Text

Requests Approval for Publication of Notice of Proposed Rulemaking, Environ Qualification of Electrical Equipment in Nuclear Power Plants, in Fr
	ML20033A900
Person / Time
Issue date:	11/04/1981
From:	Dircks W; NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:	;
Shared Package
ML19252A886	List: ML19252A885; ML20033A898; ML20033A900; ML20033A901; ML20033A902;
References
	REF-10CFR9.7, TASK-RICM, TASK-SE SECY-81-603A, NUDOCS 8111300127
	Download: ML20033A900 (69)
	v • d • e

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l.,(h f9 November 4,1981 p

S ECY-81 -603 A For:

The Co s (Commission Meeting)

From:

William J. Dircks Executive Director for Operations

Subject:

PROPCSED 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 in response to the Commission's Memorandum and Order CLI-80-21 dated May 23, 1980, relating to the environ-mental qualification of electric equipment was forwarded to the Commission in SECY-81-603 on October 20, 1981 (referred to as Version 1). This paper recommends (a) strengthening criteria for environmental qualification of electric equipment and (b) deferral of the seismic and dynamic issues pending development of a value/

impact statement.

Version 2 of the proposed rule, Enclosure A, has been undertaken in response to Commissioner Bradford's memorandum dated October 15, 1981. Version 2 differs from Version 1 only in paragraph (g) of Enclosure A, Notice of Proposed Rulemaking, in which completion date of equipment quelification is effective July 1,1983 (as opposed to keying completion date to plant refueling outage).

With respect to Comissioner Ahearne's comments in his memorandum dated October 8, 1981, that seismic qualification must be addressed in this proposed rule, the staff believes that the complete value/

impact information (safety benefits and costs) is not available at this time.

Thus, we do not believe that the requirement for seismic and dynan.ic qualification shocid be included in this pro-posed rule.

If the Commission should decide otherwise, the staff woul.d modify the proposed rule as shown in Enclosure B (Version 3) or Enclosure C (Version 4), as appropriate.

In Version 3, the seismic and dynamic qualification requirement will apply to nuclear power plants currently in the operating license review process and all future nuclear power plants.

In

Contact:

Sa K. Agg rwal, RES SECY NOTE:

This paper supplements 46 SECY-81-603A.

i 0111300127 811113 PDR 10CFR PT9.7 PDR

e Tha Commissioners 2

Version 4, the seismic and dynamic qualification requirement will apply to all nuclear power plants (all cperating as well as future plants).

The staff will be prepared to discuss advantages and disadvantages of Version 3 and Version 4 of the proposed rule at the forthcoming Commission meeting on November 10, 1981.

/

Idk illia Dircks Executive Director for Operations

Enclosures:

A - Version 2 - Notice of Proposed Rulemaking B - Version 3 - Notice of Proposed Rulemaking C - Version 4 - Notice of Proposed Rulemaking DISTRIBUTION Commissioners Commission Staff Offices Exec Dir for Operations Exec Legal Director ACRS ASLBP ASLAP Secretariat i

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[7590-01]

NUCLEAR REGULATORY 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 proposing 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 havt been given different interpretations and 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:

Docketing 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 l

Version 2

[7590-01]

i Washington, D.C., between the hours of 8:30 a.m. and 4:45 p.m. on normal work days.

FOR FURTHER INFORMATION CONTACT:

Satish K. Aggarwal, Office of Nuclear Regulatory Research, Electrical Engineering 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 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 Criterion XI,

" Test Control," of Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," to 10 CFR Part 50; and in 10 CFR 50.55a(h), which incorporates 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 containment.

The NRC has used a variety of methods to ensure that these general requirements are met for electric equipment important to safety.

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 1971, qualification was 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

' 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 Engineers, Inc., 345 East 47th Street, New York, N.Y. 10017.

2 Enclosure A Version 2

[7590-01] '

Equipment for Light-Water-Cooled Nuclear Power Plants," which endorses IEEE 323-1974,2 "IEEE Standard for Qualifying Class 1E Equipment for Nuclear Power Generating Stations," subject to supplementary provisions.

Currently, the Commission has underway 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 j

by the NRC.

A document entitled " Guidelines for Evaluating Environmental Qualification of Class 1E Electrical Equipment in Operating Reactors"

-(D0R 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.

By its Memorandum and Order CLI-80-21 dated May 23, 1980, the Commission directed the staff to proceed with a rulemaking on environ-mental qualification of safety grade eqt.'raent and to address the ques-tion of backfit.

Tne Commission also directed that the 00R Guidelines and NUREG-0588 form the basis for the requirements licensees and appli-cants must meet until the rulemaking has been completed.

This proposed rule is generally based on the requirements of the Division of Operating Reactors (DOR) Guidelines and NUREG-0588.

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, 3

Enclosure A Version 2

[7590-01]

i:

1981, the Commission considered the petition (SECY-81-486) 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 Commissioner Bradford's memorandum dated October _15, 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 pordsn of equipment important to safety commonly referred to as " Class 1E" equipment in IEEE national standards and s ma additional-non-Class 1E 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, and (c) documentation. Qualification parameters include temperature, 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 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.

_The proposed rule will codify the Commission's current requirements for the environmental qualification of electric equipment.

Upon publica-L tion of a final rule, the DOR guidelines and NUREG-0588 will be withdrawn.

1 i.

[

4

-Enclosure A l

Version 2

[7590-01],

To provide adequate assurance of public safety, NRC is considering expansion of the scope of this proposed rule to include additional elec-tric equipment important to safety and seismic and dynamic qualification for electric equipment in nuclear power plants.

These matters will be the subject of a future rulemaking.

Paperwork Renduction Act The proposed rule contains recordkeeping requirements that are sub-ject 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, will not have a significant economic impact on a substantial number of small entities.

This proposed rule affects the method of qualification of electric equipment by utilities.

Utilities do not fall within the definition of a small business found in Section 3 of the Small Business Act, 15 U.S.C. 632.

In addition, utilities are required by Commission's Memorandum and Order CLI-80-21, dated May 23, 1980, to meet the require-I ments contained in the D0R " Guidelines for Evaluating Environmental Qualification of Class 1E Electric Equipment in Operating Reactors,"

(November 1979) and NUREG-0588, " Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment," which 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 Version 2

C

[7590-01]

Pursuant to the Atomic Energy Act of 1954, as amended, the Energy Reorganization Act of 1974, as amended, and section 553 of title 5 of the United States Code, notice is hereby given that adoption of the following amendment to 10 CFR Part 50 is contemplated.

10 CFR Part 50 1.

The authority citation for 10 CFR Part 50 reads as follows:

AUTHORITY:

Secs. 103, 104, 161b and i, 182, 183, 189, 68 Stat. 935, 937, 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),

S 50.54'(i) issued under Sec. 161i, 68 Stat. 949; (42 U.S.C. 2201(i)),

SS 50.70, 50.71 and 50.78 issued under Sec. 161o, 68 Stat. 950, as amended; (42 U.S.C. 2201(o)) and the Laws referred to in Appendices.

