ML20027D798
| ML20027D798 | |
| Person / Time | |
|---|---|
| Issue date: | 06/16/1981 |
| From: | Ross D NRC |
| To: | Arlotto G NRC |
| Shared Package | |
| ML20027A669 | List:
|
| References | |
| FOIA-82-426 NUDOCS 8211100075 | |
| Download: ML20027D798 (3) | |
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{ 'c y.s m r.- LD 3-a. l}}(. I a_/ & l., Y l d t c' i JUN 16 IF 1 i A.'/L i tME TO: G. A.triotto FRG4: D. F. Coss $UBJECT: PAcc4E 10 ACRS 01 F20F03ED EQ RULE The following ecs:rtntt tre =t in agy particular ceder: 1. I note KRR wants " dust" cordf tfon rc=oved. Yet'?the RIL on teminal blocks mentions dust (alth::=gh not dust stoms). How shall this paradox b2 resoindt 2. I told Traley we muld scad hfa the draft rule and the R81.89, but not the Cns.:ntssion paper (as that muld delay cattcrs), and that we could j send it dr.wn this P.-fday. The Cc=.fssion paper states that the ACRS has reviewed the package and 2 con:urred. Yet, the Ele::trical Subce::stttes does not meet until afd-July (the 22nd). and thus it will be mid-August getting' full ACRS feedhsck (and thus late August getting to Cocsission. This neeting could be moved to 7 July if Z. Rosztoczy could attend, You should determine whether MRP wnts ACRS esv1w a conth earlier and whether Zoltan could be made available. 4. Hydrogen faurn envirornent is not spccffte, contrary to specific licensing policy in -ecant cases (Q:Gufrs. Sequoyah). When will the rettsad interim H rule be down, and 'what is, its' ' impact? 5. Environmental and Satsmic is not used uniformly throughout. 6. Can p. 4 of Corsafssion letter be revised to say "we will provide results of ACRs review in a supplement"? If so, you could send package on. I 7 Can rut concur in Ca= mission paper without a clean draft. 8. Top p. 6? Don't you have to go back to Cor:stssion with final nla? l para, b I 9. Da ma need to tell Cc=stssion, plans for nochanical EQt 10 When is there a clean draft of rule? - A'] 8211100075 821014 PDR FOIA CURRAN 62-426 PDR l
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- 0. A. Arlotto 2
!= 11.
- p. 6 of rule: Does L. Sho agree that 03E aging is taprtant? Se=rs q
sa-t of de einfants.
- 12. If H2 survivability is added it t::rald be,at step 4. p. 7 12.
- c. 7 of rule, paragraph 6: Ue use the p(. rase 'or more severe than",
but nowhere aise; 1s that sfgntficant? a 14 Does step 7. p. 7 "Padfation' inc1,cde,RU2EG-5727 i i i 15 Setsmic and Vibratory loads.appcars to oyerla,p aging. A 1". The "cargins' statenent seerns open-ende[with respsct to derivation 4 of plant parameters; did CSB agree? Also sargin statenants around in the rule; what are the conservatts:ssf, s 3 Stateeent of consideration; where is itf 17 e
- 10. Oces the Y/I statssent r:eed cost (fapact) on fr:dustry?
13. I see thet dust accumulation got picked up in RG insert. Top of p. 4 of RG 1.89: There is a May [23,1940 exclusion. C. p 21.
- o. a. tottm of RG: 00 TIC 1s, an industry code.
?2.
- p. E. mi.idl e: release of 50% of fodines to the,*atcosphere'f 1
- 23. I can not follow tha rusaber systas; 1s r?sd,fation envirorszent part of MSLBT (p. 6)
~ r, M. Top p. 7: Have fuels peop1,e considered fthese releases? i 25.
- p. 7, paragraph 5: I doubt.if,industryihas analysis capability.
l 2C. Why the rese=vation at top of p,. 8 on plateout? paragraph 7 l
- 27. Where is statistically.eeanin.gful test t.heory used?
j j 2?. paragraph 5e, p.12 is open-ended. t
- 29. P.a: angne verf ffed that implementationi(p.15) of guide is consistent wtth rule?
