ML20027D799

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Notification of 810807 Meeting to Discuss Proposed Rule & Reg Guide Re Environ & Seismic Qualification of Electrical equipment.Marked-up Proposed & Meeting Schedule Encl
ML20027D799
Person / Time
Issue date: 08/07/1981
From: Savio R
Advisory Committee on Reactor Safeguards
To:
Advisory Committee on Reactor Safeguards
Shared Package
ML20027A669 List:
References
FOIA-82-426 NUDOCS 8211100078
Download: ML20027D799 (24)
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Text

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'h NUCLEAR REGULATORY COMMISSION $.g .. E ADVISORY COMMITTEE ON REACTOR SAFEGUARDS I 1 o T. g WASHINGTON, D. C. 20555 d August 7,1981 .t i ? IOGANDUM FOR: ACRS Members R.' Savio, fW'or Staff Engineer A. $. I .!l FRGi: S

SUBJECT:

AUGUST 7, 5:00 - 6:00 PM DISCUSSIONS ON THE QUALIFICATIm j OF ELECTRICAL EQUIPbENT, TAB 9 j The Comnittee is scheduled to discuss a prbposed rule and Regulatory Guide relating to the environmental and seismic qualification of electrical equip-ment. I have included a Status Report and copies of the material to be reviewed under Tab 9. I have this morning received copies of the proposed rule and Regulatory Guide which are different from the version included under Tab 9 originally and have attached copies to this letter. The changes on these copies have been made in pen and ink and will be sucmarized by the NRC Staff in their discussions with us. I u.uld call your attention to page 5 of the inclosed copy of the proposed rule and ask that you note the change that the NRC Staff has made to the statement regarding the scope of. the equip-ment which will be affected by the rule. This has been a major issue in the discussion of the proposed regulatory action and is likely to be a critical issue in the discussions this afternoon. Attachmnt: As stated AA 8211100078 821014 ^ p1 PDR FOIA CURRAN 82-426 PDR

~ [7590-01] -Cl17.' El7/8/ NUCLEAR REGULATORY COMMISSION 10 CFR Part 50 g: - y-- s s w : m ' %;Egp

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Environmental and Seismic Qualification of Electric Equipment 5-~..,. e<' for Nuclear Power Plants AGENCY: tiliiE 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 imp.tm.... m.e.f. 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 et.'......e clarify the Commission's, requirements in this area. fbN) Nc DATES: Commentperiodexpires(60daysafter/wiseeinrederalRegister).

  1. i.s da' k Comments received after ::G ni r d t: will be considered if it is i

practical to do so, but assurance of consideration cannot be given except as to comments received on or before this date. ADDRESS S: 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" lr

_~ [7590-01]__ ~ - ~ ~ ~ delivered to the Commission's Public Document Rocm at 1717 H Street NW., Washington, D.C., between the hours of 8:30 a.m. and 4:45 p.m. cn normal. wor H ays. FOR FURTHER INFORMATION CONTACT: Satish K. Aggarval, Office of Nuclear Regulatory Research, Electrical Engineering Branch, U.S. Nuclear Regula-tory Commission, Washington, D.C. 20555, Telephoneg01)443-5946. SUPPLEMENTARY INFORMATION: Nuclear power plant equipment important to y e m m ry J safety must k up d' 1' e' ' ' ' ; functional :;:d'"Y under all 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 Cower Plants and Fuel ReprocessingPlants,"to10CFRPart50;andin10CFR$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 A n v lo de 7/# requirements are met for electric equipment important to safety. Cc 'M

' t.t ;':.t;, qualification was based on the fact that the electric

/ den.seci lo ofeMN components were of high industrial quality. For nuclear plants after g 1971, qualification was judged on the basis of IEEE 323-1971. For 1 L ^ Copies may be obtained from the Institute of Electrical and Electronics Engineers, Inc., 345 East 47th Street, New York, N.Y. 10017. r a 2 Enclosure "A" r,