2.

A new 6 50.49 is added to read as follows:

6 50.49 Environmental qualification of electric equipment for nuclear power plants.

(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 Version 2

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]

[7590-01] '

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 p'revent the satisfactory accomplishment of,one or more of the above safety functions.

(c)' The applicant or' licensee shall prepare a list of all electric 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 1

design basis events and afterwards and the lengths of the periods during 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, including 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:

i (1) Temperature 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 qualificction of electric equipment.

7_

Enclosure A-Version 2

[7590-01]

(2) Humidity.

Time-deper. dent variations of relative humidity during normal operation and design basis events must be considered.

(3) Chemical Effects..The composition of chemicals used must be at least as severe as that resulting from the most limiting mode of plant operation (e.g., containment spray, emergency core cooling, or 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 following which the equipment is required to remain functional, including the radiation resulting from recirculat-ing fluids for equipment located near the recirculating lines.

(5) Aging.

Equipment qualified by test must, where practi-cable, be preconditioned by natural or artificial (accelerated) aging to its installed end-of-life condition.

Electromechanical equipment 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 must be replaced at the end of its qualified life unless ongoing qualification of prototype equipment naturally aged in plant service shows, by artificial aging and type testing, that the item has additional qualified life.

8 Enclosure A Version 2

[7590-01] '

(6) Submergence (if subject to being submerged).

(7) Synergistic Effects.

The preconditioning and testing of equip-ment must consider known synergistic effects when these effects are l

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 conditions.

(e) Each item 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 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 Version 2

f

[7590-01]

test 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 MSLB acci-dents and for LOCAs).

(4) The same piece of equipment must be used throughout the com-plete test sequence under any given profile.

(g) Each holder of an operating license issued prior to the effec-tive date of this rule must, within 90 days after the effective date of this rule, identify the electric equipment already qualified and submit a schedule for the testing or replacement of the remaining electric equipment.

This schedule must establish a goal of final environmental qualification by July 1, 1983.

The Director of Nuclear Reactor Regula-tion may grant requests for extensions of this deadline on a case-by-case basis for specific pieces of equipment if such requests are filed on a timely basis ano demonstrate good cause for the extension, such as procurement lead time, test complications, and installation problems.

(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.

r l

10 Enclosure A l

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[7590-01]'

(i) For the continued operation of a nuclear plant, each holder of

^

an operating license issued prior to the effective date of this rule shall perform an analysis to ensure that the plant can be safely operated

~

J pending completion of the environmental qualification. The detailed analysis'for each equipment type with appropriate justification must be i

submitted to Director of Nuclear Reactor Regulation within 90 days after the effective date of the rule and must include, where appropriate, consideration of:

i (1) Accomplishing the safety function by some designated alternative

)

equipment that has been adequately qualified and satisfies the single-failure criterion if the principal equipment has not been demonstrated to be fully qualified.

i (2) The validity of partial test data in support of the original i

qualification.

(3) Limited use of-administrative controls over equipment that has i

j not been denonstrated to be fully qualified.

}

(4) Completion of the safety function prior to exposure to the ensuing harsh environment and the subsequent failure of the equipment does not degrade any safety function or mislead tce operator.

(5) No significant degradation of any safety function or misleading of f

i 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, j.

must perform an analysis to ensure that the plant can be safely operated f

pending completion of the environmental qualification in accordance 4

with paragraph (i) of this section except that this analysis must be i

1.

11 Enclosure A 2

Version 2

7:.

[7590-01]

submitted to the Director of Nuclear Reactor Regulation for consideration

. prior to granting of an operating license.

(k) A record of the qualification must be maintained in a central file to permit verification that each item of electric equipment covered by_this section (1) is qualified for its application and (2) meets its specified performance requirements when it is subjected to the conditions predicted to be present when it must perform its safety function up to the end of its qualified life.

Dated at this day of

, 1981.

For the Nuclear Regulatory Commission.

Samuel J. Chilk Secretary of the Commission 12 Enclosure A.

Version 2

l VALUE/ IMPACT STATEMENT 1.

PROPOSED ACTION 1.1 Description The applicant (licensee) of a nuclear power plant is required by the Commission's regulations to verify that structures, systems, and components important to safety will perform their intended functions in spite of the environments that may result from anticipated operational occurrences or postulated accidents.

This verification includes environmental qualification by test, operating experience, and analysis, or a combination of these.

The l

proposed rule sets forth the Commission's requirements for the environmental l

qualification of electric equipment by test and analysis.

1. 2 Need for Proposed Action The current general requirements for qualification of electric equipment l

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-tion Systems for Nuclear Power Generating Stations." The NRC has used several l

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 1971, qualification was judged on the basis of IEEE 323-1971.

However, no l

reculatory guide was ever issued endorsing IEEE 323-1971, although some of the 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 supplernentary provisions.

" Copies may be obtained from the Institute of Electrical and Electronics Engineers, Inc., 345 East 47th Street, New York, N.Y. 10017.

1 Enclosure B Version 2

Currently, the Commission has underway a program to reevaluate the quali-fication of electric equipment in all operating reactors.

As part of this program, the staff has developed more definitive criteria for the environmental qualification.

The Division of Operating Reactors (00R) 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 D0R 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 licensees and apolicants 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 D0R Guidelines or NUREG-0588.

The Commission also noted that the guidelines and NUREG-0588 apply pro-gressively less strict standards to older plants and that this problem is best resolved by a rulemaking.

The purpose of the proposed rule is to codify the current NRC practice with respect to qualification of electric equipment.

The proposed rule will apply the same uniform performance criteria for environ-mental qualification to all operating nuclear power plants and plants for which appiir.ation has been made for a construction permit or an operating license.

1.3 Value/ Impact of Proposed Action 1.3.1 NRC Operations Since regulations specifically setting forth requirements for the qualifi-cation of electric equipment in new and operating plants have never been issued, the proposed action should result in more effective ef fort 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 (1) in completion of a generic activity (A-24), " Qualification of Class 1E Safety-Related Equipment," (2) in the preparation of the 00R Guidelines and 2

Enclosure B Version 2

l j

NUREG-0588, (3) in IEEE standards committee work, and (4) in the development, funding, and monitoring of related research programs.

l 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 Agencies Not applicable, unless the government agency is an applicant.

l 1.3.3 Industry l

The licensees and applicants currently must meet the requirements for f

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 qualification of electric equipment for new and existing plants.

This, in turn, should ease the licensing process l

for industry by eliminating delays resulting from misinterpretation of NRC's l

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 Procosed Action The proposed action has been mandated by the Commission in its Memorandum and Order CLI-80-21 dated May 23, 1980.

l r

2.

