ML20027D810
| ML20027D810 | |
| Person / Time | |
|---|---|
| Issue date: | 10/20/1981 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| Shared Package | |
| ML20027A669 | List:
|
| References | |
| FOIA-82-426 CLI-80-21, NUDOCS 8211100116 | |
| Download: ML20027D810 (27) | |
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'.s October 20, 1981 For:
The Commissioners From:
William J. Dircks Executive Director for Operations
Subject:
PROPOSED RULEMAKING, " ENVIRONMENTAL QUALIFICATION OF ELECTRIC EQUIPMENT FOR NUCLEAR POWER PLANTS"
Purpose:
.To obtain Commission approval for publication of the notice of a proposed rulemaking, " Environmental Qualification of Electric Equipment for Nuclear Power Plants," in the Federal Register.
Discussion:
The proposed rulemaking is being undertaken in response to the Commission's Memorandum and Order CLI-80-21 dated May 23, 1980, relating to the environmental qualification of electric equipment.
The proposed rule does not cover seismic and dynamic qualification of electric equipment.
The current requirements for qualification of structures, systems, and components important to safety are contained in General Design r
Criteria 1, 2, 4, and 23 of Appendix A to Part 50; Criteria III l
and XI of Appendix B to Part 50; and paragraph 50.55a(h) of 10 CFR Part 50. These are general requirements stating the principle l
that structures, systems, and components important to safety in a nuclear pcwer plant shall be designed to accommodate the effects of environmental conditions (i.e., remain functional under postu-lated accident conditions) and that design control measures such as testing shall be used to check the adequacy of design.
Specific qualification methods have evolved over the past several years to ensure that these general requirements are met for elec-tric equipment. Although most of these methods have been docu-mented in various national standards, regulatory guides, and NRC publications, none has been codified as requirements in NRC's regulations.
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Contact:
Satish K. Aggam1, RES 44-35946 l
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In brief, the evolution of environmental qualification has been as follows: Prior to 1971, qualification was based un the fact that the electric components were of high industrial quality.
For nuclear plants licensed to operate after 1971, qualification was judged on the basis of IEEE 323-1971.
In November 1974, the NRC staff issued Regulatory Guide 1.89, " Qualification of Class IE Equipment for Nuclear Power Plants," which endorsed IEEE 323-1974, "IEEE Standard for Qualifying Class IE Equipment for Nuclear Power
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Generating Stations," subject to supplementary provisions. Sub-sequently, more definitive criteria for environmental qualifica-tion of electric equipment were developed by the staff. 00R issued its " Guidelines for Evaluating Environmental Qualification of Class lE Electrical Equipment in Operating Reactors" in November 1979.
In addition, NUREG-0588, " Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equip-ment," was issued in December 1979. NUREG-0588 includes two sets of qualification requirements:
the first for plants originally reviewed in accordance with IEEE 323-1971 and the second for plants reviewed in accordance with IEEE 323-1974.
As a.' interim step, in its Memorandum and Order CLI-80-21, the Come ssion ordered that the DOR Guidelines and huREG-0588 (Decem-ber '.979 "for comment" issue) form the basis for the requirements that licensees and applicants must meet. The Commission also noted that the guidelines and NUREG-0538 apply progressively less strict standards to the older plants.and instructed the staff to justify its position if a single uniform standard is not applied to all viclear plants in the proposed rule. The proposed rule is generally based on the 00R Guidelines and NUREG-0588.
General Design' Criterion 4 states, in part, " Structures, systems, and components important to safety shall be designed to accommo-date the effects of and to be compatible'with the environmental conditions associated with normal operation, maintenance, testing, and postulated accidents, including loss-of-coolant accidents."
The scope of the proposed rule, however, does not include all electric equipment important to safety in its various gradations of importance. The proposed rule includes that portion of equip-ment important to safety commonly referred to in IEEE national standards as " Class IE" equipment ano some additional non-Class 1E equipment and systems.
The proposed rule will codify explicitly the current NRC practice with respect to environmental qualification of electric equipment and will apply the same uniform performance criteria to all operat-ing nuclear power plants and plants for which application has been made for a construction permit or an operating license.