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i plants whose Safety Evaluati:n Reports were issued a M er July 1, 1974, J + i the, Commission has.iused Regulatory Guide 1.89, " Qualification of Class 1E Equ1TmentforLight-Water-CooledNuclearPowerPlants,"whichendorses 'I IEEE 323-1974,* "IEEE Standard for Qualifying Class 1E Equipment for Nuclear Power Generating Stations," subject to supplementary provisions. Currently, the Commiss, ion has underway a program to reevaluate the qualification of electric equipment important to safety in all operating ,j nuclear power plants. As a part of this program, more definitive criteria I for environmental qualification of electric equipment have been developed .s 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-0538, " 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 with IEEE 323-1974. By its Memorandum and Order (CLI-80-21) dated May 23,1980, the ' Commission directed the staff to proceed w' a rulemaking on environ - mental qualification of safety grade equipment and to address the ques-tion of backfit. The Commission also directed that the OCR Guidelines basis -{w and NUREG-0588 <<1rt the, requirements licensees and applicants must meet until the r S ec.'ng has been completed. fnenlly Th.c M 'a; ;ule is based on the requirements of the 00R Guide-4 lines and NUREG-0588 and is intended to codify =p? ?:"f7 the Commission's i I 3 Enclosur,e "A" e

v. [759,0-01] s 3 I 4 equirements for the environmental and seismic qualification of electric .) equipment ' p......-.. ml_.,. Technical areas addressed include (a) 1 1 tesWng as the principal means of qualification, (b) analysis and operating ~t experience in lieu of testing, (c) ongoing qualification, (d) accelerated j aging, (e) synergistic effects, (f) test parameter envelopes, (g) source I ' terms, (h) margins, (i) documentation, and (j) backfit requirements. Regu-3 1 latory Guide 1.89 is being revised to desNc ibe metho&s acceptable to the d NRC staff for meeting the provisin{ns nff%.a; a draft of the proposedCo ii' anl15 include 2Mt GJk egssism j] Gis sech% A s j revision is being published for public comment concurrently with the pro-J j posed rule. q Upon publication of a final rule, the 00R guidelines and NUREG-0588 will be withdrawn. F 7 R$GULATORYFLEXIBILIT ST M T f In accordance with the Regulatory Flexibility Act of 1980, 5 U.S.C. 605(b), the Commission hereby certifies that this rule, if promulgated, 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 definition of a small business found in Section 3 of the Small Business Act, 15 U.S.C. 632. Additiona1 testing required undar 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 c_ontemplated ~)5c att/ArrtY cEhahM h l0 ' 0 y (_.Tusehl / ) 4 Enclosure "A" I-.

f ] [7590-01] j N 1 I A new 6 50.49 is added to read as follows: 5 50.49 Environmental and seismic qualification of electric equipment ---; for nuclear power plants. oY (a) Each holder of end applicant for a license to operate a nuclear power plant shall establish a program for qualifying all electric equip-j ment important to safety as defined in paragraph (b)'of this section. (b) equipment important to safety means the electrically a ep ,rfepernad, actuatest r energized components necessary ' r the proper ej,Moperationofsystemsim tant to safety as defin in Appendix A to this -efwfM', Jar'd part. Such systems include s ' ems required mitigate the consequences hsh& g ge esser,//a / of an accident and tnose systems w. e fa' re or malfunction could cause h '{ " [ j,,an accident or cause an accident in pr ss to worsen. Included are cm4/nmen/ (1) systems required for reactivit' contro (2) systems required for Nolah'*Hs 7 enc /w erre reactor and process system he control, (3) sy tems required for con-cookm, ad e,,jg,,,,,J tainment isolation, (4) sy. ems required for maint 'ning containment an d seac/n' A,at,bu,u/["tegrity, (5) systems equired for preventing signifi ant release of j radioactive mater' to the environment, (6) instrumentat'on essential in M d"f for operator tion in accomplishing (1) through (5), and (/ equipment sipfc ~ he ye/eas < */ that co o fail in such a manner that the failure would prevent ygg/sach W w g.,//, ;pr. r operation of equipment important to safety, or mislead the opqtor. Oc00 (c) y 4 p u J rr b u p 'glist of all electric equ j usa 49.,fra"NO 44444. /',N if' wd. g a6,ve pr-c;.xf and maintained in a central file. 'his list s.krM, as a minimum, h CA ff include gg ,,, g ~ 5 h r"'$Y.. I l 15 Enclosure "A" ( f %%/sW -fury

