ML20027D822
| ML20027D822 | |
| Person / Time | |
|---|---|
| Issue date: | 03/08/1982 |
| From: | Cameron F NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | Scott S NRC OFFICE OF ADMINISTRATION (ADM) |
| Shared Package | |
| ML20027A669 | List:
|
| References | |
| FOIA-82-426 NUDOCS 8211100156 | |
| Download: ML20027D822 (8) | |
Text
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pa rtyg UNITED STATES
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NUCLEAR REGULATORY COMMiss!ON 8
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WASHINGTON, D. C. 20555 3i
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MAR 081582 J
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MEMORANDUM FOR:
Stephen R. Scott, TIDC, ADM 1
FROM:
Francis X. Cameron, DRA, RES j
SUBJECT:
REQUEST FOR OMB CLEARANCE OF PROPOSED RECORDKEEPING REQUIREMENT - 10 CFR 50 PROPOSED REQUIREMENT FOR THE
-1 ENVIRONMENTAL QUALIFICATION OF ELECTRICAL EQUIPMENT l
As required by the' Paperwork Reduction Act of 1980 OMB clearance is re-
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quested for the information collection requirements in proposed rule 10 CFR 50 " Proposed Requirements for the Environmental Qualification of i-Electrical Equipment." The final OMB clearance package is attached.
The Executive Legal Director has no objections to the proposed rule, and I have reviewed the supporting statement in my capacity as Information Management Coordinator.
W L i % 1 f.-j W i Francis \\ X. Cameron 4
Regulatory Analysis Branch Division of Risk Analysis Office of Nuclear Regulatory Research
Enclosure:
OMB Clearance Package G
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8211100156 821014 PDR FOIA CURRAN 82-426 PDR
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b SUPPORTING STATEMENT FOR 10 CFR 50 550.49, " ENVIRONMENTAL QUALIFICATION 0F ELECTRIC EQUIPMENT FOR NUCLEAR POWER PLANTS" l
1.
Justification Nuclear power plant equipment must be able to perform the safety
. {
functions throughout its installed life. The proposed rule is designed to assure the NRC that the electric equipment will be able j
to perform its accident mitigation functions under the postulated environmental conditions.
To accomplish this objective, the proposed
-rule requires licensees to qualify the essential electric equipment.
Although testing is to be the primary method of qualification, 3
analysis in lieu of testing will be permitted if the testing of j
equipment is impractical because of limitation due to the state of the art.
A By its Memorandum and Order CLI-80-21, dated May 23,1980, the Commission directed that the D0R Guidelines for Evaluating Environmental Qualification of Class IE Electrical Equipment in Operating Reactors j
and NUREG-0588, " Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment," form the basis for the
- requirements licensees and applicants must meet for environmental qualification of electric equipment. This Memorandum and Order also included certain reporting and recordkeeping requirements which licensees of the operating nuclear power plants are required to comply with. The recordkeeping requirements in general terms are contained in Section XI and XVII of 10 CFR 50, Appendix B. The proposed rule will codify the Commission's current requirements for the qualification of electric equipment and explicitly state the reporting and recordkeeping requirements.
In addition to the proposed rule, a revised Regulatory Guide 1.89 is being issued to describe acceptable methods of implementing the rule.
The information collection requirements contained in the proposed rule and Regulatory Guide 1.89 consist of the following:
A.
50.49(d):
establishment of records listing all electric equipment covered by the rule, its performance characteristics, its electrical characteristics, and the environmental conditions in which it must operate B.
50.49(h):
submission of a report which identifies the electric equipment already qualified prior to the effective date of the rule and a schedule for testing or replacing the remaining electric equipment C.
50.49(i):
notification of any significant equipment qualification problem that nay require extension of the completion date for qualification beyond the second refueling outage after March 31, 1982 9
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,. l D.
50.49(j):
submission of an analysis to ensure that the plant can be safely operated pending completion of the environmental l
qualification of electric equipment si E.
50.49(1): maintenance of records of electric equipment qualified M
under the proposed regulations Q-Regulatory Guide 1.89 does not impose additional reporting and/or recordkeeping requirements beyond what is covered by the-proposed
- )'
rule. These records and reporting requirements are all necessary to ensure that electric equipment covered by the proposed rule are qualified to provide adequate assurance of public safety.
2.
Description a
The proposed rule applies to all operating nuclear power plants and l-the plants which will be licensed after the effective date of this rul e.
Qualification testing is perfomed on prototype equipment.
j,'
Analysis in lieu of testing is allowed if type testing is precluded j;
by the state of the art.
3.
Time Schedule The electric equipment covered by the proposed rule for the operating nuclear power plants must be qualified by the 'second refueling i
outage beyond March 1982.
i L
Information under provisions of section 50.49(d) is not required to f
be submitted to NRC.
Submission of schedule under section 50.49(h) is required on a one-time-only basis within 90 days after the effective date of the final rule.
Information under section 50.49(i) i.
shall be submitted only when a problem occurs.