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t Included are specific technical requirements pertaining to (a) qualification parameters, (b) qualification methods, and (c) documentation. The environmental qualification methods are progressively less strict for older plants.
Based on Commission Memorandum and Order CLI-80-21, the ifcensees and the NRC staff are in the process of identifying the systems and equipment that must be qualified. The proposed rule (Enclo-sure A) will apply to those systems and equipment identified during the ongoing review.
Currently, Regulatory Guide 1.09 is being revised and will con-tain methods acceptable to the WRC staff for meeting the Commis-sion's requirements for the environmental qualification of elec-tric equipment. Attached for your information as Enclosure E is a draft of Proposed Revision 1 to Regulatory Guide 1.89, " Environ-mental Qualification of Electric Equipment for Nuclear Power Plants." The implementation section provides guidance for meet-ing the qualification requirements of the proposed rule at older plants that takes into consideration the prior qualification history of these plants and the practicality and cost effective-l-
ness of conducting requalification testing of installed electric equipment.
For example, the proposed rule recognizes that anal-i ysis alone is justified where no prototype is available for testing.
Replacement parts, however, must meet the latest criteria for qualification.
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l The proposed rule and the proposed Revision 1 to Regulatory Guide 1.89 were reviewed by the ACRS El~ectrical Systems Sub-l committee on July 22, 1981. On August 7, 1981, the Advisory l
Committee on Reactor Safeguards reviewed the proposed rule and regulatory guide, which had been revised in response to the Sub-i committee's comments. ACRS concurrence to issue the rule and guide for public comment was received on August 7, 1981.
The staff plans to issue Proposed Revision 1 to Regulatory Guide 1.89 and the proposed rule concurrently and invite public comments on both.
Upon publication of the final rule, the 00R Guidelines and NUREG-0588 will be withdrawn.
The Commission's Memorandum and Order CLI-80-21 directed that the environmental qualification of electric equipment in operating nuclear power plants be completed by June 30, 1982.
However, on September 23, 1981, the Commission considered the petition (SECY-81-846) to extend this deadline. The proposed rule covers the same electric equipment as CLI-80-21 and implements SECY-81-486 by incorporating the extension dates recommended by the Chairman in his memorandum dated September 30, 1981.
If, after receipt of
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public comments, any significant delay is perceived in the develop-ment of the final rule, the provisions extending the deadline will be issued in a separate final. rulemaking.
On a long-term basis, the staff is considering expanding the scope i.
of the proposed rule to include additional electric equipment important to safety as deemed necessary to provide adequate assur-ance of public safety. The staff is also proposing to develop criteria for determining equipment important to safety and the relative importance of such equipment. An attempt will be made i
to prepare a list based on the criteria to include all equipment
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important to safety-electrical and mechanical. Accordingly, the staff plans to propose an advance notice of rulemaking on qualifica-tion of electrical and mechanical equipment important to safety.
This advance notice of rulemaking will also include tai requirement of seismic and dynamic qualification for electric equipment in nuclear power plants.
Public comments will be invited to assess the capabilities of testing laboratories and the cost, as well as the benefit, of testing all equipment important to safety. Sub-sequent to receipt of public comments, the staff will prepare a risk analysis to justify qualification based on decrease in risk.
Recommendation:
That the Commission:
1.
Approve a.
Publication of the proposed rule', " Environmental Quali-ficctirn of Electric Equipment for Ruclear Power Plants,"
for public comment.
b.
The staff's conclusions set forth in Enclosure 0, which provide the analysis called for by the Periodic and Systematic Review of the Regulations. The criteria used were derived from Executive Order 12044, which was rescinded on February 17, 1981, by Executive Order 12291 (see memorandum dated February 27, 1981, from L. Bickwit, General Counsel to the Commission). This approach is proposed as an interim procedure pending the Commis-sion's decision on Executive Order 12291.
2.
In order to satisfy the requirement of the Regulatory Flex-ibility Act, 5 U.S.C. 605(b), certify that this rule, if promulgated, will not have a significant economic impact on a substantial number of small entities. The proposed rule affects only the licensing and operation of nuclear power plants.