TECHNICAL APPROACH During the course of rule development over the next two years, it is not

. anticipated that significant technical improvement over the material in the 3

Enclosure B Version 2

[F.

00R Guidelines and NUREG-0588 will be forthcoming from national standards committees.

In fact, a proposed revision (update) to IEEE 323-1974 is based on the-technical material in NUREG-0588. Additional new material may, however,

~be developed as a result of the various equipment qualification research pro-grams currently underway.

Therefore, the technical approach will be to codify the programs of the 00R Guidelines and NUREG-0588 as applied at the time the

. final rule is published, with additional supplementary material to reflect acceptable technical advances in this area.

3.

PROCEDURAL APPROACH Rulemaking has been mandated by the Commission in its Memorandum and Order cited above.

4.

STATUTORY CONSIDERATIONS 4.1 NRC Authority i

Authority for this rulemaking is derived from the Atomic Energy Act of 1954, as amended, and the Energy Reorganization Act of 1974, as amended.

4.2 Need for NEPA Assessment The proposed action does not require an environmental impact statement 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 are foreseen.

6.

SUMMARY

AND CONCLUSIONS This rulemaking mandated by_ the Commission should be initiated immediately j

and conducted in a timely manner.

i.

p 4

Enclosure B Version 2'

y 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 anri XI of Appendix B to Part 50 and paragraph 50.55a(h) of 10 CFR Part 50.

These ara general requirements stat-ing the principle that structures, systems, and compr.nents important to safety in a nuclear power plant must be designed to accommocate the effects of envi-runmental 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 that these general requirements are met for electric equipment.

Although docu-mented in various national standards, regulatory guides, and 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 1

Enclosure C Version 2

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. Aggarwal, 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 will be available for public inspection at the Commission's Public Document Room, 1717 H Street NW.,

Washington, D.C.

i 2

Enclosure C Version 2

ANALYSIS WITH RESPECT TO PERIODIC AND SYSTEMATIC REVIEW 0F REGULATIONS (TMI ACTION PLAN TASK IV.G.2)

SUBJECT:

Section 50.49 pertaining to environmental qualification of electric equipment Criteria for Periodic and Systematic Review of Regulations NRC Compliance 1.

The proposed regulations are needed.

Specific environmental equipment qualification methods and criteria currently contained in national stantards, NRC regulatory guides, and other publications have been given 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 by the Commission's Memorandum and Order CLI-80-21 dated May 23, 1980 to meet the requirements contained in the D0R " Guidelines for Evaluating Environmental Qualification of Class IE Electrical Equipment in Operating Reactors,"

(November 1979) and NUREG-0588, " Interim Staff.'osition on Environmental Qualification of Safety-Related Electrical

+

Equipment," which form the basis of this proposal.

Conse-quently, this rule codifies existing requirements and imposes no new costs or obligations on licensees.

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 environmertal qualifica-i 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.

l adequate response has been prepared.

l 1

Enclosure D Version 2

SUBJECT:

Section 50.49 pertaining to environmental qualification of electric equipment Criteria for Periodic and Systematic Review of Regulations hRC Compliance 5.

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 comply with it.

6.

An estimate has been made of the new reporting There are no reporting requirements in the proposed rule.

burdens or recordkeeping requirements necessary Additional burden on applicants 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.

7.

The name, address, and telephone number of a The Federal Register notice promulgating the proposed rule knowledgeable agency official is included in contains the name, address, and telephone number of a the publication.

knowledgeable agency official.

8.

A plan for evaluating the regulation after Licensee and staff experience with the regulation will be 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).

2 Enclosure O Version 2

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r [7590-01] NUCLEAR REGULATORY COMMISSION 10 CFR Part 50 Environmental and Seismic Qualification of Electric Equipment for Nuclear Power Plants AGENCY: Nuclear Regulatory Commission. ACTION: Proposed Rule.

SUMMARY

The Nuclear Regulatory Commission is proposing to amend its regulations applicable to nuclear power plants to clarify and strengthen-the criteria for environmental and seismic qualification of electric equip-ment. Specific qualification methods currently contained in national standards, regulatory guides, and certain NRC publications for equipment qualification have been given different interpretations and have not had the legal force of an agency regulation. The proposed rule would codify these environmental qualification methods and clarify the Commission's requirements 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: Docketing 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 Version 3

;/ :

[7590-01] V, / 7 ~ Washington, D.C., between the hours of 8:;30 a.m. and 4:45 p.m. on normal ~ work days. FOR FURTHER INFORMATION C NTACT: 'Satish K. Aggarwal, Office of Nuclear Regulatory Research, Electrical Engineeri~ng 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 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 Criterion XI, " Test Control," of Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," to 10 CFR Part 50; and in 10 CFR 50.55a(h), which incorporates by reference IEEE 279-1971,1,2 " Criteria for Protection Systems for Nuclear Power Generating Stations." This requirement is applicable t? equipment located inside as well as outside the containment. The NRC has used a variety of methods to ensure that these general requirements are met for electric equipment important to safety. 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 1971, qualification was 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 ' 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 Engineers, Inc., 345 East 47th Street, New York, N.Y. 10017. 2 Enclosure A Version 3

l [7590-01] / ? f, Equipment for Light-Water-Cooled Nuclear Power Plants," which endorses 7 ,IEEE 3I3-1974,2 "IEEE Standard for Qualifying Class 1E Equipment for Nudlearf Power Generating Stations," subject to supplementary provisions. Curre'ntly, the Commission has underway 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 NRC. 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. By its Memorandum and Order CLI-80-21 dated May 23, 1980, the Commis-sion directed the staff to proceed with a rulemaking on environmental qualification of safety grade equipment and to address the question of backfit. The Commission also directed that the 00R Cuidelines and NUREG-0588 form the basis for the requirements licensees and applicants must meet until the rulemaking has been completed. This proposed rule is generally based on the requirements of the Division of Operating Reactors (DOR) Guidelines and NUREG-0588. However, the scope has been expanded to include the requirement pertaining to seismic and dynamic qualification. In the area of dynamic qualification, the NRC staff is concerned about hydrodynamic loads due to accident conditions (for example, hydrodynamic loads resulting from pressure suppression pool operation in BWR plants). l 3 Enclosure A Version 3 j