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~. hw 'f N Yq ~ ] (1) The performance characteristics l' _ .._.._y 22 7:#rm ....d and integrity requirements under conditions existing duriflgnormalandabnormaloperation,duringthe,copainmen,ttes,t,and -w during design basis events and aftervards and '" -- "" integrity i 4' 4 i must be maintained, l (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. (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. ,n.st" v (d) The qualification program shtrH include the following: (1) Known Syneraistic Effects. wust (2) Aging. Equipment qualified by test shp4, where practi-cable, be preconditioned by natural or artificial (accelerated) aging to its " installed end-of-life condition." Aging considerations based on seismic and dynamic loads cha?4 include a justifiable number of operating basis earthquakes and other dynamic (cyclic) loading effects. Electro-m ust" mechanical equipment d.a44 be operated to simulate the r;::'M mechanical @ dcGu.iq dsid U4 b5 wear and electrical degradation. F... ...el l t : ' u -' " " ? d ' ' ': ':- 'N A 6 Enclosure "A" f~

. - -... n.. ;.. - _ ..a.~- ~ [7590-0,1] a i,, - .9 -). i ^-0 ;. 4E. Where preconditioning to a qualified life equal to the installed i li.fe is not pcssible, 7 : g# -p m erof w a f k jesen,sL L ef m. to a shorter qualified life :t E

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Such equipment be replaced at the end of its qualified life unless ongoing qualification of prototype equipment naturally aged in j plant service shows, by artificial aging and type testing, "that the item E has additional qualified 1.ife. 1 ruusf j (3) Margins. Quantified margins +han be applied to account y,sc<'hioska " CC"'* "" I* aAL i.j for production rrwr and test instruments:cre.T. These margins & " - } in addition to margins applied during the derivation of the plant parameters. (4) Temaerature and Pressure. The time-dependent temperature must and pressure at the location of the equipment sha'e+ be established for wu.e' the most limiting of the applicable postulated accidents and shau be used as the basis for the environmental qualification of electric equip-ment.# ;- ' '

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(5) Humidity. Time-dependent variations of relative humidity usuif during normal operation and design basis events-sham be considered. i-w ust-(6) Chemical Effects. The composition of chemicals used. sham-af fun.d as caveU-A s be c; :sa' ..t 0: ""r: thr. that resulting from the most limit- - -' a ing mode of plant operation (e.g., containment spray, emergency core cool-ing, or recirculation). If the composition of the chemical spray can be t l-affected by equipment malfunctions, the most severe chemical spray \\. nru d environment that results from a single failure in the spray system :ha'.1-be assumed. t i 7 Enclosure "A"

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w f' (7) Radiation. The radiation environment.sha'A be based on .j the type of radiation and the dose and dose rate of the radiation environ-I ment expected during normal operation over the installed life of the j 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-ing fluids for equipment located near the recirculating lines.

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

4 (9) Seismic and Vibratory Loads. WE (i) Equipment.+hett 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 sheti be included. wit (ii) Loads resulting from anticipated operational occurrences ,vr ud or accidents s)ntTT be combined with the seismic loads in an appropriate manner. l (iii) The characteristics of the applicable input motion masf shait-be specified by response spectra, time history, or other means,if appropriate. nrusl-(e) Each item of electric equipment 'hw.e --2-ktp eheFr be qualified by one of the following methods: r 8 Enclosure "A" l 1