The reports will be reviewed by the NRC staff within 15 days after receipt. Submission of analysis under section 50.49(j) is required on a one-time basis only upon publication of the final rule. These analyses will be reviewed by the NRC staff within 90 days after receipt. Recordkeeping requirements under section 50.49(1) must be completed no later than November 1985 for all operating nuclear power plants.
4.
Consultations Outside the Agency NRC staff participates in the development of national IEEE standards.
Since 1975, these IEEE standards require maintenance of qualification records of essential electric equipment.
+
6 9
5.
Estimate of Compliance Burden Compliance Burden For 72 Operating For 30 Nuc. Pwr. Plts.
Nuclear Power Plar.ts to be licensed in next 3yr Requirement (mh/ plant)
(mh/ plant)
To To To To Licensees Govt. Applicants Govt.
50.49(d)
Development of list of essential electric 320 40 160 Pt. of nor-equipment and its characteristics mal des.rev.
(one time only) 50.49(h)
Submission of schedule for testing and replacement (one time only) 160 8
NA NA 50.49(i)
Reporting of significant qualification 40 8
NA NA problem 50.49(j)
- Submission of safety analysis 320 160 NA NA
~
- Note: Only 18 operating nuclear power plants must resubmit this analysis. Satisfactory reports have been submitted for 54 operating nuclear power plants.
If this is accomplished prior to the effective date of the final rule for the 18 plants, this section will be deleted from the regulation.
50.49(1)
Maintenance of qualification file 10000 320 10000 Pt. of nor-mal des.rev Sensitive Questions 6.
None 7.
Estimates of Cost to Federal Government Estimated cost per plant is incidded in paragraph 5.
The total cost to the government is estimated to be $2,400.000.00.
[(40 + 8 + 8 + 320) mh's x 72 plants 4
x $80/mh + 160 mh's x 18 plants x $80/mh = $2,396,160.00]
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' 2875 Edtrn! Register / WL 47. Nc.13 / Wednesday Januar/ 20. 198:1 / Pr*: posed Rules
?'5 combination of perscna which--
cedicine, without edequato evidence of Regulatory Reserrch.E!cenical -
i advocates or practices the commission rehabilitation or reformation.
Eogineenng Bronch. U.S.Nedear
)
of ac:s of force or violence to prevent (I) Has engssed in any unusual Regulatery Comcdssion. Washington.
.4 D.C.20555. Telephone (301) 4G-346. -
others fract exercising their rights under conduct oris subject to any 1
4 the Constitution or t.aws of the United.
cat.u= stances which tend to show that semxrAamanuanosc Nudear
~f States or any State or subdivision-the individualis not hcnest. reliable. or PO**f P 888 89.p=enti=ponant m I
d thereof by unlawn:1 means.
trustworthy, and there is no adequate safety must he acle m peric,6e
?
(d) Publicly or privately advocates or evidence of rehabintation or safety functio =s throu;sout its installed participates in the activities of a group refor=stiam or which fr_~ishes resson IHe.Es nquire=ent ts e= bodied in or orgschation. which has as its goal.
to be!! ave that Be Individual may be General Cesign Criten,a 1. 2. 4. and *3 of revolution by forts or violence to subject to coercion. InUuence, or Appendix A.-CeneralDesign Criteria over6:cw the Covernment of the United pressure which may cause the for Nuclear Power Plants. to 10 CE 2
States or the alterstics of the form of ind!vidual to act contrary to the best Part 50, -Domesuctcens,":g d u
Covernment of the United States by Interests of the nation! security.Such Produen,en and Utilbation Facilities,,;in unconsetutioni!:::ans with the conduct or circu= stances include but Giterian III. -Design Conto 1.' and knowledge thatit will further those are not '.1=f ted to sexual activity.
Cdtenon Mest Control.,d s
goals.
deconstrated Enancial hresponsibiuty APP **dI* 3 ~Q"*IIIY ^88"T*888 or notonously disgraceful conduct.
Cnteda for Nucles: Power Mants and (e) Parent (s), brother (s). sistar(s).
spouse. or olispring residing In a nation trao si.artr dts.ausw FuelReprocessing Mants, m to Cm s whose interests may be Inimical to the saua caos u eus Part 50: and in to Cs 50.53a(h) which.
'I
- Intensts of the United States, orin Incorporates by aference u n I
satellites or occupied areas thereof(to.
1971.5 *" Criteria for Protection Systems be evaluated in the I!aht of the risk t: tat NUCf. EAR REGUI ATORY
. "j pressure appued through such re!atives CCMMISS!CN for Nuclear Power Generating Stations.,
. This requirement is applicable to could force the iodIvidual to act equipmentlocated !=sida as well as 10 CFR Part 50 cor.trary to national sicurity).
outside the contaic=ent.
(f) Has deliberately misrepresented.