[7590-01] Prior to 1971, no specific requirements for seismic qualification existed. Industry practice was such that the effects of seismic accelera-tions were determined by physical tests, mathematical analysis, or engi-neering judgement. In 1971, IEEE 344-1971, "IEEE Guide for Seismic Qualification of Class I Electric Equipment for Nuclear Power Generating Stations" was published. In 1972, the NRC staff informally issued a branch technical position that supplemented IEEE 344-1971 by requiring justification for single-axis and single-frequency testing in lieu of multi-axis and multi-frequency testing. In 1975, IEEE 344-1975 adopted this position. Section 3.10, " Seismic Qualification of Category I Instrumentation and Electrical Equipment," of the Standard Review Plan (SRP), issued November 24, 1975, provided the following criteria for seismic and dynamic qualification for nuclear power plants for which an operating license had not been issued: electric equipment for plants having construction permit docket dates prior to October.*7, 1972 should meet the requirements of IEEE 344-1971, and electric equipment for plants having construction permit docket dates after October 27, 1972 should meet the requirements of IEEE 344-1975, with certain exceptions. Regula-tory Guide 1.100 issued in August 1977 endorsed, with certain exceptions, IEEE 344-1975. In the proposed rule, the requirement of seismic and dynamic quali-fication will apply to nuclear power plants whose applications for con-struction permit is made on or after October 27, 1972. However, the requirement for environmental qualification will apply to all operatirg nuclear power plants and future nuclear power plants. r 4 Enclosure A Version 3

[7590-01]- 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-81-486) 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. 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 equipment important to safety commonly referred to as " Class 1E" equipment in IEEE national standards and some additional non-Class 1E equipment and systems whose failure under extreme seismic of environmental conditions could prevent the satisfactory accomplishment of safety functions by accident-m'tigating equipment. Included in the proposed rule are specific technical *equirements pertaining to (a) qualification parameters, (b) qualification methods, and (c) documentation. Qualification parameters include temperature, pressure, humidity, radiation, chemicals, submergence, vibration and seismic forces. Qualification methods include (a) testing as the prin-cipai means of qualification and (b) analysis and operating experience in lieu of trng. The proposed rule would require that the qualifi-cation program include synergistic effects, aging, margins, radiation, and environmental conditions. Also, a record of qualification must be maintained. Regulatory Guide 1.89 is being revised to describe methods acceptable to the NRC for meeting the provisions of this proposed rule and to include a list of typical equipment covered by it; a draft of the proposed revision is being published for public comment concurrently with the proposed rule. 5 Enclosure A Version 3

[7590-01] The proposed rule will codify the Commission's current requirements for the environmental and seismic qualification of electric equipment. Upon publication of a final rule, the 00R guidelines and NUREG-0588 will be withdrawn. To provide adequate assurance of public safety, NRC is considering expansion of the scope of this proposed rule to include additional elec-tric equipment important to safety. This will also include consideration of backfitting the requirement of seismic and dynamic qualification to operating 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-ject 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, will not have a significant economic impact on a substantial number of small entities. This proposed rule affects the method of qualification of electric equipment by utilities. Utilities do not fall within the definition of a small business found in Section 3 of the Small Business Act, 15 U.S.C. 632. In addition, utilities are required by Commission's Memorandum and Order CLI-80-21, dated May 23, 1980, to meet the require-ments contained in the 00R " Guidelines for Evaluating Environmental 6 Enclosure A Version 3 J

[7590-01] ' Qualification of Class 1E Electric Equipment in Operating Reactors," (November 1979) and NUREG-0588, " Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equi pent," which form the basis of this proposed rule. Consequently, this rule codifies existing requirements and imposes no new costs or obligations on utilities. The requirement pertaining to seismic and dynamic qualification will not apply to operating nuclear power plants. Pursuant to the Atomic Energy Act of 1954, as amended, the Energy Reorganization Act of 1974, as amended, and section 553 of title 5 of the United States Code, notice is hereby given that adoption of the following amendment to 10 CFR Part 50 is contemplated. 10 CFR Part 50 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, 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). Sections 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), 5 50.54 (i) issued under Sec. 1611, 68 Stat. 949; (42 U.S.C. 2201(i)), 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. 7 Enclosure A Version 3 1 l

y_ l [7590-01] 2. A new S 50.49 is added to read as follows: 9 50.49 Environmental and seismic qualification of electric equipment for nuclear power plants. (a) Except as noted in paragraph (k) of this section, 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 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 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 during 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. 8 Enclosure A Version 3

[7590-01] (3) The environmental conditions, including temperature, pressure, l humidity, radiation, chemicals, and submergence, vibration and seismic forces and the predicted variations 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) Temperature 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. (2) Humidity. Time-dependent variations of relative humidity during normal operation and design basis events must be considered. (3) Chemical Effects. The composition of chemicals used must be at least as severe as that resulting from the nst limiting mode of plant operation (e.g., containment spray, emergency core cooling, or recircula-tion from containment sump). If the composition of the chemical spray can be affected by equipment malfunctions, trm 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 environment 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 following which the equipment is required to remain functional, including the radiation resulting from recirculating fluids for equipment located near the recirculating lines. .9 Enclosure A Version 3 k_ . i r i er

~ [7590-01] o (5) Aging. Equipment qualified by test must, where practicable, be preconditioned by natural or artificial (accelerated) aging to its installed end-of-life condition. Aging considerations based on seismic and dynamic loads must include a justificiable number of operating basis earthquakes and other dynamic (cyclic) loading effects. Electromechanical equipment must be operated to simulate the mechanical wear and electrical degradation expected during its installed life. Where preconditioning to a qualified life equal to the installed life is not possible, the equip-ment may be preconditioned to a shorter qualified life. The equipment must be replaced at the end of its qualified life unless ongoing qualifi-cation of prototype equipment naturally aged in plant service shows, by artificial aging and type testing, that the item has additional qualified life. (6) Submergence (if subject to being submerged). (7) Seismic and Vibratory Loads. (i) Equipment must be subjected to the forces resulting from one operating basis earthquake and one safe shutdown earthquake. Other vibra-tory loads occurring during both normal operation and accidents must be included. Loads resulting from anticipated operational occurrences or accidents must be combined appropriately with the seismic loads. . (ii) The characteristics of the applicable input motion must be speci-fied by response spectra, time history, or_other means, if appropriate. (8) Synergistic 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. (9) Margins. Margins must be applied to account for production variations and inaccuracies in test instruments. These margins are in 10 Enclosure A Version 3

[7590-01]

addition to margins applied during the derivation of the environmental conditions.