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u--......a .. a ....w.2 v. j J [759,0-01] 2 m g J, .l (1) Testing an identical item of equipment. ~i (2) Testing a similar item of equipment with a supporting ~ a analysis to show that the equipment to be qualified is acceptable. } (3) Experience with identical or similar equipment under similar conditions with a supporting analysis to show that the equipment i to be qualified is acceptable. b inlleuflc'NW (4) Analysis aLue, subject to the approval of the NRC staff in the following cases-- (i) Type testing is precluded by the physical size of the equipment or by the state t; or ^ . -.m m.,....... (fif) The equipment was installed prior to May 23, 1980. (f) If an item is to be qualified by test - rndt (1) The acceptance criteria M be established prior to testing. onusf (2) The tests sAe;+ be designed and conducted to demonstrate that the equipment can perform its required function as specified in accorcance with paragraph (c)(1) of this section for all conditions as specified in accordance with paragraphs (c)(2) and (3) of this section. 9 Enclosure "A" 3-

[7590-01] m ? p1u.b The test profile (e.g., pressure, temperature, radiation vs. time) seraTT~ inc de sufficient margin to account for differences among various prodsc, tion units of the tested equipment and for errors within the instrumenta-tion monitoring and controlling the test. ThismarginA='$ b in addi-tion to that applied in deriving the values of the accident parameters. spsuGY (3) The test profile sham be either (i) a single profile that i envelops the environmental conditjons resulting frcm any design basis ) myr%yxs dar:9 mma of,erolkoet 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 s of event (e.g., separate profiles for the MSLB accidents and for LOCAs). %d (4) The same piece of equipment 4A+ H be used throughout the cceplete test sequence under any given profile. Eae.Ieismic and vibratory load [ testing?nuJ/ use (5) (i) t " - , a'.... m...Multifrequencyand i multiaxial input motions ~unless justification for using a single-frequency input motion or a single-axis input motion is provided. A Mai* (ii) P.: dW ' 'h test mounting 43&'.J simulatef the de*S actual service mounting and s M not cause any extraneous dynamic coupling to the equipment being tested. 10 Enclosure "A" !' ++ p_

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Aos 6/17/81 ,%) can be (fermdruhef hit :":'? 5e 'm :tr:td " '"e actual input motion iii) i a -] equal / or exceeds the anticipated :;_: _f-input motion. The duration of wr 'j each test 8:ll equal or exceed the strong motion portion of the design j earthquake and other dynamic loads. .l i (f ' :t.~.'. ,.r.m... i.- .., m. a. r _ _ Jr.,s.,,a-,..,., . 7,.,,,, m,,,, n,, a ,:,.---_. _ _,,, g,, 1

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__.....f....m. o.m J c: ' ' m. coe c.ie au... y v. ~ v.ie equ r.ent to runcuan grupo y. 2 J V wet j A record of the qualification gll53 be maintained in a central ?? 'l file to permit verification that each item of electric equipment G$hSeeh*oaL t:rt '- - r is qualified for its application and meets its specified performance requirements when subjected to the conditions present 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. t Samuel J. ChilK Secretary of the Commission l 11 Enclosure "A" l F* -Ia ,- -+

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....:. c...;. -...... j VALUE/ IMPACT STATEMENT 1. PROPDSED ACTION 1.1 Description The applicant (licensee) of a nuclear power plant is required by the Commission's regulations to verify that structures, systems and components important to safety will perform their intended functions in spite of the environments that may " result from the anticipated operational occurrences or postulated accidents. This verification includes environmental and seismic qualification by test, operating experience, and analysis, or a combination of these. The proposed rule sets forth the Commission's requirements for the qualification of electric equipment '7 t.2 M. '2; by test and analysis and the requirements for backfit.

1. 2 Need for Prooosed Action The current general requirements for qualification of electric equipment important to safety are found in Geraral 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 safety. 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 j regulatory guide was ever issued endorsing IEEE 323-1971, although some of.the l plants referenced the standard in their licensing submissions to the Commission. i. 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. 1 Enclosure "B"