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3.
NOTE a.
That the notice of proposed rulemaking in Enclosure A will be published in the Federal Register allowing 60 days for public comment.
b.
That if, after expiration of the comment period, no I
significant adverse comments or significant questions l^
have been received and no substantial changes in the l.
text of the rule are indicated, the Executive Director lt for Operations will arrange for publication of the amendment in final form.
c.
That the information collection requirements in this proposed rule will be submitted to the Office of Maagement and Budget as a part of the general clear--
ance for 10 CFR Part 50.
d.
That, pursuant to 5 51.5(d) of Part 51 of the Commis-sfon's regulations, neither an environmental impact statement nor a negative declaration need be prepared in connection with the amendment since the amendment is nonsubstantive and insignificant from the stand-point of environmental impact.
a.
That the Subcommittee on Ene'rgy and the Environment of the House Committee on Interior and Insular Affairs, the Subcommittee on Energy Conservation and Power of the House Committee on Energy and Commerce, the Sub-committee on Environment, Energy and Natural Resourcas of the House Committee on Government Operations, and the Subcommittee on Nuclear Regulation of the Senata Committee on Environment and Public Works will be informed.
f.
That the Federal Register Notice of proposed rulemaking will be distr S uted directly to power reactor licensees /
permit holders, applicants for a construction permit for a power reactor, public interest groups, and nuclear steam system suppliers.
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That a public announcement (Enclosure C) prepared by the Office of Public Affairs will be issued when the i
Federal Register Notice is filed with the Office of the Federal Register.
Schedulino:
Recommend affirmation at an open meeting.
I
'Wi ias J. Dircks Executive Director for Opeirations
Enclosures:
A - Notice of Proposed Rulemaking B - Value/ Impact Statement C - Oraft Public Announcement 0 - Analysis with Respect to Review of Regulations E - Oraft Regulatory Guide 1.89 (Revised) b t
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That a public announcement (Enclosure C) prepared by the Office of Public Affairs will be issued when the Federal Register Notice is filed with the Office of the
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Federal Register.
Scheduling:
Recommend affirmation at an open meeting.
1 William J. Dircks Executive Of ractor for Operations
Enclosures:
A - Notice of Proposed Rulemaking 8 - Value/ Impact Statement C - Oraft Public Announcement 0 - Analysis with Respect to Review of Regulations E - Oraft Regulatory Guide 1.89 (Revised)
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NUCLEAR RECULATORY COMMISSION 10 CFR Part 50 Environmental Qualification of Electric Equipment for Nuclear Power Plants AGENCY: Nuclear Regulatory Commission.
ACTION: Proposed Rule.
SUMMARY
- The Nuclear Regulatory Commission is prooosing to amend its regulations applicable to nuclear power plants to clarify and strengthen the criteria for environmental qualification of electric equipment.
Specific qualification methods currently contained in national standards, regulatory guides, and certain NRC publications for equipment qualifica-tion have been given Jifferent interpretations anc have not had the legal force of an agency regulation. The proposed rule would codify these environmental qualification methods and clarify the Commission's require-ments in this area.
DATES: Comment period expires (60 days after publication in the Federal Register). Comments received after 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.
ADDRESSES: Written comments and suggestions may be mailed to the Secretary of the Commission, Attention: Occketing and Service Branch, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, or hand-delivered to the Commission's Public Document Room at 1717 H Street NW.,
1 Enclosure A
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Washington, D.C., between the hours of 8:30 a.m. and 4:45 p.m. on normal work days.
i FOR FURTHER INFORMATION CONTACT: Satish K. Aggarwal, Office of Nuclear I'
Regulatory Research, Electrical Enginesring 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 able to perform the safety functions throughout its e
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 Part 50, " Domestic Licensing of Production and utili-zation Facilities"; in Criterion III, " Design Control," and Criter' ion XI,
" Test Control," of Appendix B, " Quality Assurance Criteria for Nuclear l
Power Plants and Fuel Reprocessing P.lants," to 10 CFR Part 50; and in i
10 CFR 50.55a(h), which incorporate's 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 centainment.
The NRC has used a variety of methods to ensure that these general l
requirements are met for electric equipment important to safety.
