ML20039C654

Ack Receipt of & Discusses Current NRC Actions on Environ Qualification of safety-related Electrical Equipment & value-impact Analysis in Setting of New Requirements

ML20039C654
Person / Time
Issue date:	12/02/1981
From:	Palladino N NRC COMMISSION (OCM)
To:	Vandenburgh D YANKEE ATOMIC ELECTRIC CO.
Shared Package
ML20039C655	List: ML20039C654 ML20039C656
References
NUDOCS 8112300008
Download: ML20039C654 (2)

Text

.-

.e Pre 4

4 UNITED STATES

,f j,

NUCLEAR REGULATORY COMMISSION E

WASHINGTON, D. C. 20565 e

'*n,*****+

December 2,1981

.c...

.cHainauw;

. g...

g.-

+....

.v

~=-

- :-- h:-

gMr;.D. E. Vandenburgh

~ +

C' Senior Vice President

. ;-...:w. Yankee Atomi c El ec t ri c Co. - -..

'l

~

~

26 1671.~ Worcester Road

- 1.- ~

"r

. :.1. ~.Framingham, Massachusett's 01701

~-

m..,

". '. Dea r Mr. Vandenbu rg h :

.E V.

.l~ThisM s#in response to'your letter of September 14, 1981 ~

"which discusses your concern with current Commission actions 7'~~

on equipment qualification and with use of interim require-ments unsupported-by appropriate value-impact analyses.

As you.know, the background and basi's for the current staff actions on environmental qualification of safety-related electrical equipment is contained in the Commission's Memo-randum and Order, CLI-80-21, dated May 23, 1980.

This Memorandum and Order was issued when it became clear.to the Commission that resolution of the qualification issues was not receiving the attention it deserved.

Since the staff guidelines and applicable NUREG do'cument apply progressively less strict standards to older plants, the Memorandum and Order specified rulemaking as the appro-priate vehicle for determining the final qualification re-quirements.

CLI-80-21 stated that:

"If the staff proposed rule does not require plants to be upgraded to a single uniform standard along the lines of the 1974' requirements in NUREG-0588, then its justification for that position will be articulated in depth and will be subject to comment in the proceeding."

The rulemaking process is intended to assure that unnecessary requirements or changes in requirements which would unduly tax industry and NRC resources would not be issued and that s

all alternative means to' achieve safety objectives be given full consideration.

. You have pointed out the'iinp'ortanceJo'f value-impact anaiysis c

.. in the sett.ing of..new requirements.-

It is our view that d-

'. consideration of 6 costs -is. always appropriate in deciding' 2..-

~

.y

....._f.[amo_ng alternatiye5methodsj forf achieving a given. level of E,(

..;g.

E.. ' M ': '

~L';[_ ' % a-ff-]@FG 2

^*

n

3. - :

.=;. _

8112300008 811202 PDR COMMS NRCC 3.

CORRESPONDENCE PDR *^'

e. g.,..

~

..L.t y " _

.2

7Lt.:

"_g_

d U

~ <

E._, D. Y eN -

7 2

safety.

These factors are being considered and will be applied in the ongoing rulemaking on equipment qualifica-tion.

We intend to allow licensees sufficient time for in-depth engineering, design, and procurement of high quality equipment and for proper installation, compatible with operational schedules to the extent possible in view of public health and safety considerations.

Finally, you expressed concern about the overall impl emen-tation of seismic,. dynamic and environmental qualification of safety-related electrical and mechanical equipment.

In establishing the proposed and the final requirements in this area the Staff will develop a value-impact assessment and will provide an estim' ate of the potential risk reduction that can be obtained from implementation of the requirements.

~~These assessments will be evaluated by the Commission during our del.iberations on the requirements.

n Sincerely, jfNh Y

Nunzio J. Palladino b

e i

e e

m