r

m..... Currently, the Commission has underway a program to reevaluate the quali-p fication of electric equipment '7-":" " ::'A in all operating reactors. ~ As part of this program, the staff has developed more definitive criteria for-~. l the enviroTmental qualification. 00R issued it " Guidelines for Evaluating Environmental Qualification of Class IE Electrical Equipment in Operating Reactors", in November 1979. In addition, for reactors under licensing review, the staff has issued NUREG-0588, " Interim Staff Position en Environmental Quali-fication of Safety-Related Electr.ical Equipment." In its Memorandum and Order (CLI-80-21) issued on May 23, 1930, the Commis-sion endorsed the staff's actions to use the D0R Guidelines to review operating 1;j plants and NUREG-0588 to review plants under licensing review. Further, the Commission ordered that these two documents form the requirements that licensees and applicants must meet in order to satisfy those aspects of Appendix A to ] 10 CFR Part 50 that relate to the environmental qualification of electric equipment 4 _._ The Commission also ordered that licensees of _--y. operating reactors are to comply with these requirements so that the applicable equipment in all operating plants will meet the D0R Guidelines or NUREG-0588. - The Commission also noted that the guidelines and NUREG-0588 apply pro-gressively less strict standards to older plants and that this problem is 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 to all operating nuclear power plants and plants for which application has been made for a construction permit or an operating license. d ~

1. 3 Value/Imoact of proposed Action
1. 3.1 NRC Ooerations Since regulations specifically setting forth requirements for the qualifi-cation of electric equipment important to safety 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 riosition by taking advantage of previous staff effort (1) in completion of a generic activity (A-24),

K j 2 Enclosure "B" ? L If'

2.. .i " Qualification of Class 1E Safety-Related Equipment," (2) in the preparation of the 00R Guidelines and NUREG-0588, (3) in IEEE standards committee work, and j (4) in the development, funding, and monitoring of related research programs. f, ) There should be little impact on the staff ' " ': N T.'. ; ~ .j at tt.e time the rule is approved. Approximately two man years of effort is .j anticipated in preparation of the rule. 9 1l 1.3.2 Other Government Acencies Not applicable, unless the government agency is an applicant. .s _1 1.3.3 Industry 4 j The proposed rule applies uniform criteria to all nuclear power plants. i If the final rule is published as now proposed, the rule have .f jidd mpact on industry because of backfit. IMG bMM N k I" , j 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. i i

1. 4 Decision on Procosed Action 4

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 technidal improvement over the material in the 00R Guidelines and NUREG-0588 will be forthcoming from national standards H ] K:- ) 3 Enclosure "B" ll , r"

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.i. /) 4 ej committees. In fact, a proposed revision (update) to IEEE 323-1974 is based l on the technical material in NUREG-0588. Additional new material may, however, be develiggd as a result of the various equipment qualification research pro - grams currently underway. Therefore, the technical approach will be essenti-j ally to codify the programs of the 00R Guidelines and NUREG-0588 as applied at j the time.the final rule is published, with additional supplementary material j to reflect acceptable technical advances in this area. d

{

3. PROCEDURAL APPROACH .:) Rulemaking has been mandated by the Commission in its Memorandum and Order cited above. 4. STATUTORY CONSIDERATIONS 4.1 NRC Authority I 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. ,i 5. RELATIONSHIP TO OTHER EXISTING OR PROPOSED REGULATIONS OR POLICIES No conflicts or overlaps with requirements promulgated by other agencies are foreseen. i 6.

SUMMARY

AND CONCLUSIONS This rulemaking mandated by the Commission should be initiated immediately and developed in a timely manner for issuance for public comment. i 4 Enclosure "B" j.

.....__ 7 } NRC PROPOSES RULEMAKING ON ENVIRONMENTAL AND SEISMIC QUALIFICATION OF ELECTRIC EQUIPMENT The Nuclear Reg.aury Commission is proposing a rulemaking on Environ-mental and Seismic Qualification of Electric Equipment 1-; n t_cl *: T't. The current requirements for qualification of structures, systems, and 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 50 and paragraph 50.55a(h) of 10 CFR Part 50. These are general requirements stat-ing the principle that structures, systems, 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 ,._-'-~'

';ty.