EnvirentnentalCuaufication of Sectric Tae E has used a vadety of e
falsified or omitted signi5 cant Equipment for Nuclear Pcwer P! ants medads m erisun est dese general e infermation h :m a Persor=el Securit'y
' Questiennaire, a personnel
--Actucv: Nuclear Regulatory requirements are =et for elecnic qualificatiens statement. cr a personnel-I 89"'P**** I*P?rtant m saretyEor 2 t
1971. qualiScation was based on the fact AcTicec Proposed rule..
security interview.
that the electric components wsreof In,$r.at. faEd to protect c'.assified p
suuuAay:ne Nuclear Regulatory high Industdal quality. For nuclear
.i ten. or safeguard special Commissionis proposing to amend its plants licensed to' operate after1971..
nuc. ear = ate,nah or has wiHfuHT re5ulations appucable to nuclear-power qualifica tion was judged on the basis of no!ated cHnre;srded se==rity ct "
plants to clarify and strengthen the ww 351g71. For plants whose Safety safeguards regulations to a desme enteria for envtremnental quauBcation Evaluation Reports wen issued since which would endanger the c== mon
,g,1,cee,q.ziped Specine W Im 6 6eissemed de4ense and security or has Intentios2HY quahEestion =ethods c=rnstly Regulatory Guide 1.as. -Quali!!ca:fon of disclosed classiSed informatica to a centained in national standards.
Cass IE Equipc ent for f.ight. Water.
person unauthorized to receive such regulatory guides, and certain NRC Cooled Nuclear Power P! ants " which publications for equipment qnsliRcation endorses F"351974.*"u rr -
5 informatim (h) Has any u,,, mess or mental have been given difierent interpretations Standard for Qualifying Cass15 l-cond! tion of a nature which la the and have not had the legalIcree of an Equipment for Nuclear Power opuuan of ccmpetent medical authority agency regulation.The proposed rule Generating Stanons." subject to causes, or may czose. sigm rea nt defect would cod!Iy there entw_.. ental supplementary provisions.
In the lodgment or reliability of the qualiBeation methods and claxify the Currently, the Commission has -
Commission's requirements in this area.
underway a program to resvaluate the e m e by a a
t.
c A n s:Com=ent period expires March qualification of etectric equipment (i) Has ref= sed to testify before a
. 22.1982. Co=ments received after that i= portant to safety in all operating Coegressional Committee. Federal or date wiH be considered ifit Is practical n=c! ear power plants. As a part of this,,
Sta:e court. or Federal administra tive to do so. but assurance of cocsiderstion program. more des =itive criteria for body, regardhis charges relevant to cannot be given except as to comments, envireemental qualification of electric eIIgibility fo CCE access authorination.
received on or before this data.
equipc:ent have been developed by the (1)Is a oser of alcohol habitually to aooatsses Written comments and NRC. A docu=ent entitled "Cuidelines excess, or has been such without for Evaluating Environmental adequate evidence of rehabiutation or suggestions may be crailed to the Quali!! cation of Cass 1E Electrical reformation.
. Secretary of the Cocunis.sion. Attention:
Equirment in Operatang Reactors (COR (k) Has used. trafficked (n. sold.
Docieting and Service Branch. U.S.
Cuidelines) was issued in hovember transferred or possessed a drug or other Nuclear Regulatory Commission.
1979. In addittor:. the NRC has issued Washiegten. D.C. 20533. or hand.
NUREC-c38a. In:erim Staff Posittert on substacce IIsted in the schedule of delivered to the Commission's Public Cootrolled Substacces established Document Room at 1717 H Street NW, pursuant to Secticrt 2C2 of the ControUed Washington. D.C. hetween the hours of
.tuorp,nuo,, by rd.,- err:wi ny ihe Substances Act of1970(such as am;heta r hs. barbiturates. narcotics.
8 30 am. and 4:45 p.m. on nor= al work c;mi e.t vi. otac. et rederas sepa.r es ian=rr i
i etc.) except as presc:ibed or days.
2g adrainistered by a physic!an licensed to FCR FURTNER tNFORM AT10N CONTAcTT Cecrical and C renasca Zas.taers. he. sa3 last dispense drugs in the practice of
. Satish K. Aggarwal.Cilice of Nuclear 4r:n snei.New yes. N.Y. u:mr.
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' I Federni Rep. ster / Vcl 47. Nr.13 / W;dntsday. January :c.198: / Prepostd Rulis 2377 Environmental QualiHestion of Safety-principal means of qualincation and (b) qualified.These !!sts and the schedule.
Related Electdcal Equipment." which anaylsis and operating experienes In fer c:mpletion of equip =ent.
contains two sets of crtteria: the fir:t for lieu of testing.The proposed rule would quali5 cation would have to be plants originally reviewed in accordance require that the qualincatica progrant - submitted written 90 days after the 6
with A 33-13Z1 and the second for include synergistic effects. aging, effec:ive date of this rule. However. this plants reviewedin accordance with margins, radiation. and environmental ti== period wiH be adjusted during the 1
m :20-1974.
conditions. Also, a record of final rule r=aking process to allow By !!s Me=orandum and Order CU-qualiacatien must be maintained.-
ressenable ti=e forlicensees to t
co-21 dated May 23.1980. the Regulatory Guide 1.39 is being revised to evaluate NRC"a safety reviews that are Coerission directed the staff tn descibe methods acceptable to the NRC currently underway.