(e) Each item 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. l (4) Analy, sis 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 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 test 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 11 Enclosure A Version 3 u________--__

[7590-01] break (MSLB) and loss-of-coolant eccidents (LOCA)) or (ii) separate pro-files for each type of event (e.g., separate profiles for the MSLB acci-dents and for LOCAs). (4) The same piece of equipment must be used throughout the complete test sequence under any given profile. (5) Seismic and vibratory load testing must use: (i) Multifrequency and multiaxial input motions unless adequate justification for using a single-frequency input motion or a single-axis input motion is provided. (ii) A test mounting that simulates the actual service mounting and does not cause any significant extraneous dynamic coupling to the equip-ment being tested. (iii) An actual input motion that can be demonstrated to equal or exceed the anticipated input motion. The duration of each test must equal or exceed the strong motion portion of the design earthquake and other dynamic loads due to accident conditions. (g) Each holder of an operating license issued prior to the effec-tive date of this rule must submit a schedule for the environmental quali-fication of electric equipment within 90 days after the effective date of this rule. This schedule must establish a goal of final environmental qualification by the end of the second refueling outage after March 31, 1982. The Director of Nuclear Reactor Regulation may grant requests for extensions 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 l 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. I 12 Enclosure A Version 3

[7590-01] * (h) Each licensee shall notify the Commission of any significant environmental qualification problem that may require extension of the completion date within 30 days of its discovery. L (i) For the continued operation of a nuclear plant, each holder of i~ an operating license issued prior to the effective date of this rule i shall perform an analysis to ensure that the plant can be safely operated 1 pending completion of the environmental qualification. The detailed analysis for each equipment type with appropriate justification must be submitted to Director of Nuclear Reactor Regulation within 90 days after the effective date of the rule and must include, where appropriate, consideration of: f (1) Accomplishing the safety function by some designated alterna-tive equipment that has been adequately qualified and satisfies the single-failure criterion if the principal equipment has not been demon-strated to be fully qualified. (2) The validity of partial test data in support of the original qualification. (3) Limited use of administrative controls over equipment that has not been demonstrated to be fully qualified. (4) Completion of the safety function prior to exposure to the ensu-ing 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 of 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 pr.ior to November 30, 1985, 13 Enclosure A Version 3

p [7590-01] i 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 submitted to the Director of Nuclear Reactor Regulation for consideration prior to granting of an operating license. (k) The aging considerations based on seismic and dynamic loads of paragraph (d)(5) of this section and testing requirements for seismic and vibrating loads of paragraph (d)(7) of this section apply only to nuclear power plants whose applications for a construction permit is made on or after October 27, 1972. (1) A record of the qualification must be maintained in a central file to permit verification that each item of electric equipment covered by this section (1) is qualified for its application and (2) meets its specified performance requirements when it is subjected to the conditions predicted to be present when it must perform its safety function up to the end of its qualified life. Dated at this day of , 1981. For the Nuclear Regulatory Commission. Samuel J. Chilk Secretary of the Commission 14 Enclosure A Version 3

i VALUE/ IMPACT STATEMENT 1. PROPOSED ACTION 1.1 Description The applicant (licensee) of a nuclear power plant is required by the Commission's regulations to verify that structures, systems, and components important to safety will perform their intended functions in spite of the environments that may result from anticipated operational occurrences or postulated accidents. This verification includes environmental qualification by Lest, ope ating 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 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-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 1971, qualification was judged on the basis of IEEE 323-1971. However, no regulatory guide was ever issued endorsing IEEE 323-1971, although some of the 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. -1 Enclosure B Version 3

0-Currently, the Commission has underway a program to reevaluate the quali-fication of electric equipment in all operating reactors. As part of this program, 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 licensees 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 DOR Guidelines or NUREG-0588. The Commission also noted that the guidelines and NUREG-0588 apply pro-gressively less strict standards to older plants and that this problem is best resolved by a rulemaking. The purpose of the proposed rule is to codify the current NRC practice with respect to qualification of electric equipment. 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 made for a construction permit or an operating license. 1.3 Value/ Impact of Proposed Action 1.3.1 NRC Operations Since regulations specifically setting forth requirements for 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 (1) in completion of a generic activity (A-24), " Qualification of Class 1E Safety-Related Equipment," (2) in the preparation of the 00R Guidelines and 2 Enclosure B Version 3

e I NUREG-0588, (3) in IEEE standards committee work, and (4) in the development, funding, and monitoring of related research programs. 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 Agencies Not applicable, unless the government agency is an applicant. 1.3.3 Industry l The licensees and applicants currently must meet the requirements for qualification of elect *ic equipment in accordance with the Commission's Memorandum and Order.LI-80-21. The requirement in this proposed rule pertain-r t ing to seismic and dynamic qualification will not apply to operating nuclear power plants. If the final rule is published as now proposed, 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 qualification of electric equipment for new and existing plants. This, in turn, should ease the licensing process for industry by eliminating delays resulting from misinterpretation of NRC's requirements. 1.3.4 Public The proposed action will improve public safety by further ensuring that electric equipment will perform its safety functions in spite of environments that may result from design basis events. These is no perceived impact on the public. e 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.:10 development over the next two years, it is not anticipated that significant technical improvement over the material in the 3 Enclosure B Version 3 1 t l

00R Guidelines and NUREG-0588 will be forthcoming from national standards committees. In fact, a proposed revision (update) to IEEE 323-1974 is based on the technical material in NUREG-0588. Additional new material may, however, be developed as a result of the various equipment qualification research pro-grams currently underway. Therefore, the technical approach will be to codify the programs of the 00R Guidelines and NUREG-0588 as applied at the time the final rule is published, with additional supplementary material to reflect acceptable technical advances in this area. 3. PROCEDURAL APPROACH Rulemaking has been mandated by the Comraitsion 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. 4.2 Need for NEPA Assessment The proposed action does not require an environmental impact statement 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 are foreseen. 6.

SUMMARY

AND CONCLUSIONS i This rulemaking mandated by the Commission should be initiated immediately and conducted in a timely manner. 4 Enclosure B Version 3

o e NRC PROPOSES RULEMAKING ON ENVIRONMENTAL AND SEISMIC QUALIFICATION OF ELECTRIC EQUIPMENT 1 The Nuclear Regulatory Commission is proposing a rule on Environmental l and Seismic Qualification of Electric Equipment. f The current requirements for qualification of structures, systems, and components important to safety are contained in General Design Criteria 1, 2, 4, and 23 of Appendix A to Part 50, Criterion III and XI of Appendix B to Part 50 and paragraph 50.55a(h) of 10 CFR Part 50. These are general require-ments stating the principle that structures, systems, and components important to safety in a nuclear power plant must be designed to accommodate the effects of environmental 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 that these general requirements are met for electric equipment. Although docu-mented in various national standards, regulatory guides, and 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 tnis 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 cf electric equipment. The full text of the proposed rule is being published in the Federal Register on Interested persons are 'nvited to submit written 1 Enclosure C Version 3

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. Aggarwal, 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 will be available for public inspection at the Commission's Public Document Room, 1717 H Street NW., Washington, D.C. 4 i i 2 Enclosure C Version 3

ANALYSIS WITH RESPECT TO PERIODIC AND SYSTEMATIC REVIEW 0F REGULATIONS (TMI ACTION PLAN TASK IV.G.2)

SUBJECT:

