ML20027D906
| ML20027D906 | |
| Person / Time | |
|---|---|
| Issue date: | 05/14/1982 |
| From: | Aggarwal S NRC |
| To: | Case E, Johnston W, Vollmer R Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20027A669 | List:
|
| References | |
| FOIA-82-426 NUDOCS 8211100378 | |
| Download: ML20027D906 (4) | |
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UNITED STATES
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g NUCLEAR REGULATORY COMMISSION
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WASHINGTON, D. C. 20555 o
l May 14,1982
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NOTE FOR:
E. Case NRR
'.j R. Vollmer, NRR W. Johnston, NRR E. Jordan, IE W. Olmstead, ELD FROM:
Satish K. Aggarwal t
SUBJECT:
SECTION 50.49 EQ RULE During the CRGR meeting on May 12, 1982, four issues-were raised. These issues are stated in the enclosure, with our proposed solutions and supporting reasons. Please review and provide your comments by May 17 (10:00 am).
'k,A-)'ph O Satish K. Aggarwal s
Enclosure:
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D. F. Ross
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Issue #1:
The scope of the rule is stated in terms of safety functions;
.j 1.e., the electric equipment has not been classified either
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" Class lE" or " Safety-related." Reading the scope, one 4
1 could construe that the instrumentation whose failure might 4j mislead the operator are included. This has not been an NRC position.
il Solution:
We agree with the coment.
1 The tenn " safety-related" should be utilized in the title and t
throughout the rule, as appropriate.
Paragraph (c) should be changed, as marked.
(Enclosure 1) 9 Reason:
The term " safety-related" is consistent with the Commission Memo and Order, and 00R Guidelines and NUREG-0588.
" Safety-related" has been used explicitly in regulations and applied by staff and industry in safety review process.
Issue #2:
Rule does not explicitly state that the scope covered by
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00R Guides (or NUREG-0588) is identical to the scope of the rule.
Solution:
We agree with the coment.
The explicit change is shown in Enclosure 2 (page 4 of the final rule).
Reason:
This has been the staff intent.
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l Issue #3:
The requirement for equipment located in the mild environment should be deleted from the rule.
The relief for the i
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extension of completion date for equipment in mild i
i environment should be addressed.
I Solution:
We agree with the connent.
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The rule will not cover the mild environment. The statement i
of considerations will be expanded to state as follows:
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"This rule does not cover the equipment located in a 1
mild environment. NRC licensing requirements have been provided in generic letter 82-09. The regulatory position on equipment located in a mild environment for all nuclear pcwer plants will be included in Regulatory Guide 1.89.
The cualification of safety-related electric equipment loc'ated in a mild environment must be demonstrated by June 30, 1983."
Reason:
We have maintained that the requirements for equipment in a mild environment are not " qualification requirements",
rather "QA requirements." Further these requirements are too prescrip,tive and, therefore, should be included in R.G. 1.89.
Issue #4:
The requirements for replacement parts should be explicitly included in the rule.
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Solution:
The rule should be modified as marked.
(See footnote 3, page 14 of the final rule - Enclosure 1)
Reason:
We agree with the coment.
Although the Commission Memo and Order states, "The Guidelines i
1 leave open the question of what standard will be applied to replacement parts in operating plants.
Unless there are 1
3 sound reasons to the contrary, the 1974 standard in I
NUREG-0588 will apply." We believe that the requalification
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will not yield any demonstrated significant safety benefit for the following reason: Upgrading a portion of the system on a fragmented basis does not significantly improve safety, since a chain is no stronger than its weakest link.
Further, such a requalification requirement would tend to discourage timely replacement of worn equipment.
Some members of the staff believe that the Conmission Memo and Order should be followed.
NOTE:
The statement of considerations should be changed in the area of ;old shutdown requirement to indicate qualification of equipment needed to achieve cold or hot shutdown will be required consistent with the licensing basis of the plant.
A marked-up (Enclosure 3) is enclosed.
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