Prior l
to 1971, qualification was based on the fact that the electric components l
l were of high industrial quality. For nuclear plants ifcensed to op rate I
after 1971, qualification '.;as 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, " Qualification of Class IE I
' 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 l
Engineers, Inc., 345 East 47th Street, New York, N.Y.10017.
2 Enclosure A l
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Equipment for Light-Water-Cooled Nuclear Power Plants," which endorses IEEE 323-1974,2 "IEEE Standard for Qualifying Class li Equipment for Nuclear Power Generating Stations," subject to supplementary provisions.
Currently, the Commission has undenvay 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 for environmental qualification of electric equipment have been developed by the NRT. A document entitled " Guidelines for Evaluating Environmental Qualification of class 1E Electrical Equipment in Operating Reactors" (00R Guidelines) was issued in November 1979.
In addition, the NRC 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 accordance with IEEE 323-1971 and the second for plants reviewed in accordance with IEEE 323-1974.
l By its Memorandum and Order CLI-80-21 dated May 23, 1980, the Commission directed the staff to proceed witn a rulema. ting on environ-mental qualification of safety grada equipment and to address 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 m'.;t meet until the rulemaking has been completed. This proposed rule is generally based on the requirements of the Division of Operating i'
Reactors (00R) Guidelines and NUREG-0588.
The Commission's Memorandum and Order CLI-80-21 directed that the i
environmental qualification of electric equipment in operating nuclear power plants be completed by June 30, 1982. However, on September 23, l
3 Enclosure A t
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1981, the Commission considered the petition (SECY-81-846) to extend this deadline. The proposed rule covers tt.e same electric equipment'as CLI-80-21 and implements SECY-81-486 by incorporating the extension dates recommended by the Chairman in his memorandum dated September 30, 1981.
The scope of the proposed rule does not include all electric equip-ment important to safety in its various gradations of importance.
It includes that portion of (quipment important to safety commonly referred to as " Class 1E" equipment in IEEE national standards and some additional
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non-Class IE equipment and systems whose failure under extreme environ-mental conditions could prevent the satisfactory accomplishment of safety functions by accident-mitigating equipment.
Included in the proposed rule are specific technical requirements pertaining to (a) qualification parameters, (b) qualification methods, l
and (c) documentation. Qualification parameters include temperature, e
pressure, 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 rule would require that the qualification program include synergistic effects, aging, margins, radiation. and environmental conditions. Also, a record of qualification must be maintained. Regulatory Guide 1.89 is l
being revised to describe methods acceptable to the NRC for meeting the provisions of this proposed rule and to include a list of typical equip-ment covered by it; a draft of the proposed revision is being published for public comment concurrently with the proposed rule.
l The proposed rule will codify the Commission's current requirements for the environmental qualification of electric equipment. Upon publica-tion of a final rule, the 00R guidelines and NUREG-0588 will be withdrawn.
4 Enclosure A l
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.,j To provide adequate assurance of public safety, NRC is considering i
expansion of the scope of this proposed rule to include additional elec-tric equipment important to safety and seismic and dynemic qualification for electric equipment in nuclear power plants. These matters will be the subject of a future rulemaking.
Paperwork Reduction Act The proposed rule contains recordkeeping requirements that are sub-i fact to review by the Office of Management and Budget (OMB). As required by P.L.96-511, this proposed rule will be submitted to OMB for clearance of the recordkeeping requirements.
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
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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.
In addition, utilities are required by Commission's l
l Memorandum and Order CLI-80-21, dated May 23, 1980, to meet the require-ments contained in the 00R " Guidelines for Evaluating Environr. ental Qualification of Class lE Electric Equipment in Operating Reactors,"
(November 1979) and NUREG-0588, " Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment," whicn form the basis of this proposed rule. Consequently, this rule codifies existing requirements and imposes no new costs or obligations on utilities.