" proceed with a rulemaking on for meeting the provisions of this ne proposed rule will codify the -
environmental quali5 cation of safety-proposed rule and to include a IIst of Coc: mission's current recuirements for -
grade equipment and to address the typical equipment covered by it: a draft the environ = ental quali5' cation of question of beckfit.no Commission of the proposed revision is being electric equipment. Upon pub!ication of also dincted that the DOR Cuidelines published for public cornment a Enal rule. the DOR guidelines and and NUREC4538 form the basis for the concurrently with the propsed rule.
NUREC c338 will be withdrawn.
requ!ncents licensees and applicants Also included in the proposed rule is a. ne generst requincents for seismic must meet until the rulemaking has been require =ent which is consistent with and dpsamic qualI5 cation for electric completed.This proposed rule is Commission Memorandum and Crder.
equip =ent are contained in the General generally based on the requirements of,
CU-60-zt for submissica of an analysis Design Criteria. Pending development of
. the Division of Operati=g Reactors by licensees to ensure t' tt the plant can specEc requirements in this area, the -
(DCR) Guidelines and NUREC-0588. -
be safely ope stad pend: :g completion general requirements win continue to ne Coc=ission's Memorandum and of the environmental qualiHeation of apply. NRC is considering expansion ef Order CU-60-21 directed that the electric equipment.The Co= mission the scope of this proposed rule to envird := ental qualiEcatien of electric.
expects that. for each of the curantly Indude additienal elec ric equiprnent-equipczent in operating nudear power operating power plants. this analysts i=portant to safety. This matter wtl! be plants be completed by June 30.1582.
and its evaluation by the NRC staff will the subject of a futun relem.alicg.
However.on Septa =ber 23.158L the be completed wellin advance of the
- .**.N#*"*"#
Com=ission considend the petition effective date of this rule.If the (SECY-alass) to extend this deadHae.
licensees of operatic power plants fail y
The ;roposed rule covers the same -
to provide these analyses in a timely (see:.od re'ueUng outage afte.r March 3L electric equipment as CU-80-21 and marmer. the CommNsion expects the iss:) for quaHEca&n is =uca too Imple=ents SECY-31-t38 by NRC staff to take the appropriate steps nlaxed. pen 6 facdadcensees,
incorporating the extension dates to require that the information be and the NRC have been aware cf the recorn= ended by the Chairman In his provided and to enforcs compliance pr ble=s la this, ens since 1973.The with this require =ent.This requirement memo =ndum dated September :0. isat' has been Included in this proposed rule proposed dead!=e extends as c:uch as Inc!uded!n the proposed rule is a
"=
requirement that each holder of or each to provide a regu! story basis for Q*
da.
Y o
applicantfor a !hense to operate a
-- e=forcement.
Industrisicom= conduded 6st nes@
ncdaar power plant identify and qualify-NRC will generally not accept an electica equipment couMbe quaHHed. Gl wen de con generous the electne equip =ent needed to analysis in lieu of testing. Experience has shown that qualincation of deadhne. he also believes that the rule coreplete ons path of achieving and c:sintaining a cc!d shutdown condition.
ebalpment without test data may not be
- should have contained requirements quate to demonstrate functional The Cocimission speci5cally nquests a
operabiHty during design basis event seis=ic and dyna =ic qualineation.
com=ent on this proposed add!t:enal cond!: ions. Analysis may be acceptable While the general design enteria co,ntain requirement,
' ' ~'
ne scope of the prEpose' rul's does if testing of the equip =entis i= practical nquire=ents in this ans. clari5 cation d
not bduda all elec:ric equipment becausa of size. or limitation due to the now would ensure that equipment to be
- important to safety inits various
' state of the art.The proposed rule takes replaced in the nest te=s will not have gradations ofimpore Itincludes into consideration the prior qualification to be npped out-in a few years because that portion of equipment important to * ' history of the operating power plants.
It was not properly seismically qualiSed.
safety commonly referred to as "Cass
- Fcr example the proposed rule Commissioner Cmasky has agreed 1E' equipcent in tru. national recogn'zes that for those plants which with these views.
standards and some additfonal non' ars not co=mitted to eitherr m 3:3 Paperwork Reduction Act Cass II equipment and systems whose 1971 or IEEE 3:3-1974 for equipment failure under extrece envimnn: ental
, quallHeation and have been tested only The proposed rule c: stains ennd!tions could pravent the for bigh temperature pressurs and recordkeeping nquire=ents that are satisfactory accomplishment of safety '
steam, some equipment may not need to subject to review by the OfHen of functions by acddect-c:itigating
- be tested again to include other service Managernent and Budget (OMS). As equ!;rnent.
conditions such as radiation and required by Pub.1.SS-51L this proposed Included in the proposed rule are chernical sprays.ne qual!5 cation of rOs will be submitted to CMB for specific technical requin=ents equipment for these service c=nditions clearance of the recordkeeping
- perWng to (a) qcallHeation may be established by analysis, requitece=ta, parameters. (b) queufication me' hods, ne proposed rule would reqdre that Regulatray Mexibitty Statement and (c) documentation. Quallficat:en each holder of an operating IIcense parameters include temperature.