3::. s 16.- afddle. beginning with 'H3 wever..." is.not a sentence. e e
u.: S. A. I.-lotto,, G).,E2 m.agraph (3) on p.16: Ehtt does after F:ay 23,1C0 acant tibt i* ..- {fi "c=f:. ting star.dards"?' ~ ', ' ', ',i ~ ' N Sy need to dfscuss scoe of these natters with Vollmer, et al. Tha cae sef::::s f1a w f s H2 b:rrn eny1ronsent. Yad ahould 'ccrisult with Bernere 8 't (Flofshan) on their plans: 14'soori se'nd down a rule on Mr. I foresee, in A:rgust, the Ccmission reviewing two proposed EQ rul,es; one has H2 enviror. ment, ene docs r.ot, t, Orihnal Signed by C V Denwood F.Ross,3r. D. F. Ross, Deputy Director 5 office of 7tuclear Regulatory Research i cc: E. Case 5: D. Tullivan % 4garms1 ? l 4 DISTRIBUTION: CIRCN l CHRDF ~ sua.1 i DFRoss r/f j !l t f s t j .= 8 e = f ~ ~ RES:DD ~ DPoss:s'
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- o UNITED STATES
^,, ] 8 NUCLEAR REGULATORY COMMISSION g
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{ ,e ADVISORY COMMITTEE ON REACTOR SAFEGUARDS FC a gyppy.g4 o e WASHINGTON. D. C. 20555 [ -j July 27,1981 i 'I i i MEMORANDUM FOR: W. Kerr, Chairnian, ACRS Subcommittee on Electrical Systems 1 D. Fischer, Reactor Engineer )[(,,$sk i FROM:
SUBJECT:
SUBCOMMITTEE ON ELECTRICAL SYSTEMS MEETING OF JULY 22, 1981 1 I I have prep'ared the attached proposed meeting summary for your review. Copies are being distributed to the other ACRS members and Subcommittee con-sultants for their information and comment. Corrections and additions will be included in the n}inutes of the meeting.
Attachment:
As stated cc: ACRS Members ACRS Technical Staff W. Lipinski Z. Zunans P. Davis E. Case, NRR G. Zech, NRR Z. Rosztoczy, NRR G. Bagchi, NRR F. Akstulewicz, NRR
- 0. Sullivan, RES Sg.Aggarwal,RES.[
A. Hintze, RES E. Wenzinger, RES R. Sherry, RES nts dieunest fbb ,_,x,., As UmCiAIRJSFONW t
, July 27, 1981* b FO!" EXEMPT!0" (515 L. y* j PROPOSED
SUMMARY
g OF THE JULY 22, 1981 MEETING OF THE ACRS SUBCOMMITTEE ON ELECTRICAL SYSTEMS I l PURPOSE: } The purpose of the meeting was to review and comment on a proposed rule and J ] proposed regulatory guide revision on the environmental qualification of electrical equipment important to safety. The entire meeting was open to the public. d n. PRINCIPAL ATTENDEES: q ACRS NRC STAFF W. Kerr, Chairma" Z. Rosztoczy D. Moeller, Member G. Bagchi P. Davis, Consultant F. Akstulewicz W. Lipinski, Consultent D. Sullivan Z. Zudans, Consultant A. Aggarwal R. Savio, Designated Federal Employee A. Hintze D. Fischer, Staff E. Wenzinger R. Sherry OTHERS J. Gallagher, Westinghouse MEETING HIGHLIGHTS, AGREEMENTS, AND REQUESTS: 1. The NRC Staff presented to the Subcommittee the proposed rule and regu-latory guide on the environmental qualification of electrical equipment important to plant safety. The Staff stated that specific qualification methods currently contained in national standards, regulatory guides, and certain NRC publications for equipment qualification have been given different interpretations and have not had the legal force of an agency regul ation. The proposed rule would codify these qualification methods and otherwise clarify the Commission's requirements in this areas. As -GiBCtAl-11SE4ftt#=
j JULY 27, 1981 TOIA EXEMN70N4b}6-- ' PROPOSED
SUMMARY
}' ELECTRICAL SYSTEMS 1-3 f
- j directed by the Commissioners, the proposed rule addresses backfit and 3
is based on the requirements of DOR guidelines and NUREG-0588. These ?I documents currently promulgate the requirements licensees and appli-1 j cants must meet until the rule is issued. The technical areas addressed by the rule include: (a) testing as the principal means of qualifica-1 . tion, (b) use of analysis and operating experience in lieu of testing, ) (c) ongoing qualification. (d) accelerated aging, (e) synergistic 4 tj effects, (f) test parameter envelopes, (g) source tems, (h) margir:s, 1j (1) documentation, and (j) backfit ; quirements. Regulatory Gaide 1.89 [l is being revised to describe methods acceptable to the NRC Staff for meeting the provisions of the rule; a draft of the proposed revision will be published for public comment concurrently with the proposed rule. Upon publication of a final rule, the D0R guidelines and NUREG-0588 will be withdrawn. As part of their presentation, the Staff made the following points: a. The Staff knows of no technical issues requiring resolution prior to issuance of the Rule or Regulatory Guide. b. The Staff considers Class IE electrical equipment to be a subset of equipment "important to plant safety". c. The Staff clarified the definition of a mild environment (see proposed Reg. Guide 1.89, Section C.4.2, p.11). Equi-ment located in a mild environment is not required to be qualified by test. A mild environment is an environment that, even during accident conditions, is no more severe o L Mff!CIALWSE:0NtY-L.- q