Although documented in various national standards, regulatory guides, and NRC publications, these specific methods have not been explicity codified as requirements in NRC's regulations. The proposed rule will explicitly codify the current NRC practice with respect to qualification of electric equipment 'r.:- t_.t ' - ' "/. 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 o..,.m 2 : : ' n.-. .m... 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" I~ ~

.. q....a . ~.. f comments and suggestions on the proposed rule and the supporting value/ impact i: statement to the Secretary of the Commission, ATTN: Docketing and Service Branch, U T. 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. Aggarval, Electrical Engineering Branch, Office of Nuclear Regulatory Research, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, Telephone: (301)443-5946. H 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., Washington, D.C. e i l i l l l t 2 Enclosure "C" 'I =

..u,.... w w ;. _,. 1 m j ] ANALYSIS WITil RESPECT TO PERIODIC AND SYSTEMATIC REVIEW OF REGULATIONS (THI ACTION PLAN TASK IV.G.2) t

SUBJECT:

Section 50.49 pertaining to environmental and seismic 9 qualification of electric equipment ! p^-*=' 1: f *s E 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 E dif ferent interpretations and have not had the legal force [ of Commission's regulation. The proposed rule is needed to clarify and strengthen the methods and criteria for 9 environmental qualification of electric equipment important to safety. ?. The direct and indirect effects of the The direct and indirect effects of this rulemaking were c regulations have been adequately considered. considered in the Value/ Impact Analysis prepared in connec-l tion with the proposed rule. (See Enclosures B.) 3. Alternative approaches have been considered Rulemaking was chosen as the least burdensome to codify and the least burdensome of the acceptable the requirements pertaining to environmental qualifica-alternatives has been chosen. tion of electric equipment loportant to safety. E l 4. Public comments have been considered and an The proposed rule will be issued for public comments. [" adequate response has been prepared. l S. The regulation is written so that it is under-The proposed rule has been reviewed and edited for the Ll: 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. 'I, 1 Enclosure D e

. c. x .,n.. .....a_.. SUDJECT: Section 50.49 pertaining to environmental and seismic qualification of electric equipment i pa-*--* te r 2 '-'y - i 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. i 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 . h its issuance has been developed. used to evaluate the regulation. 3rrddI+1a=_'Khissubpart [ will be reviewed in the second cycle of HRC's periodic and systematic review process (1986-1991). l b e f. .g ' 2 Enclosure D j

~ ~ r ..~ _ s. l I,. SCHEDULE FOR AUGUST 7,1981 DISCUSSION ON ENVIROM4 ENTAL AND SEISMIC QUALIFICA-TION OF ELECTRICAL EQUIPMENT IMPORTANT TO SAFETY, 5:00 pm - 6:00 pm 1. Subcommittee Report - W. Kerr

ibmin,

'~ 2. Discussion with the NRC Staff a) NRC Summary of Proposed Rule and Proposed Reg Guide Revisions - S. Aggarwal./.............. 25 min Intent of Proposed Regulatory Action and Definition of Equipment Affected Sumary of Changes from Current Regulatory Action Schedule for Approval and Implementation b) Status of the Activities of the Environmental Qualifications Branch - Z. Rosztoczy t '. 15 min c) Committee Comments 10 min 9 O A to

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? s t t i July 23,1981 I I ACRS ELECTRICAL SYSTEMS SUBCOMMITTEE COMMMENTS - JULY 22,1981 MEETING The Subcommittee believes that a systematic evaluation of the qualification of " safety grade" and "euipment important to safety" and the-current guidelines for equipment qualification in existing plants should be pursued by the NRC Staff. Ve particularly encourage that attention be given to equipment which has not been categorized as safety grade but can significantly effect the risk - j associated with the operation of a nuclear plant. We have reviewed the proposed rule, titled, " Environmental and Seismic Qualification of Electric Equipment Important to Safety for Nuclear Power Plants," and the proposed revision to Regulatory Guide 1.89, titled, " Environmental Qualification of Electric Equip-ment Important to Safety for Light-Water-Cooled Nuclear Power Plants," and have the following comments: 1. Neither the proposed rule or the proposed Reg Guide revision contains a an interpretaable designationof the equipment which will be affected by these regulatory actions. If some clear specification cannot be made, a rule is premature. 2. The value-impact evaluation should be improved and should address the impact of the NRC guidelines which the proposed rule and Regulatory Guide revision are intended to formalize. It would appear that compliance with the NRC guidelines would result in substantial costs. A clear case for the need for and safety benefits of this additional regulation has not been presented. The NRC Staff should consider using risk assessment in assessing the value-1 impact of these proposed regulations. 3. The need for and the usefulness of the proposed requirements for the maintenance of an extensive central file of qualification records should be reexamined from a cost-benefit perspective. 1 1 l 1 a