provide a !!st of electne equipc:ent In accordance with de Regulatory pnssure. hurnidity. radiation. chernicals. pnviously qualified based on testing or Flexibility Act of 1980. 5 U.S.C. So5(b).
and submergence. Qualification analysis or a combination thereof. and the Com=Ission hereby certines that c ethods inefude (a) testing as the a list of equipment that has not been this rule. if promu!;sted. will not have a 6
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- 373 Fedtral Re;;! stir / Vol. 47. Ns.13 / Wednesd:y. January 20.198 / Prcpostd Rules
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signiReant economicimpact on a equipment and systems that are ~ results fara a single faiIcre in the spray
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This prepcsedn !e affects the method of. shutdown, containment isolation.
. systern must be assu=ed.
J substantial number of small entities.
essential to e:=enency reactor (4) Radiation. The radiation i
quali!! cation of electric equipment by nactor core cooling, and containment - envimnment must be based on the type
.s 1
utilities. Utilit:es do not fall withirt the and reactor heat removal or that are of radiation and the dese and dcse rate densition of a smaH business found in otherwise essential in preventing of the radiation envimament expec:ed i
4 3
Section 3 of the Smau Bestness Act.15 sig:sincant alense of radioactive during cor=al operation over the..
i i
U.S.C 632.In addition.utitities are material to the environ =ent bduded is Installed life of the equipcent plus the required by Commission's 11emorandunr equipment (1) thst performs the above radiation enviror. ment associated with t
and Crder CU40-22. dated.May 23.
Emetions automatically. (2) that is used
- he most savere design basis event 1
1980, to meet the requinments by the operator to perfor: t these' N.
during or foHowing which the equipment d
contained in the DOR"CuldeIInes for functions =anually, and (3) whose is required to remain funcLocal.
1
- 3 Evaloating Environmental Qualineation failure can present the satisfactory including the radiation rese.iting kom I
~
of Class IE Eectd: Equipment in ac:omplishment of one ormore of the recirculating GrJds for equipment Opersti=g Reactors ** (November 1979) above safety Ma* A!so included is located near the recrculating IInes.
and NUREC4538. "htazim Staff equipment needed to complete one path (S) Aging. Equipment qualified by test i
shutdown condih,maintammg a cold
- precodidoned by naturalor at65dal of achievu:g and must, where practicable, be Position on E:vironmental Quali5 cation
_of Safety.Related E!ectrical Equipment.".-
(d)na applicant orlicensee shall.
(acc.etersted) aging to its instaDed end-i on.
which form the basis of this proposed
. ' rule. Cocsequently, this rule enne.
. - prepare a !!st of an electric equipment g,;6 edihdemhical existing nquirements andimposes no,
covered by this section and maintain it equipment must be operated to simulate i
new costs or obEgations on utilities.... in an auditable form.nis list of. clude the mechanical wear and electrical I
Pursuant to the Atomic Energy Act of,.
s equipment must as a ~8 mum,in d W ahnm d W h 1954 as amended,the EnerEF (1) The perfocmco chara,cteristics installed life. Where preconditioning to '
Recrgani:ation Act ofi974 as amended.,.and structuralintegrity.
ents d Me iH d &
and section 533 of titie 5 of the United under conditions ensting
.ng normal th' be States Code. notice is henby given that. and abnormaloperation and during Is"$P'8d'bl Fment gg adoption of the following "-=~'m-d in.. design basis events and aftervards and * {,
b I d tifebess fhs of th doggwhich.
10 CFR Part 50 is contemplated..
the e d o q
H PART 50-DOMESTIC t.! CENSING Ofr (2)Th range of voltage,hequency.
ongoing quaHSesha dprototype
.. Ioad, and other elecincal characte=stics equip =ent nat:raDy aged in plant I
PRODUCT!CN AND UTII!ZA110N for which the perior-'=nen spe<=fied in servsce shows. by artificial ag ng and FActLITIES type testing, that the !tein has adehnal i
1.& authority citation for10 CFR. ', ac:ordance with parag aph (d)(1) of this quali.Eed life.
J secdon can be e.sured.
(6) Submergenes(if subject tobeing Part 50 reads as.fonows:
.(3) N environmental conditions.
j i
l Antbeity: Sees. tos.104. tes. ts=. 2ss.tse.
Includi=g temperasure. pressure.
submersed).
. humidity: radia tien. chemicals, and (7)Synergisticefects.The I
sa Stat. saa arr. 94a. ssa, ss4 ass. ssa, as d [ U S C.2:33.2134.
submerge ce, and the predicted prected!Sni:3 and testing of us.a.t as[u uSCs&st. sac.sa4al.u.iese. variations of these environmental
. equipment must c=caider k: sown.