5 Enclosure A l
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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 f
the United States Code, notice is hereby given that adoption of the l
following amendment to 10 CFR Part 50 is contemplated.
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1.
The authority citation for 10 CFR Part 50 reads as follows:
AUTHORITY: Secs. 103, 104, 161b and i, 182, 183, 189, 68 Stat. 936, 937, I
948, 953, 954, 955, 956, as amended (42 U.S.C. 2133, 2134, 2201(b) and (i),
2232, 2233, 2239); secs. 201, 202, 206, 88 Stat. 1243, 1244, 1246 (42 U.S.C.,
5841, 5842, 5846), unless otherwise noted. Section 50.78 also issued under Sec. 122, 68 Stat. 933 (42 U.S.C. 2152). Sections 50.80-50.81 also issued under Sec. 184, 68 Stat. 954, as amended; (42 U.S.C. 2234). Sec-tions 50.100-50.102 issued under Sec. 186, 68 Stat. 955; (42 U.S.C. 2236).
For Purposes of Sec. 223, 68 Stat. 958, as amended; (42 U.S.C. 2273),
9 50.54 (i) issued under Sec. 1611, 68 Stat. 949; (42 U.S.C. 2201(1)),
SS 50.70, 50.71 and 50.78 issued under Sec. 1610, 68 Stat. 950, as amended; (42 U.S.C. 2201(o)) and the Laws referred to in Appendices.
2.
A new 5 50.49 is added to read as follows:
5 50.49 Environmental qualification of electric equipment for nuclear power plants.
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(a) Each holder of or each applicant for a license to operate a nuclear power plant shall establish a program for qualifying the electric equipment as defined in paragraph (b) of this section.
(b) Electric equipment and systems covered by this section include electric equipment and systems that are essential to emergency reactor shutdown, containment isolation, reactor core cooling, and containment 6
Enclosure A
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and reactor heat removal or that are otherwise essential in preventing significant release of radioactive material to the environment.
Included is equipment (1) that performs the above functions automatically, (2) that is used by the operator to perform these functions manually, and (3) whose failure can prevent the satisfactory accomplishment of one or more of the above safety functions.
(c) The applicant or licensee shall prepare a list of all electric l
equipment covered by this section and maintain it in a central file.
This list of equipment must, as a minimum, include:
(1) The performance characteristics and integrity requirements under conditions existing during normal and abnormal operation and during design basis events and afterwards and the lengths of the periods curing which the integrity must be maintained.
(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, incinding temperature, pressure, humidity, radiation, chemicals, and submergence, and the predicted varia-tions of these environmental conditions with time at the location where the equipment must perform as specified in accordance with paragraphs (c)(1) and (2) of this section.
(d) The electrical equipment qualification program must include the following:
(1) Temoerature and Pressure. The time-dependent temperature and pressure at the location of the equipment must be established for the most limiting of the applicable postulated accidents and must be used as the basis for the environmental qualification of electric equipment.
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(2) Humidity. Time-dependent variations of relative humidity during normal operation and design basis events must he considered.
f (3) Chemical Effects.. The composition of chemicals used must be at least as severe as that resulting from the most limiting mode of q
plant operation (e.g., containment spray, emergency core cooling, or t
recirculation 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 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 folluwing which the equipment is required to remain functional, including the radiation resulting from recirculat-l, ing fluids for equipment located near the recirculating lines.
(5) Agi.ng. Equipment qualified by test must, where practi-cable, be preconditioned by natural or artificial (accelerated) aging l'
to its installed end-of-life condition. Electromechanical equipment I
must be operated to simulate the mechanical wear and electrical degrada-tion expected during its installed life. Where preconditioning to a qualified life equal to the installed life is not possible, the equipment may be preconditioned to a shorter qualified life. The equipment.T.ust be replaced at the end of its qualified life unless ongoing qualification of prototype equipment naturally aged in plant service shows, by artificial i
l aging and type testing, that the item has additional qualified life.
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(6) Submergence (if subject to being submerged).
(7) Syneraistic Effects. The preconditioning and testing of equip-ment must consider known synergistic effects when these effects are known 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 derivation of the environmental
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conditions.