Section 50.49 pertaining to environmental and seismic qualification of electric equipment Criteria for Periodic and Systematic Review of Regulations NRC Compliance 1. The proposed regulations are needed. Specific environmental equipment qualification methods and criteria currently contained in national stantards, NRC regulatory guides, and other publications have been given 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 by the Commission's Memorandum and Order CLI-80-21 dated May 23,1980 to meet the requirements contained in the 00R " Guidelines for Evaluating Environmental Qualification of Class IE Electrical Equipment in Operating Reactors," (November 1979) and NUREG-0588, " Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment," which form the basis of this proposal. Conse-quently, this rule codifies existing requirements and imposes no new costs or obligations on licensees. The requirement for seismic and dynamic qualification will not apply to operating nuclear power plants. 3. Alternative approaches have been considered Rulamaking was chosen as the least burdensome to codify and the least burdensome of the acceptable the requirements pertaining to environmental qualifica-alternatives has been chosen. tion of electric equipment. 4. Public comments have been considered and an The proposed rule will be issued for public comments. adequate response has been prepared. 1 Enclosure D Version 3

SUBJECT:

Section 50.49 pertaining to environmental and seismic qualification of electric equipment Criteria for Pericdic and Systematic Review of Regulations NRC Ccgtiiance 5. 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 uaderstood by persons who are required to comply with it.. 6. An estimate has been made of the new reporting There are no reporting requires:.its in th e proposed rule. burdens or recordkeeping requirements necessary Additional burden on apriicantw sith resp'ct to recordkeep- .for compliance with the regu::*, ion. ing will result from (a, "equirement for 6 central file under the control of the applicant, and (b) expansion of the central file to include seismic qualification data beyond General Design Criteria XVI of Appendix B to 10 CFR 50. 7. The name, address, and telephone number of a The Federal Register notice promulgating the proposed rule krawledgeable agency official is included in contains the name, address, and telephone number of a the publication. knowledgeable agency official. 8. A plan for evaluating the regulation after Licensee and staff experience with the regulation will be 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). 2 Enclosure D Version 3

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[7590-01] NUCLEAR REGULATORY COMMISSION 10 CFR Part 50 Environmental and Seismic Qualification of Electric Equipment for Nuclear Power Plants AGENCY: Nuclear Regulatory Commission. 1 ACTION: Proposed Rule.

SUMMARY

The Nuclear Regulatory Commission is proposing to amend its regulations applicable to nuclear power plants to clarify and strengthen l the criteria for environmental and seismic qualification of electric equip-ment. Specific qualification methods currently contained in national standards, regulatory guides, and certain NRC publications for equipment qualification have been given different interpretations and have not had the legal force of an agency regulation. The proposed rule would codify these environmental qualification methods and clarify the Commission's requirements 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: Docketing 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 Version 4

[7590-01] Washington, D.C., between the hours of 8:30 a.m. and 4:45 p.m. on normal work days. FOR FURTHER INFORMATION CONTACT: Satish K. Aggarwal, Office of Nuclear Regulatory Research, Electrical Engineering 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 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 Criterion XI, " Test Control," of Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," to 10 CFR Part 50; and in 10 CFR 50.55a(h), which incorporates 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 containment. The NRC has used a vseiety of methods to ensure that these general requirements are met ~for electric equipment important to safety. 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 1971, qualification was 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 1 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 Engineers, Inc., 345 East 47th Street, New York, N.Y. 10017. 2 Enclosure A Version 4

[7590-01]

Equipment t' / Light-Water-Cooled Nuclear Power Plants," which endorses IEEE 323-1974,2 "IEEE Standard for Qualifying Class 1E Equipment for Nuclear Power Generating Stations," subject to supplementary provisions.

Currently, the Commission has underway a program to reevaluate tha qualification of electric equipment important to safety in all operating nuclear power plants. As a part of this program, more definitive criteria for ens'ronmental qualification of electric equipment have been developed by the NRC. A document entitled " Guidelines for Evaluating Environmental Qualification of Class 1E Electrical Equipment in Operating Reactors" (DOR 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. By its Memorandum and Order CLI-80-21 dated May 23, 1980, the Commis-sion directed the staff to proceed with a rulemaking on environmental qualification of safety grade equipment and to address the question of backfit. The Commission also directed that the 00R Guidelines and NUREG-0588 form the basis for the requirements licensees and applicants must meet until the rulemaking has been completed. This proposed rule is generally based on the requirements of the Division of Operating Reactors (00R) Guidelines and NUREG-0588. However, the scope has been expanded to include the requirement pertaining to seismic and dynamic qualification. In the area of dynamic qualification, the NRC staff is concerned about hydrodynamic loads due to accident conditions (for example, hydrodynamic loads resulting from pressure suppression pool operation in BWR plants). 3 Enclosure A Version 4

[7590-01] Prior to 1971, no specific requirements for seismic qualification existed. Industry practice was such that the effects of seismic accelera-tions were determined by physical tests, mathematical analysis, or engi-neeringjudgement. In 1971, IEEE 344-1971, "IEEE Guide for Seismic Qualification of Class I Electric Equipment for Nuclear Power Generating Stations" was published. In 1972, the NRC staff informally issued a branch technical position that supplemented IEEE 344-1971 by requiring justification for single-axis and single-frequency testing in lieu of multi-axis and multi-frequency testing. In 1975, IEEE 344-1975 adopted this position. Section 3.10, " Seismic Qualification of Category I Instrumentation and Electrical Equipment," of the Standard Review Plan (SRP), issued November 24, 1975, provided the following criteria for seismic and dynamic qualification for nuclear power plants for which an operating license had not been issued: electric equipment for plants having construction permit docket dates prior to October 27, 1972 should meet the requirements of IEEE 344-1971, and electric equipment for plants having construction permit docket dates after Lctober 27, 1972 should meet the requirements of IEEE 344-1975, with certain exceptions. Regula-tory Guide 1.100 issued in August 1977 endorsed, with certain exceptions, IEEE 344-1975. In the proposed rule, the requirements of environmental seismic and dynamic qualification will apply to all operating nuclear power plants and future nuclear power plants. i 4 Enclosure A Version 4

[7590-01] lne 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-81-486) 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. 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 equipment important to safety commonly referred to as " Class 1E" equipment in IEEE national standards and some additional non-Class 1E equipment and systems whose failure under extreme seismic of environmental 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, and (c) documentation. Qualification parameters include temperature, pressure, humidity, radiation, chemicals, submergence, vibration and seismic forces. Qualification methods include (a) testing as the prin-cipal means of qualification and (b) analysis and operating experience in lieu of testing. The proposed rule would require that the qualifi-cation program include synergistic effects, aging, margins, radiation, and environmental conditions. Also, a record of qualification must be maintained. Regulatory Guide 1.89 is being revised to describe methods acceptable to the NRC for meeting the provisions of this proposed rule 'and to include a list of typical equipment covered by it; a draft of the proposed revision is being published for public comment concurrently with the proposed rule. 5 Enclosure A Version 4

