If an item is to be qualified by test -

i ij (1) The acceptance criteria shall be established prior to testing.

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(2) The tests shall be designed and conducted to demonstrate

ij that the equipment can perform its required function as specified in accordance with paragraph ('c)(1) of this section for all conditions as specified in accordance with paragraphs (c)(2) and (3) of this section.

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The test profile (e.g., pressure, temperature, radiation vs. time) shall include sufficient margin to account for differences among various produc-tion units of the tested equipment and for errors within the instrumenta-tion monitoring and controlling the test. This margin shall be in addi-

'iy tion to that applied in deriving the values of the accident parameters.

(3) Th,e test profile shall be either (i) a single profile that

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j envelops the environmental conditions resulting from any design basis event during any mode of plant operation (e.g., a profile that envelops the conditions produced by the postulated spectrum of main steamline break and loss-of-coolant accidents) or (ii) separate profiles for each type of event (e.g., separate profiles for the MSLB accidents and for LOCAs).

b (4) The same piece of equipment shall be used throughout the complete test sequence under any given profile.

(5) For seismic and vibratory loads testing--

(i) Equipment shall be qualified using multifrequency and multiaxial input motions unless justification for using a single frequency P

input motion or a single axis input motion is provided.

(ii) The design of the test mounting shall simulate the actual service mounting and shall not cause any extraneous dynamic coupling to the equipment being tested.

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6/17/81 (iii) It shall be demonstrated that the actual input motion equals or exceeds the anticipated required input motion.

The duration of i

each test shall equal.or exceed the. strong motion portion of the design earthquake and other dynamic loads.

e (g) Installed electric equipment important to safety shall be sub-jected to adequate programs of preventive maintenance and quality assur-ance,includingroutinemaintenancetominimizedustaccumulationthat could degrade the ability of the equipment to function properly.

(h) A record of the qualification shall be maintained in a central file to permit verification that each item of electric equipment impor-tant to safety is qualified for its application and meets its specified performance requirements when subjected to the conditions pres,ent when it must perform its safety function up to the end of its qualified life.

Dated at this day of

, 1981.

For the Nuclear Regulatory Commission.

l-i Samuel J. Chilk l

Secretary of the Commission l

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.j VALUE/ IMPACT STATEMENT 1.

PROPOSED ACTION 1.1 Description a

1 The applicant (licensee) of a nuclear power plant is required by the Commission's regulations to verify that structures, systems and components

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important to safety will perform their intended functions in spite of the environments that may result from the anticipated operational occur,ences or

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postulated accidents.

This verification includes environmental and seismic

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qualification by test, operating experience, and analysis, or a combination

'j, of these.

The proposed rule sets forth the Commission's requirements for the

.j qualification of electric equipment important to safety by test and analysis 1

and the requirements for backfit.

1. 2 Need for Proposed Action 9

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The current general requirements for qualification of electric equipment important to safety are found in General Design Criteria 1, 2, 4, and 23 of Appendix A to Part 50;Section III and XI of Appendix B to Part 50; and 10 CFR 50.55a(h), which incorporates by reference IEEE 279-1971,* " Criteria for Protec-tion System for Nuclear Power Generating Stations." The NRC has used several methods to ensure that these general requirements are met for electric equipment important to s'afety.

For the oldest plants, qualification was based on the fact that the electric components were of high industrial quality.

For plants after 1971, qualification was judged on the basis of IEEE 323-1971.

However, no I

regulatory guide was ever issued endorsing IEEE 323-1971, although some of the I

plants referenced the standard in their licensing submissions to the. Commission.

j For the newest plants, whose safety evaluation reports were issued after July 1, 1974, the Commission has issued Regulatory Guide 1.89 which, in most respects, endorses IEEE 323-1974,* subject to supplementary provisions.

" Copies can be obtained from the Institute of Electrical and Electronics Engineers, Inc., 345 East 47th Street, New York, N.Y.10017.

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.i Currently, the Commission has underway a program to reevaluate the quali-fication of electric equipment important to safety in all operating reactors.

J As part of this program, the staff has developed more definitive criteria for y

the environmental qualification.

00R issued it " Guidelines for Evaluating

[3 Environmental Qualification of Class IE Electrical Equipment in Operating

[,j Reactors" in November 1979.

In addition, for reactors under licensing review, the staff has issued NUREG-0588, " Interim Staff Position on Environmental Quali-3l fication of Safety-Related Electrical Equipment."