(e) Each ites of electric equipment must be qualified by one of the following methods:
(1) Testing an identical item of equipment.
(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 similar conditions with a supporting analysis to show that the equipment to be qualified is acceptable.
(4) Analysis in lieu of testing in the following cases, subject to the approval of the NRC:
(i) Type testing is precluded by the physical size of the equipment l
or by the state of the art; or (ii) The equipment was installed prior to May 23, 1980.
(f) If an item of electric equipment is to be qualified by test -
(1) The acceptance criteria must be established prior to testing.
(2) The tests must be designed and conducted to demonstrate that the equipment can perform its required function as specified in accord-ance with paragraph (c)(1) of this'section for all conditions as speci-fied in accordance with paragraphs (c)(2) and (3) of this section. The 9
Enclosure A i
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tast profile (e.g., pressure, temperature, radiation vs. time) must include margins as set forth in paragraph (d)(9) of this section.
(3) The test profile must be either (i) a single profile that 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 (MSLB) and loss-of-coolant accidents (LOCA)) or (ii) separate pro-files for each type of event (e.g., separate profiles for the M3LB acci-lA dents and for LOCAs).
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(4) The same piece of equipment must be used throughout the complete test sequence under any given profile.
(g) Each holder of an operating license issued prior to the effective date of this rule must submit a schedula for the environmental qualifica-tion of electric equipment within 90 days after the effective date of this rule. This schedule must establish a goal of final environmental qualifi-cation by the end of the second refueling outage after March 31, 1982.
The Director of Nuclear Reactor Regulation may grant requests for exten-sions of this deadline to a date no later than November 30, 1985, for specific pieces of equipment if such requests are filed on a timely basis and demonstrate good cause for the extension, such as procurement lead time, test complications, and installation problems.
In exceptional cases, the Commission itself may consider and grant extensions beyond l
November 30, 1985 for completion of environmental qualification.
l (h) Each licensee shall notify the Commission of any significant equipment qualification problem that may require extension of the comple-tion date within 30 days of its discovery.
10 Enclosure A
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.i (i) For the continued operation of a nuclear plcnt, each holder,of,.
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anoperatinglicenseissuedpriortotheeffecti(edateofthisrule j
shall perform an analysis to, ensure that the plant can be safely operated pending completion of the environmental qualification. The detailed analysis for. each equipment type with appropriate justification must be.
Y submitted to Director of Nuclear Reactor Regulation within 90 days after the effective date of the rule and must include, where appropriate, consideration of:
(1) Accomplishing the safety function by some designated alternative equipmentthathasbeenadequatelyqualifiedandsatisfiestriesingle-failure criterion if the principal equipment has not been demonstrated to be fully qualified.
(2) The validity of partial test data in support of_the originale.,
qualification.
(3) Limited use of. administrative controls over equipment that-bas not been demonstrated to be fully qualified.
(A) Completion of the safety function prior to exposure t'o the ensuing harsh environment and the subsequent failure of the equipment does not degrade any safety function or mislead the operator.
(5) No significant degradation of any safety function or misleading N the operator as a result of failure of equipment under the harsh environment.
(j) The applicant for an operating license that is granted on or after the effective date of this rule, but prior to November 30, 1985, must perform an analysis to ensure that the plant can be safely operated pending completion of the environmental qualification in accordance with paragraph (i) of this section except that this analysis must be L
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submitted to the Director)of Nuclear Reactor Regulation for consideration
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(k) y recorM'of the qualification must be'aaintained in a central N
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1' f$le to permit verificatior th.st each ites of electric equipment covered j
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!cy this section (1) is qualified for its application and (2) meets its ss s
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specifie?J performancy requirements when it is subjected to the conditions s
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Dated 4t,
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For the Nuclear Regulatory Commission.
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l 12 Enclosure A t
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VALUE/ IMPACT STATEMENT 1.
PROPOSED ACTION 1.1 Description l
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 anticipated operational occurrences or postulated accidents.
This verification includes environmental qualification by test, operating experience, and analysis, or a combination of these. The proposed rule sets forth the Commission's requirements for the environmental qualification of electric equipment by test and analysis.