.. _... _.. m; a. _..._......u._ I .e L. ( Electrical Systems Mtg i July 23, 1981 2 [ We also have the following comments of a more ) ~1. specific nature: 1! On the proposed rule, enclosure A - I a) page 6, Sec (d)(2) - Additional guidance should be provid ~ ' ; [ to what would be a " justifiable number of operati e as { earthquakes and other dynamic (cyclic) loading effects " 1 ng basis for b) page 7, Sec (d)(3) - The discussion relating to "margi f " errors" a y tainties. ppears tc be more appropriately addressed to uncer-ns" and i i '? c) models) by which temperature and pressu t I. determined should be specified. on 4 e d) j - page 7, Sec (d)(6) - Change " equivalent or morc severe" t "at least as severe as." i. o .c e) page 8. Sec (d)(ii) - The guidance as to the acceptable m i c' 4 for load combination should be clarified. e os I f) page 9, Sec (c)(4)(LL) - Delete " Prototype equipment is n t l available." { o g) page 11, Sec (g) - i Should be deleted - An undue emphasis appears to be given to the need to minimize dust accumula i 2. On the proposed rule, Enclosure 0: s t a) D.- .( page 2, Item 6 - It appears that, in contrast to the stat i ~ the proposed rule does impose record keeping require ^ ~ '.., ement those which are currently practiced by the Applica tments beyon,d 3. n s. On the proposed Regulatory Guide: E. I ' "a ) { page 4, Sec (a)(1) - Change " Methods for calculations" to F "Some acceptable methods for calculations. g .: b) without supporting test data" and "and (c) " p g is not available" alone pment I. c) not necessarily a limiting condition."page 4, Sec (a)(1) ~The last sentence states " High pressure i I s emphasis is given to pressure. It appears that an undue I d) i j page 6, Sec (2)(c) - Delete " solution" in " water as spray solution." i r!! i,u

u.. ~ ... ~ 3 ..,3 a <t F 'i F g Electrical Systems Mtg I July 23,1981 ( A 4 : e) ( page 8, Sec (3) - The spacial distribution of the sou'rce ters ~ should also be considered. 2 E j f) page 10, Sec (9) - Change " gamma radiation levels" to " g (, radiation dose", or " dose rate" or something appropriate quantitative. i g) page 10, Sec (12) - Further consideration should be given to 1(; establishing a lower limit of radiation dose below which ment qualification need not be reviewed. j h) Page 11, Sec (e)(1) - Delete the comma after "high ene i j i t breaks." rgy pipe !( 1) page 11, Sec (4)(a) - The NRC Staff appers to be stating that enviro.9 mental tests need not be perforemd when the accide 'f-environment is not more severe than what is experienc y nonnal plant operation or anticipated transient conditions t, This section should be revised to clarify the NRC Staff'

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I s f j) other than " thermal and cyclic degradation."page 12 es I k) I page 12, Sec (4)(d) - Chan component being qualified"ge "as close as practical to the L E, the environment." to "which adequately characterizes I I 1) page 13, Sec (4)(c) - The test environment provided by Cobalt I, and Cessium 137 sources will be different if the are sufficiently thick. p m) bined with other aging effects."page 14, Sec (6)(a) - Change - ( b f g n) I page 14, Sec (6)(b) - Change " calculated" to " expected " o) [ clarified as to the NRC's intent.page 16, Sec (8) - The word k g p) expanded to include examples of " materials tha ~~ identified as being susceptible to significant degradation d to aging." ue f j q) page 17, Sec (2) - Last sentence - Change "the valve operators and the motors" to "the valve operators and the motors prior to testing." [ r) pages 17-18, Sec (3) - Clarify " existing standards." i r I ' 18 i.' ,}}

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