l, July 27,1981- --Of?10tAl--USE 4Nt* = =::am PROPOSED
SUMMARY
j* ELECTRICAL SYSTEMS :1 i than the environment that would occur during normal power ,k plant operation or during anticipated operational occurrences. 4 .i d. The Staff stated that there was no impact on industry due to backfit as the requirements treated in the proposed rule were .i already in force under a Commission order. This statement was 'ater refuted by Mr. Gallagher of Westinghouse. He used NRC j documentation to show that equipment "important to plant ] safety" included both safety and non-safety grade equipment ? (see Attachment A). He further stated that systems affected by the proposed rule would include virtually all of the electrical systems in the plant. Presently and under the ,1 proposed rule, the specific list of systems "important to plant safet)" will be determined by the utility and NRC jointly. This list can vary considerably using the pro-posed rule. The Staff contends that the proposed rule is intended to include only a small class of equipment beyond what is now treated as safety-grade equipment. The Staff agreed to modify the text of the proposed rule to clarify its scope. 2. The Subcommittee discussed the proposed rule and regulatory guide. 1. The Subcommittee believes that there should be a systematic evaluation of all plant systems to determine what environ-mental qualifications are necessary. The Subcommittee felt that particular attention should be given to those
- -WflCIAL:USE:0NLY-F r.
7/27/81 b I TOIA CXEtiPHON {M5= ~
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- PROPOSED StJMMARY i
ELECTRICAL SYSTEMS 1 L systems which have not been categorized as safety-grade l but which can significantly affect the risk associated j with the operation of a nuclear plant. i
- 2) The Subcommittee found that the value impact evaluation should
') be improved. The evaluation should address the impact on industry 1 ,) of the proposed rule and regulatory guide revision are intended to
- 8 fomalize.
It would appear that compliance with the NRC guidelines d. q would result in substantial costs. A clear case for the need for and safety benefits of this additional regulation has not been 2 presented. The Subcommittee suggested that the NRC Staff should consider using risk assessment in evaluating the value impact of t these proposed regulation.
- 3) The Subcommittee believes that clear guidelines as to the type of equipment requiring environemtnal qualification should be fomulated.
The criteria in the proposed rule and regulatory guide are intended to be applied to " equipment important to plant safety". The NRC Staff has indicated that this is not intended to apply to a very much larger class of equipment beyond what is currently classified as " safety-grade". The definition of the "equpment important to plant safety" given in the proposed rule could be interpreted as applying to a much larger class of equipment.
- 4) The Subcommittee believes that the role of maintenance procedures in protecting the qualification of the equipment should be addressed.
-0mC!AL=USE-0NLY= c
~ WFFICIAL=USE 0NL#= -#ea-exeMeT-10u-< sis-L y. 4 PROPOSED
SUMMARY
j ELECTRICAL SYSTEMS - i 1
- 5) The Subcommittee feels that the need for and usefullness of the s
l proposed requirements for maintaining an extensive central file l of qualification records should be reexamined from a cost-benefit .i perspective.
- 6) The Subcommittee made numerous comments to the Staff regarding the j
wording and content of the proposed rule and regulatory guide. An i informal compilation of these comments will be provided to the Staff. 4 FUTURE MEETINGS: d The proposed rule and regulatory guide are scheduled to be discussed by the Subcommittee chairman at the August full ACRS meeting. ACRS comments from this meeting will b,e combined with those from the Subcommittee meeting. ACRS comments on the proposed rule and regulatory guide will be provided to the Staff by letter through Mr. Dircks. It is the NRC Staff's intent to meet with the Commissioners on August 10th to discuss the environmental 1' qualfication of electrical equipment important to safety. The proposed rule and regulatory guide will be issued for public comment after Commis-h [ sion concurrence is obtained, o ll l b a l 8 0FFICIALWSE20Nt-Y-t
3 ................:.= ~ SAFETY CLASSIFICATIONS NRC vs IAEA '.l l - l IMPORTANT TO SAFETY IMPORThMT TO SAFETY - (ENTIRE CIRCLE) i -(ENTIRE CIRCLE) l l i I ss l SAFETY-RELATED SAFETY-RELATED SSC i SAFETY FEA'TURES NON-SAFETY SAFETY-GRADE (QAB) i i OR SAFETY SYSTEMS OR I i SAFETY-RELATED NON-SAFETY-GRADE (MRR) f i l l Oe l HRR/QAB IAEA ,6 h em J + t
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