- 1. 2 Need for Proposed Action i
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-l tion Systems. for Nuclear Power Generating Stations." The NRC has used several methods to ensure that these general requirements are met for electric equipment.
Prior to 1971, qualification was based on the fact that the electric components were of high industrial quality. For nuclear plants licensed to operate after
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1971, qualification was judged on the basis of IEEE 323-1971. However, no L
regulatory guide was ever issued endorsing IEEE 323-1971, although some of the j.
plants referenced the standard in their licensing submissions to the Commission.
For the plants whose safety evaluation reports were issued after July 1,1974, the Commission has issued Regulatory Guide 1.89, which endorses IEEE 323-1974*
subject to supplementary provisions.
" 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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1 Enclosure B F
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l Currently, the Commission has underway a program to reevaluate the quali-fication of electric equipment in all operating reactors. As part of this p"ogram, the staff has developed more definitive criteria for the environmental qualification. The Division of Operating Reactors (DOR) issued " Guidelines for Evaluating Environmental Qualification of Class IE Electrical Equipment in Operating Reactors" in November 1979.
In addition, for reactors under licens-ing review, the staff has issued NUREG-0588, " Interim Staff Position on Environ-mental Qualification of Safety-Related Electrical Equipment."
In its Memorandum and Order CLI-80-21 issued on May 23, 1980, the Commis-sion endorsed the staff's actions to use the 00R Guidelines to review operating plants and NUREG-0588 to review plants under licensing review. Further, the Commission ordered that these two documents form the basis for requirements that ifcensees and applicants must meet in order to satisfy those aspects of Appen-dix A to 10 CFR Part 50 that relate to the environmental qualification of elec-tric equipment. The Commission also ordered that licensees of operating reac-tors must comply with these requirements so that the applicable equipment in all operating plants will meet the 00R Guidelines or NUREG-0588.
The Commission also noted that the guidelines red 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.
The proposed rule will apply the same uniform performance criteria for environ-mental qualification to all operating nuclear power plants and plants for which application has been cade for a construction permit or an operating ' license.
- 1. 3 Value/ Impact of Procosed Action l
l 1.3.1 NRC Operations Since regulations specifically setting forth requirement.or the qualifi-cation of electric equipment in new and operating plants have never been issued, 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 l
(1) in completion of a generic activity (A-24), " Qualification of Class 1E l
Safety-Related Equipment," (2) in the preparation of the 00R Guidelines and 2
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i NUREG-0588, (3) in IEEE standards committee work, and (4) in the development, funding, and monitoring of related research progranis.
There should be little impact on the staff at the time the rule is approved.
Approximately two man years of effort is anticipated in preparation of the rule.
1.3.2 Other Government Acencies Not applicable, unless the government agency is an applicant.
j 1.3.3 Industry The licensees and applicants currently must meet the requirements for qualification of electric equipment in accordance with the Commission's Memorandum and Order CLI-80-21.
If the final rule is published as now pro-posed, the rule will not have significant impact on industry because of backfit.
The value of this rule is that the industry will have clearly specified requirements to follow with respect to the quali.fication of electric equipment for new and existing plants. This, in turn, should ease the licensing process for industry by eliminating delays resulting from misinterp etation of NRC's requirements.
- 1. 3. 4' Public The proposed action will improve public safety by further ensuring that electric equipment will perform its safety functions in spite of environments that may result from design basis events. These is no perceived impact on the public.
- 1. 4 Decision on Proposed 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 j
anticipated that significant technical improvement v.7c the material in the 3
Enclosure B I
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i 00R Guidelines and NUREG-0588 will be forthcoming from national standards
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committees.
In fact, a proposed revision (update) to IEEE 323-1974 is based j
on the technical material in NUREG-0588. Additional new material say, however, be developed as a result of the various equipment qualification research pro-I grams currently underway. Therefore, the technical approach will be to codify j
the programs of the 00R Guidelines and NUREG-0558 as applied at the time the
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final rule is published, with additional supplementary material to reflect accaptable technical advances in this arria.
ll 3.