[7590-01] The proposed rule will codify the Commission's current requirements for the environmental and seismic qualification of electric equipment. Upon publication of a final rule, the 00R guidelines and NUREG-0588 will be withdrawn. To provide adequate assurance of public safety, NRC is considering expansion of the scope of this proposed rule to include additional elec-tric equipment important to safety. This matter will be the subject of a future rulemaking. Paperwork Reduction Act The proposed rule contains recordkeeping requirements that are sub-ject 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 recordke0 ping 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, will not have a significant economic impact on a substantial number of small entities. This proposed rule affects the method of qualification of electric equipment by utilities. Utilities do not fall within the definition of a small business found in Section 3 of the Small Business Act, 15 U.S.C. 632. In addition, utilities are required by Commission's Memorandum and Order CLI-80-21, dated May 23, 1980, to meet the require-ments contained in the D0R " Guidelines for Evaluating Environmental 6 Enclosure A Version 4

[7590-01]

Qualification of Class 1E Electric Equipment in Operating Reactors,"

( (November 1979) and NUREG-0588, " Interim Staff Position on Environmental l Qualification of Safety-Related Electrical Equipment," which form the l basis of this proposed rule. The requirement pertaining to seismic and dynamic qualification will apply to operating nuclear power plants and will impose additional costs and obligations on utilities. ) . Pursuant to the Atomic Energy Act of 1954, as amended, the Energy i l Reorganization Act of 1974, as amended, and section 553 of title 5 of l the United States Code, notice is hereby given that adoption of the following amendment to 10 CFR Part 50 is contemplated. 10 CFR Part 50 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, 948, 953, 954, 955, 956, as amended (42 U.S.C. 2133, 2134, 2201(b) and l (i), 2232, 2233, 2239); secs. 201, 202, 206, 88 Stat. 1243, 1244, 1246 I l (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). Sections 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), 6 50.54 (i) issued under Sec. 1611, 68 Stat. 949; (42 U.S.C. 2201(i)), $$ 50.70, 50.71 and 50.78 issued under Sec. 161o, 68 Stat. 950, as amended; (42 U.S.C. 2201(o)) and the Laws i referred to in Appendices. G ._s 7 Enclosure A Version 4

[7590-01] + - 2. A new 6 50.49 is added to read as follows: 5 50.49 Environmental and seismic qualification of electric equipment for nuclear power plants. (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 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 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 during which the integrity must be maintained. f (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. 9 f 8 Enclosure A Version 4 f~

[7590-01] (3) The environmental conditions, including temperature, pressure, humidity, radiation, chemicals, and submergence, vibration and seismic forces and the predicted variations 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) Temperature 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. (2) Humidity. Time-dependent variations of relative humidity during normal operation and dasign basis events must be considered. (3) Chemical Effects. The composition of chemicals used must be at least as severe as that resulting from the most limiting mode of plant operation (e.g., contaio ht <; pray, emergency core cooling, or recircula-tion from contain N..a If the composition of the chemical spray can be affectni by equipmed malfunctions, the most severe chemical spray environment that results from a single failure in the spray system must be assumed. (4) Radiation. The radiation environat must be based on the type of radiation.and the dose and dose rate of the radiation environment 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 following which the equipment is required to remain functional, including the radiation resulting from recirculating fluids for equipment located near the recirculating lines. 9 Enclosure A Version 4

[7590-01] t (5) y_n_g. Equipment qualified by test must, where practicable, be preconditioned by natural or artificial (accelerated) aging to its installed end-of-life condition. Aging considerations based on seismic and dynamic loads must include a justificiable number of operating basis earthquakes and other dynamic (cyclic) loading effects. Electromechanical equipment must be operated to simulate the mechanical wear and electrical degradation expected during its installed life. Where preconditioning to a qualified life eonal to the installed life is not possible. the equip-ment may be preconditioned to a shorter qualified life. The equipment must be replaced at the end of its qualified life unless ongoing qualifi-i cation of prototype equipment naturally aged in plant service shows, by artificial aging and type testing, that the item has additional qualified life. (6) Submergence (if subject to being submerged). (7) Seismic and Vibratory Loads. (i) Equipment must be subjected to the forces resulting from one operating basis earthquake and one safe shutdown earthquake. Other vibra-tory loads occurring during both normal cperation and accidents must be included. Loads resulting from anticipated operational occt..'rences or accidents must be combined appropriately with the seismic loads. (ii) The characteristics of the applicable input motion must be speci-fied by response spectra, time history, or other means, if appropriate. (8) Synergistic 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. (9) Margins. Margins must be applied to account for production variations and inaccuracies in test instruments. These margins are in 10 Enclosure A Version 4

[7590-01] addition to margins applied during the derivation of the environmental conditions. (e) Each item 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 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 test 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 11 Enclosure A Version 4

L [7590-01] break (MSLB) and loss-of-coolant accidents (LOCA)) or (ii) separate pro-files for each type of event (e.g., separate profiles for the MSLB acci-dents and for LOCAs). (4) The same piece of equipment must be used throughout the complete test sequence under any given profile. (5) Seismic and vibratory load testing must use: (i) Multifrequency and multiaxial input motions unless adequate justification for using a single-frequency input motion or a single-axis input motion is provided. (ii) A test mounting that simulates the actual service mounting and does not cause any significant extraneous dynamic coupling to the equip-ment being tested. (iii) An actual input motion that can be demonstrated to equal or exceed the anticipated input motion. The duration of each test must equal or exceed the strong motion portion of the design earthquake and other dynamic loads due to accident conditions. (g) Each holder of an operating license issued prior to the effec-tive date of this rule must submit a schedule for the environmental and seismic qualification of electric equipment within 90 days after the effective date of this rule. This schedule must establish a goal of final environmental and seismic qualification by the end of the second refueling outage after March 31, 1982. The Director of Nuclear Reactor Regulation may grant requests for extensions 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. 12 Enclosure A Version 4

[7590-01] c, In exceptional cases, the Commission itself may consider and grant exten-sions beyond November 30, 1985 for completion of environmental and seismic qualification. (h) Each licensee shall notify the Commission of any significant l environmental and seismic qualification problem that may require extension of the completion date within 30 days of its discovery. (i) For the continued operation of a nuclear plant, each holder of an operating license issued prior to the effective date of this rule shall perform an analysis to ensure that the plant can be safely operated pending completion of the environmental and seismic qualification. The detailed analysis for each equipment type with appropriate justification must be 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 alterna-tive equipment that has been adequately qualified and satisfies the single-failure criterion if the principal equipment has not been demon-strated to be fully qualified. (2) The validity of partial test data in support of the original qualification. (3) Limited use of administrative controls over equipment that has not been demonstrated to be fully qualified. (4) Completion of the safety function prior to exposure to the ensu- .ing harsh environment and the subsequent failure of the equipment does not degrade any safety function or mislead the operator. 13 Enclosure A Version 4