3 otherwise noud. Section says eIse issued conditions with time at thelocatzon sy=ergistic effects wcen these effects under Sec.t=.se Stat.sse (c Usc us:1 where the equipment must perform as
- are known to have a sig=iScant efect on Sec ons scand.st also issued under Sec.
speciSed in accordance with paragraphs equipment performance, (8) Afargins.Manzas mustbe applied ta4. se Stat.ssa, as amended,taz UAC (d)(1) and(2) of this section.
to account for production variations and
=34). v-m-mano* issued unde (e) Es electrical equipment Sec.2se. Sa Stat.953:(42 USC:=8l For qualification prograra must include the inaccuracias in test. tion to marginsi.nstrs Purposes of Sec.=2.64 Star. ssa, as oHowingt i
margms are in addi
.m.n,s.d;[42 USC ---31. I sa.5.Wil !ssiasd.
(1) T88Perecure andpressure.De applied during the derivation of the Y
under Sec.161L ss St r. 94s:(42 USC time-dependent tamperature and environmental conditions.
=at(11). Il sara,so.rt and says tssued cade, Sec.Ista. es Stat ssa as amended:(42 USC., pres,sare at the location of the (f) Each item of electric equipment
=ct(o)) and the t.sw referred to in equipment must be established for the must be qualified by one of the most limiting of the applicable I-
- A new I 30.49 is added to rend as postulated accidents and must be used - foHowing methods Appendican.
(1) Testing an identicalitem of*
(,
fogo,,
as the basis for the envuonmental quahfication of electric equipment.
I so.as Eowonmental quaancation et (2) Humid 7ty.me dependent (2) Testing a sm.nlaritem of equipczent efectrie egapment for nuclear power variations of relative humidity during with,a supporting analysis to show that -
normal operation and design basis the equipment to be quaIISed is pianta.
(a) Requirements for seismic and events must be considered.
acceptable.
dynamic qualI5catica of electric (3) C'remicalcgeets, ne composition (3) Experience with Identical or
('
equipment are notincluded in this of chemical used must be atleast as sh=ilar equip =ent under si=ilar severe as that resulting Som the most cond!tiens with a suppor*Jng analysis to section.
I!=iting mode of plant operstion (e.g.,
show that the equip =ent to be quaH5ed (b) Each holder of or each applicant for a IIcense to operate a nuclear power cantainment spray, emergency core is acceptable.
plant shall establish a progrzm for cooling, or recirculation from (4) Analysis inIIeu of testiss In the qualifying the elec ric equipment as containment sump).If the composition foHowing cases a
delinedinparagraph(c)of this section.
of the chemical spray can be a:Tected by (i} !f type testing is precluded by the (c) E!ect:ic equipment and systems
' equipment mal!=nctions the cost physical size of the equipment or by the l
, covered by this secha include elect:ic severe che=ical spray environment that state of the art.
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4 Tsdiral Register / Vol. 47. Ne.13 / Wednesdsy. Janutrf 20. 1982 / P.oposed Rules
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(ii) By analysis in combination with operating license issued prior to the to CFR Part 50
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. partial type test data which adequately effective date of this amendment shall supports the analytical assumptiens and perform an analysis to ensure that the Ernergency Planning and j
conc!usions.if the equipment purchase plant can be safely operated pending
, Preparedness; Exercises
- l order was executed prior to Wy 23.
completion of the environmental Actucv: Nuclear Regulatory
.N l 1980.
qualification.ne detailed analysis for.
Coc -dssion.
(g) If an Item el ef ectric equip =ent is esch equ!pment type with appropriate Acm ProppsedIule: extension of j
to be qualif!ed by test-justification must be submitted to comment penod.
g (1) ne acceptance citeria must b6. Director of Nuclear Reaction Regulation 3
established prior to testing.
by (insert the effective date of the swuw.h Nuc6ar Regulatmy
, l (2)ne tests must be designed and amend =ent) and must include. where Commission is extending the puosic g
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conducted to demonstrate that the appmpriate. consideradon oh comment period regarding clanneation g.8 equipment can perform its required (1) Accomplishing the safety funedon of the exer:ise requinments under the function as spec!5ed in accordance with by some designated attemative-Commission's Emergency Planning acd j
paragraph (d)(1) of this section for au equipment thathas been adequately Preparedness regulations. Notice of this conditions as speci5ed in ac:ordance quatined and satisfies the single-railure rulemaking was published in the Federal j
with paragraphs (d) (2) and (3) of this criterion if the pnncipal equipment has E gister on December 13.1981(4s FR 3
secdon. ne test prose (e.g. pressure, not been* demonstrated to be ful!Y su:4) with a comment period closing temperature: radiation vs. tf=e) must date of January 14.1982.h comment l-5 lac!ude margins as set forth in
.qualised.
paragraph (eJ(8) of this section.