PROCEDURAL APPROACH
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Rulemaking has been mandated by the Commission in its Memorandum and. Order cited above.
4.
STATUTORY CONSIDERATIONS 4.1 NRC Authority Authority for this rulemaking is derived.from the Atomic Energy Act of 1954, as amended, and the Energy Reorganization Act of 1974, as amended.
I 4.2 Need for NEPA Assessment The proposed action does not require an environmental impact st'atement in accordance with 51.5(d)(3) of 10 CFR Part 51.
5.
RELATIONSHIP TO OTHER EXISTING OR PROPOSED REGULATIONS OR POLICIES No conflicts or overlaps with requirements promulgated by other agencies j
are foreseen.
6.
SUMMARY
AND CONCLUSIONS This rulemaking mandated by the Commission should be initiated immediately and conducted in a timely manner.
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Enclosure B I
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NRC PROPOSES RULEMAKING ON ENVIRONMENTAL QUALIFICATION OF ELECTRIC EQUIPMENT The Nuclear Regulatory Commission is proposing a rule on Environmental Qualification of Electric Equipment.
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 4
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 2
in a nuclear power plant must be designed to accommodate the effects of envi-ronmental conditions and that design control measures such as testing must be used to verify the adequacy of design.
Specific qualification methods have evolved over the past decade to ensure l
that'these general requirements are met for electric equipment. Although docu-i mented in various national standards, regulatory guides, ar.d NRC publications, these specific methods have not been codified in NRC's regulations.
The proposed rule would codify the current NRC practice with respect to qualification of electric equipment. Regulatory Guide 1.89 on this subject is being revised to provide guidance on methods acceptable to the NRC for meeting the requirements of the proposed rule for the environmental qualification of electric equipment.
The full text of the proposed rule is being published in the Federal Register on Interested persons are invited to submit written.
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Enclosure C i
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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. Aggcrwal, 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 4.11 be available for public inspection at the Commission's Public Document Room, 1717 H Street NV.,
Washington, D.C.
2 Enclosure C I
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ANALYSIS WITil RESPECT TO PERIODIC AND SYSTEMATIC REVIEW 0F REGULATIONS (THI ACTION PLAN TASK IV.G.2) l
SUBJECT:
Section'50.49 pertaining to environmental qualification k
of electric equipment
- i Criteria for Periodic and Systematic Review
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i of Regulations NRC Compliance y
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The proposed regulations are needed.
Specific environmental equipment qualification methods anu criteria currently contained in national stantards, NRC regulatory guides, and other publications have been given different 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 environmental qualification of electric equipment.
2.
The direct and indirect effects of the There will not be any significant cost impact on the regulations have been adequately considered.
industry because of backfit. The licensees are required
- a by the Commission's Memorandum and Order CLI-80-21 dated Ij h:
4 May 23, 1980 to meet the requirements contained in the l
00R " Guidelines for Evaluating Environmental Qual'!' cation
.of Class IE Electrical Equipment in Operati.ig Re _.s,"
(November 1979) and NUREG-0588, "Interin Staff Position
.on Environmental Qualification of Safety-Related Electrical Equipment," which form the basis of this proposal. Conse-li quently, this rule codifies existing requirements and j
imposes no new costs or obligations on licensees.
i 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.
Lion of electric equipment.
4.
Public comments have been considered and an The proposed rule will be issued for public comments.
adequateresponsehasbeenprepar,ej.
1 Enclosure D
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SUBJECT:
Section 50.49 pertaining to environmental qualification of electric equipment Criteria for Periodic and Systematic Review of Regulations NRC Compilance S.
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 9
comply with it.
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6.
An estimate has been made of the new reporting There are no reporting requirements in the proposed rule.
l burdens or recordkeeping requirements necessary Additional burden on appilcants with respect to recordkeep-for compliance with the regulation.
ing will result from the requirement for a central file under the control of the applicant.
i 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 af ter Licensee and staff experience with the regulation will be i
its issuance has been developed, used to evaluate the regulation. This subpart will be reviewed in the second cycle of NRC's periodic and systematic review process (1986-1991).
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