[7590-01] (5) No significant degradation of any safety function or misleading of 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 and seismic qualification in 1 accordance with paragraph (i) of this section except that this analysis must be submitted to the Director of Nuclear Reactor Regulation for consideration prior to granting of an operating license. (k) A record of. the qualification must be maintained in a central file to permit verification that each item of electric equipment covered by this section (1) is qualified for its application and (2) meets its specified performance requirements when it is subjected to the conditions predicted to be present when it must perform its safety function up to the end of its qualified life. Dated at this day of , 1981. For the Nuclear Regulatory Commission. Samuel J. Chilk Secretary of the Commission 14 Enclosure A Version 4

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 environmentel 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. l 1.2 Need for Proposed Action l l l The current general requirements for qualification of electric equipment j 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-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 l 1971, qualification was judged on the basis of IEEE 323-1971. However, no regulatory guide was ever issued endorsing IEEE 323-1971, although some of the 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 Electonics Engineers, Inc., 345 East 47th Street, New York, N.Y.10017. 1 Enclosure B Version 4

Currently, the Commission has underway a program to reevaluate the quali-fication of. electric equipment in all operating reactors. As part of this program, the staff has developed more defini;ive 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 Memorandem and Order CLI-80-21 issued on May 23, 1980, the Commis-sion endorsed the staff's actions to use the D0R 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 licensees 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 D0R Guidelines or NUREG-0588. The Commission also noted that the guidelines and NUREG-0588 apply pro-gressively less strict standards to older plants and that this problem is best resolved by a rulemaking. The purpose of the proposed rule is to codify the current NRC practice with respect to qualification of electric er:uipment. 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 made for a construction permit or an operating lice..se.

1. 3 Value/ Impact of Proposed Action 1.3.1 NRC Operations Since regulations specifically setting forth requirements for the qualifi-cation of electric equipment in new and operating plants have never been issued, the proposed action should result in more ef fective 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 advantace of previous staff effort (1) in completion of a generic activity (A-24), " Qualification of Class 1E Safety-Related Equipment," (2) in the preparation of the 00R Guidelines and 2 Enclosure B Version 4

,.. o NUREG-0588, (3) in IEEE standards committee work, and (4) in the development, funding, and monitoring of related research programs. There should be littla impact on the staff at the time the rule is approveC. Approximately two man years of effort is anticipated in preparation of the rule. 1.3.2 Other Government Agencies l Not applicable, unless the government agency is an applicant. 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. The requirement in this proposed rule pertain-ing ts .ismic and dynamic qualification will apply to operating nuclear pcwer plants. If the final rule is published as now proposed, the rule will 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 qualification of electric equipment for new and existing plants. This, in turn, should ease the licensing process for industry by eliminating delays resulting from misinterpretation of NRC's requirements. 1.3.4 Public The proposed action will improve public safety by further ensuring that electric equipment 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 C.I-80-21 dated May 23, 1980, 2. TECHNICAL APPROACH During the course of rule development over the next two years, it is not anticipated that significant technical improvement over the material in the 3 Enclosure B Version 4 j

.o..- 00R Guidelines and NUREG-0588 will be forthcoming from national standards committees. In fact, a proposed revision (update) to IEEE 323-1974 is based on the technical material in NUREG-0588. Additional new material may, however, be developed as a result of the various equipment qualification research pro-grams currently underway. Therefore, the technical approach will be to codify the programs of the D0R Guidelines and NUREG-0588 as applied at the time the final rule is published, with additional supplementary material to reflect acceptable technical advances in this area. 3. PROCEDURAL APPROACH Rulemaking has been mandated by the Commission in its Memorandum and Order cited above. 4. STATUTORY CONSIDERATIONS 4.1 URC 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. 4.2 Need for NEPA Assessment The proposed action does not require an environmental impact statement 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 are foreseen. 6.

SUMMARY

AND CONCLUSIONS This rulemaking mandated by the Commission should be initiated immediately and conducted in a timely manner. 4 Enclosure B Version 4

NRC PROPOSES RULEMAKING ON ENVIRONMENTAL AND SEISMIC QUALIFICATION OF ELECTRIC EQUIPMENT The Nuclear Regulatory Commission is proposing a rule on Environmental and Seismic 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 and paragraph 50.55a(h) of 10 CFR Part 50. These are general require-ments stating the principle that structures, systems, and components important to safety in a nuclear power plant must be designed to accommodate the effects of environmental 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 that these general requirements are met for electric equipment. Although docu-mented in various national standards, regulatory guides, and 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 1 Enclosure C Version 4

=. -,., 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. Aggarwal, Electrical Engineering Branch, Office of Nuclear. Regulatory Research, U.S. Nuclear Ragulatory Commission, Washington, D.C. 20555, Telephone: (301)443-5946. Copies of the comments received by the Commission will be available for pu'oile inspection at the Commission's Public Document Room,1717 H Street NW., Washington, D.C. I ~2 Enclosure C Version 4

ANALYSIS WITH RESPECT TO PERIODIC..d0 SYSTEMATIC REVIEW OF REGULATIONS (TMI ACTION PLAN TASK IV.G.2)

SUBJECT:

Section 50.49 pertaining to environmental and seismic qualification of electric equipment Criteria for Periodic,and Systematic Review of Regulations NRC Compliance 1. The proposed regulations are needed. Specific envircr. mental equipment qualification methods and criteria currently rantained 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 be significant cost impact on the industry regulations have been adequately considered. because of backfit resulting from seismic and dynamic qualification. The licensees are required by the Commission's Memorandum and Order CLI-80-21 dated May 23, 1980 to meet the environmeatal requirements contained in the D0R " Guidelines for Evaluating Environmental Qualification of Class 1E Electrical Equipment in Operating Reactors," (November 1979) and NUREG-0588, " Interim Staff Position on Environ-mental Qualification of Safety-Related Electrical Equipment," which form the basis of this proposal. Conse-quently, this rule codifies existing requirements and will impose additional costs and obligations on licensees. 3. Alternative approaches have been considered Rulemaking was chosen as the least burdensome to codify and the least burdensome of the acceptable the requirements pertaining to environmental qualifica-alternatives has been chosen. tion of electric equipment. 4. Public comments have been considered and an The proposed rule will be issued for public comments. adequate response has been prepared. 1 Enclosure D Version 4

y 1 .o:

SUBJECT:

Section 50.49 pertaining to environmental and seismic 1 qualification of electric equipment Criteria for Periodic and Systematic Review of Regulations NRC Compliance l .5. 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 comply with it. 1 l 6. An estimate has been made of the new reporting There are no reporting requirements in the proposed. rule. burdens or recordkeeping requirements necessary Additional burden on applicants.with respect to recordkeep-for compliance with the regulation. ing will result from (a) requirement for a central file under the control of the applicant, and (b) expansion of the central file to' include' seismic qualification data-beyond General Design Criteria XVI of Appendix B to 10 CFR 50. 7. .The name, address, and telephone number of a The Federai 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. { l 8. A plan fc" cvaluating the regulation after . Licensee and staff experience with the regulation will be 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). l 1 2 Enclosure D Version 4 b}}

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