- (2) ne validity of partial test data in period is being extended in response to (3) ne test pro 8Ie must be either (!) e support of the odginal qualification, requests.
single profile that envelops the (3) Limited use of shtrative carts: Comments must be received
- L environmental conditions resulting from controls over equipment that has not before January 2s.1982. Comments any desis:r basis event during any = ode been demonstrated to be fully quali5ed.
received after this date will be I
(4) Completion of the safety function considered if it is practical to do so' but I
. of plant operatioh (e.g.a profile tha:
stulated spect:u:n of main staar-fme-.i-environment and the subsequent failuregiven except for com=ents received
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envelops the c=nditions prodced by the prior to exposure to the ensuing accident anurance of consideration cannot be reak (MSL3) and loss-of-coolant before this date.,
ac=idents(LOCA)J or(ii) separate
- .:. of the equipment does not degrade any
~~ ~ safety funcdon or =Islead ta,e operator.
accasssss: Comments on the proposed i
prof 1Ies for each type of event (e.g '
l (5) No signf5 cant degradation of any amend =ents should be sent to the
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separate pron!es for the MSL3 ac=idents. safety function or misleading of the Secretary of the Co= mission. U.S.,
t and for LCCAs)..
(4 ne same piece of equiemeitt must ' operator as a result of failure of Nuclear Regulatory Commissior l
be u) sed through out the complete test.
equipment under the ac::ident Washington.D.C,2c555. Attentiom j
o Docketing and Service Branch.
g ence under any given profile.
- environ =ent..
) Each ho!dar of an oper3tinglicense. (k) nn applicant for an operating Comments =ay also beband-delivered t
to Roem 1121.1717 H Street.NW
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license that la granted on or after the issued pnor to (*u. sert the effecdve date ' effective date of this amend =ent, but Washington, D.C benveen 8:15 a.m. and
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of this amendment) must. by (insert a date 90 days ah!The effective date of '. prior to November 30.1985 must 5:15 p.m. Copies of comments rece!ved '
this ame=dment). !dentify the electric.
' perform an analysis to ensure that the. may be examined and copied at the Commission's Public Document Room at
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plant can be safely operated pending equipment already qualified to the provisions of this rule and submit a! -?!'
comptedon of the environmentag 1717 H Street. NW., Washington. D.C.
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.qua!!5 cation in accordance with ron matusa inconnaT:oM CONTaCTt h
, schedule for the teseng or replacement of the remaining elecmc eqmpment. -
Michaellamgochian.Hu=an Factors '
nis schedule =mst establish a goal of., paragraph (!) of this section except that this analysis must be submitted to the Branch. Of5ce of Nuclear Regulatory
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final environmental quaEcadon by the. Director of Nuclear Reactor Regulation Research. U.S. Nuclear Regulatory a
end of the second refueling outage after.. for consideration prior to the granting of Commission. Washington. D.C.20535 r
March.31.1982. W Director of Nuclear 3 an operaung license.
(telephone: 301-443-3942).
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(I) A record of the qualification must Dated at wahinstoa. D.C. this 23th day ef
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aun that each Hern pects,mn e ma n a ne a a central Ble to pe January. tsas, g
no later than November 30,1985, for For the Nuclear.Resulatory Canunission.
(
specific pieces of equipment if such. w mequipment covered,by this section (1) issamu.I J. cha, t
)
requests are f!!ed on a timely basis and quali5ed forits appIIcation and (2) g,c,.,,,,.7,f e, cm,.niuse,.
demonstrate good cause for the-a muts us speciSed perfonnance
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estension.such as inwsentlesd requirements whenit is subjected to the.
time. test compIications. and installation conditions predicted to be present when problems. In exceptional cases, the
' it must perfecn its safety function up to Commission itself may consider and the end ofits qualified life.
.9 grant extensions beyond November 30.
1965 for c mpletion of environmental,
Dated at Washt gton. D.C. this isth day of p
g qua M eadon.
e,.
january.19e2.
Preparedness for procuet!on and (i) Each IIcensee shall' notify the rar the Nuc!.ar Regulatory comminion. -
Utin=ation Facmties
,.o Commission of any signi5 cant -
equipment qualification problem that. Samue W hn.
Acancy:Nuc!est Regulatory may requfre extension of the coreptetion 3'cretary ofde Co.~unission. -
Com:nission.
Irs o m-mr eu.4= ms e acT:Ctc Preposed rule: extension of date within 30 days ofits discovery.
(l) For the centinued operation of a sumacccavn ws em.ent pedod.
4 nuc! ear;! ant. each holder of an 1
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WAR 1B Igg 2 SKAggarwal DFSullivan LCShao GAArlotto AEiss HDIORAliDUM FOR: William J. DircLs Executive Director for Operations bec: PDR FROM:
Satish K. Aggarwal Electrical Engineering Branch Division of Engineering Technology Office of Nuclear Regulatory Research.
SU3 JECT:
PROPOSED RiR.E. " ENVIRONMENTAL QUALIFICATION OF ELECTRIC EQUIPPENT FOR NUCLEAR POWER PLANTS" - C0HMENT PERIOD I have just received a copy of a letter, dated March 15, 1982, addressed to Secretary Chilk from Mr. Nicholas S. Reynolds of the law fire of Debevoise & Liberman, on the above subject.
The letter states, in part, "We were assured by the Staff that if our co::nents are hand delivered to the Comission by March 25, 1982 (as l
opposed to being mailed on Harch 22, 1982), they will receive full and j
cceplete consideration by the Staff and Comission."