In its Memorandum and Order (CLI-80-21) issued on May 23, 1980, the Commis-

.j sion endorsed the staff's actions to use the 00R Guidelines to review operating

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plants and NUREG-0588 to review plants under licensing review.

Further, the j

Commission ordered that these two documents form the requirements that licensees j

and applicants must meet in order to satisfy those aspects of Appendix A to

f 10 CFR Part 50 that relate to the environmental qualification of electric

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equipment important to safety.

The Commission also ordered that licensees of operating reactors are to comply with these requirements so that the applicable equipment in all operating plants will meet the DOR Guidelines or NUREG-0588.

The Commission also noted that the guidelines and NUREG-0588 appiy pro-l gressively less strict standards to older plants and that this problem is i

best resolved by a rulemaking.

The purpose of the proposed rule is to codify the current NRC practice with respect to qualification of electric equipment important to safety.

The proposed rule will apply the same uniform criteria 4 ~

to all operating nuclear power plants and plants for which application has been l

made for a construction permit or an operating license.

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1.3 Value/ Impact of Proposed Action 1.3.1 NRC Operations Since regulations specifically setting forth requirements for the qualifi-h cation of electric equipment important to sufety in new and operating plants have never been issued in the past, the proposed action should result in more effective effort by the staff in reviewing applications for construction permits and operating licenses, and in the backfitting of the these requirements to operating plants.

The proposed action will codify an NRC position by taking advantage of previous staff effort (1) in completion of a generic activity (A-24),

2 Enclosure "B"

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" Qualification of Class 1E Safety-Relatad Equipment," (2) in the preparation of the 00R Guidelines and NUREG-0588, (3) in IEEE standards committee work, and (4) in the development, funding, and monitoring of related research programs.

There should be little impact on the staff vis-a-vis the level of effort at the time the rule is approved. Approximately two man years of effort is f

anticipated in preparation of the rule.

1.3.2 Other Government Agencies Not applicable, unless the government agency is an applicant.

i 1.3.3 Industry q

The proposed rule applies uniform criteria to all nuclear power plants.

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If the final rule is published as now proposed, the rule would have considerable impact on industry because of backfit.

The value of this proposed rule is that the industry will have clearly specified requirements to follow with respect to the qualification of electric equipment important to safety for new and existing plants.

This, in turn, should ease the licensing process for industry by eliminating delays resulting from misinterpretation of NRC's requirements.

1.3.4 Public The proposed action will improve public safety by further ensuring that electric equipment important to safety will perform its safety functions in spite of environments that may result from design basis events.

1.4 Decision on Procosed Action The proposed action has been mandated by the Commission in its Memorandum and Order CLI-80-21 dated May 23, 1980.

2.

TECHNICAL APPROACH During the course of rule development over the next two years, it is not anticipated that significant technical improvement over the material in the D0R Guidelines and NUREG-0588 will be forthcoming from national standards 3

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.:j committees.

Ir. fact, a proposed revision (update) to IEEE 323-1974 is based j

on the technical material in NUREG-0588. Additional new material may, however,

'j be developed as a result of the various equipment qualification research pro-j grams currently underway.

Therefore, the technical approach will be essenti-4 ally to codify the programs of the D0R Guidelines and NUREG-0588 as applied at 1

j.

the time the final rule is published, with additional supplementary material

/

to reflect acceptable technical advances in this area.

.id 3.

PROCEDURAL APPROACH i'Y A

j Rulemaking has been mandated by the Commission in its Memorandum and Order

[:j cited above.

LiJ 3

4.

STATUTORY CONSIDERATIONS

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4.1 NRC Authority Authority for this Rulemaking is derived from the safety requirements of the Atomic Energy Act and the Commission's Memorandum and Order cited above.

4.2 Need for NEPA Assessment The proposed action is not a major action as defined in paragraph 51.5(a)(10) of 10 CFR Part 51 and does not require an environmental impact statement.

5.

RELATIONSHIP TO OTHER EXISTING OR PROPOSED REGULATIONS OR POLICIE i'

No conflicts or overlaps with requirements promulgated by other agencies are foreseen.

4 6.

SUMMARY

AND CONCLUSIONS i.

This rulemaking mandated by the Commission should be initiated immediately and developed in a timely manner for issuance for public comment.

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Enclosure "B" r,

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NRC PROPOSES RULEMAKING ON ENVIRONMENTAL AND SEISMIC QUALIFICATION OF ELECTRIC EQUIPMENT 4

The Nuclear Regulatory Commission is proposing a rulemaking on Environ-i mental and Seismic Qualification of Electric Equipment Important to Safety.

I The current requirements for qualification of structures, systems, and l

components important to safety are contained in General Design Criteria 1, 2, 4, and 23 of Appendix A to Part 50, Criterion III and XI of Appendix B to Part 56 and paragraph 50.55a(h) of 10 CFR Part 50.

These are general requirements stat-ing the principle that structures, systans, and components important to safety in a nuclear power plant shall be designed to accommodate the effects of envi-ronmental conditions and that design control measures such as testing shall be used to verify the adequacy of design.

Specific qualification methods have evolved over the past several years to ensure that these general requirements are met for electric equipment important to safety.

Although documented in various national standards, regulatory guides, and NRC publications, these specific methods have not been explicity codified as require tents in NRC's regulations.

The proposed rule will r xplicitly codify the current NRC practice with respect to qualification of slectric equipment important to safety.

Regulatory Guide 1.89 on this subject is being revised to provide guidance on methods acceptable to the NRC staff for meeting.the requirements of the proposed rule for the environmental qualification of electric equipment important to safety.

The full text of the proposed rule is being published in the Federal Register on Interested persons are invited to submit written 1

Enclosure "C"

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comments and suggestions on the proposed rule and the supporting value/ impact statement to the Secretary of the Commission, ATTN:

Docketing and Service Branch, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555.

Single copies of the proposed rule and the value/ impact statement may be obtained upon request from Mr. Satish K. Aggarwal, Electrical Engineering Branch, Office of Nuclear Regulatory Research, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, Telephone:

(301)443-5946.

Copies of the comments received by the Commission will be available for public inspection at the Commission's Public Document Room, 1717 H Street NW.,

j Washington, D.C.

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2 Enclosure "C"

f i

i ANALYSIS WITil RESPECT 10 PERIODIC AND SYSTEMATIC REVIEW 0F REGULATIONS (TMI ACTION PLAN TASK IV.G.2)

SUBJECT:

Section 50.49 pertaining to environmental and seismic qualification of electric equipment important to safety Criteria for Periodic and Systematic Review of Regulations NRC Compliance 1.

The proposed regulations are needed.

Specific environmental equipment qualification methods and criteria currently contained in national stantards, NRC regulatory guides, and other publications have been given different interpretations and have not had the legd1 force of Commission's regulation.

The preposed rule is needed to clarify and strengthen the methods and criteria for environmental qualification of electric equipment important to safety.

2.

The direct and indirect effects of the The direct and indirect effects of this rulemaking were regulations have been adequately considered.

considered in the Value/ Impact Analysis prepared in connec-tion with the proposed rule.

(See Enclosures B.)

3.

Alternative approaches have been considered Rulemaking was chosen as the least burdensome to codify 2

and the least burdensome of the acceptable the requirements pertaining to environmental qualifica-3 i

alternatives has been chosen.

tion of electric equipment important to safety.

1 i

4.

Public comments have been considered and an The proposed rule will be issued for public comments.

adequate response has been prepared.

i 5.

The regulation is written so that it is under-The proposed rule has been reviewed and edited for the standable to those who must comply with it.

specific purpose of ensuring that the regulation is clear and can be understood by persons who are required to comply with it.

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Enclosure D 4

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SUBJECT:

Section 50.49 pertaining to environmental and seismic qualification of electric equipment important i

to safety Criteria for Periodic and Systematic Review of Regulations NRC Compliance 6.

An estimate has been made of the new reporting There are no reporting requirement in the proposed rule.

burdens or recordkeeping requirements necessary It also does not place any additional burden to record-for compliance with the regulation, keeping beyond what is presently maintained by the applicants.

7.

The name, address, and telephone number of a The Federal Register notice promulgating the proposed rule knowledgeable agency official is included in contains the name, address, and telephone number of a the publication.

knowledgeable agency official.

~ 8.

A plan for evaluating the regulation after Licensee and staff experience with the regulation will be its issuance has been developed.

used to evaluate t:1e regulation.

In addition, this subpart i

will be reviewed in the second cycle of NRC's periodic and systematic review process (1986-1991).

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Enclosure D i

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