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This is an incorrect statement. I did not_ assure him that their connents will receive full and cocplete censideration by the staff if rc<eived i
after March 22, 1982. Mr. M. Phillips of Cebevoise S Liberman contacted me by telephone and asked if the staff would consider their cocaents on the proposed rule if they were hand delivered to the Comission by March 25, 1982.
(Coment period expires on March 22,1982.)
I infomed him that only the Coenission can grant an extension of the comment period and referred him to that portion of the Federal Register notice which states,
" Comment period expires March 22, 1982. Conments received after that date will be considered if it is practical to do so, but assurance of g
consideration cannot be given exc'ept as to coaments received on or l
before this date."
I also expressed the opinion that, in all probability.
the comments would be considered if hand delivered by March 25.
I am providing this infomation to you for the nicord and also as back-ground material for any reply you may wish to make to the law firm of Debevoise & Liberman, Original Signed By:
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Satish K. Aggarwal N
EEB/DET/PIS
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R. B. Minogue H. R. Denton l'
R. C. DeToung
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Mr. SamueJ
.7. Chilk Secretary
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Washington, DC 20555 g
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Consideration of Corr.ents on the Proposed Rule Regardinc Environmental Quali fication of Electric F.cuipment.
47 Fed. Reg. 2S76 (January _20,
_ 1982)
Dear Mr. Chilk:
Sy letter tc Chairman Palladino of February 11, 1952, we requested that the comment period for the captioned rulemaking be extended from March 22, 1982 to !\\pril 21, 1982.
We believe that gooc e.nd sufficient reasons vero advanced in that let.ter to support the extension.
How-ever, we were informed today that our recuest has been denied.
We assume similar requests from the Atomic Industrial Forum, Commonwealth Edison Company, Duke Power Company, Texas Utilities Genera ting Company, Northeast Utilities, Philadelphia Electric Company, and.likely others also were denied.
Portunately, we did not assume that our recuest would be granted, and therefore, pressec forward vich all diligence to complete our comments on this complex issue by March 22.
He are hopeful that we can do so.
- However, in order to protect against unforeseen contingencies that might delay the filing of comments a few days, we contacted the Staff to assure that some leeway in schedule would be afforded.
We were assured by the Staff that if our comments are hand delivered to tne Conctission by March 25, 1982 (as opposed to being mailed on March 22, 1982), they will receive full and complete consideration by the Staff and Commission.
We are preparing our comments on the assuinption that this represents a formal coomitment of the Staf f.
We are rp o
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Mr. Samuel J.
Chilk March 15, 1982 Page 2 serving a copy of this letter on the Executive Director
-for Operations with the request that we be notified
,isnediately if our assumption is incorrect.
Thank you for your consideratiqn this matter.
Sincere,,
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db Nichol-s' $(. Reynolds i
NSR/dfn j, h cc:
Chairman Palladino commissioner Gilinsky
-t_omm2.ss1oner Anearne e
Commissioner Roberts William J. Dircks HAND DELIVERY G
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Dircks X}
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Re NUCLEAR REGULATORY COMMISSION
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March 15,1982 CY:ROSS OFFICE OF THE GILLESPIE-SECRETARY ARLOTT0/SHA0 D. SULLIVAN S.
AnnADWAI_
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Nicholas S. Reynolds, Esq.
Debevoise.& Liberman 1200 Seventeenth Street, N.W.
Washington, D.C.
20036
Dear Mr. Reynolds:
This is in response to your request that the Comission (1) extend by 30 days the comment period for the proposed rule on the environmental qualification of electrical equipment, and (2) treat extension of the current deadline for compliance with interim requirements for environmental qualification as a matter separate from the rulemaking proceeding and extend such deadline.
For the reasons discussed below, your requests are declined.
First, regarding the commenf. period on the proposed rule, draft Regulatory Guide 1.89, " Environmental Qualification of Electric Equipment for Nuclear Power Plants" was issued on February 18, 1982. 47 Fed. Reg. 7782. (February 22,1982). This will provide your clients one month to comment on the relation between the draft Regulatory Guide and the proposed rule.
As you know, the draft Regulatory Guide is not part of the proposed rule and your clients will have a 60 day period in which to provide detailed technical coments on that Regulatory Guide.
Moreover, an earlier but basically similar version of the draft Regulatory Guide has been available in the NRC's Public Document Room since about November 6,1981.
Under these circumstances, the Comission believes that there is no need to extend the comment period for the '.
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proposed rule.
Second, as to an extension of ~the deadline for complying with the interim requirements, the Comission believes that that request is premature.
It is not yet clear that the rulemaking proceeding cannot be completed by June 30, 1982.
If at some later date it becomes clear that the final rule will be delayed beyond June 30, 1982, the Comission at that time will consider what actions are necessary and you may renew
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your request.
However, before any extension of time can be permitted, the Commission must have a factual basis for finding that continued
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operation in the interim is consistent with adequate protection of the public health and safety.
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i;icholas S. Reynolds, Esq.
2 Chairman Palladino and Commissioner Roberts would have extended the comment period on the proposed rule.
Sincerely, 1
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i Samuel Chilk Se#cretary of the.Comission I
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