ML20039G677

Submits Agenda for 820107 Meeting.Reg Guide 1.68.3,proposed Equipment Qualification Rule & Response to Emergencies Will Be Briefing & Discussion Topics.Documents Encl

ML20039G677
Person / Time
Issue date:	12/21/1981
From:	Stello V Committee To Review Generic Requirements
To:	Eisenhut D, Jordan E, Mausshardt D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS), Office of Nuclear Reactor Regulation
Shared Package
ML20039G678	List: ML20039G677 ML20039G683
References
RTR-REGGD-01.068.03, RTR-REGGD-1.068.03 NUDOCS 8201180620
Download: ML20039G677 (6)

Text

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MEMORANDUM FOR: Darrell G. Eisenhut NRR Edward L. Jordan IE P

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Donald B. Mausshardt. NMSS t

i Robert M. Bernero, RES i

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Victor Stello, Jr., Chairman Comittee to Review Generic Requirements

SUBJECT:

CRGR MEETING NU!EER 5 The Comittee to Review Generic Requirements will meet on Thursday, January 7,1982, from 1-5 pm in Room 6507 telBB. The meeting agenda is as follows:

1.

Regulatory Guide 1.68.3 Briefing - Preoperation Testing of Instrument and Control Air Systems. This Regulatory Guide was sent to my office for concurrence prior to final printing and distribution (Enclosure 1). I have asked Robert Minogue, Director of Research, to have his staff brief the CRGR regarding Reg. Guide 1.68.3 (1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />).

2.

Equipment Qualification Briefing - The Comission is considering the proposed Equipment Qualification Rule.

In this regard, I have asked the Office Directors involved with the proposed rule to brief the CRGR on this topic (Enclosures 2 & 3) (1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />).

3 Continuation of Emergency Response Discussions - During the last CRGR meeting, the Comittee continued discussion of the previous meeting on the topic of " Facilities, Equipment and Procedures to Cope with Emergencies in Nuclear Power Plants." Ed Blackwood of the DEDROGR staff discussed the initial findings of a Task Force review of flRC's requirements in this area. The Comittee decided that it will seek coments from the Program Offices after the Task Force refines the proposed requirements. The DEDROGR staff is drafting an integrated plan for further EDO actions. These are to be discussed. As soon as the DECROGR staff completes its work but prior to the meeting, I will forward some information to you regarding this subject (1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />).

4 The CRGR will discuss and develop itsrrecommendations in a closed session. (1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />).

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' ' ' !#dI CRGR Members With regard to attendance at CRGR meetings, I believe that having 25-30 senior level staff in attendance is unnecessary and unproductive. By copy of this memo, I am requesting the Office Directors to limit attendance of their staffs at CRGR meetings to those few senior staff needed to address the agenda item under discussion.

In addition, the time set aside for the CRGR to discuss and develop its recommendations will be closed to all but CRGR members and invited participants.

Origi::a1 signed by ygg steller Victor Stello, Jr., Chairman Committee to Review Generic Requirements

Enclosures:

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U.S. NUCLEAR REGULATORY CO,MMISSION. -

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REGULATORY GUIDE 1.68.3 (Task RS 709 4)

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PREOPERATIONAL TESTING OF INSTRUMENT AND CONTROL AIR SYSTEMS g

3 A. INTRODUCTION Because of the diversity orI5 ads nor=&Uy supplied, there is a possibility for unsafe interactions.Thetsfore,it is impor-General Design Criterion 1, " Quality Standards and tant that testing be done toverify proper functioning during !

Records," of Appendix A, " General Design Criteria for normal operation and to determine the effects of totalloss, l

Nudear Power Plants," to 10 CFR Part 50, " Domestic reduction, orincrease of the pressu c within the entire inst:u- ;

Licensing of Production and Utilization Facilities," requires ment and control air distribution system and portions thereof.

that structures, systems, and components important to safety be tested to quality standards commensurate with It is essential that testing verify that the system will the importance of the safety functions to be performed.

respond appropriately to both normal operation of the Criterion XI, " Test Control," of Appendix B, " Quality plant and upset, faulted, or emergency conditions with Assurance Criteria for Nudear Power Plants and Fuel consideration being given to (1) complete and sudden loss of Reprocessing Plants," to 10 CFR Part 50 requires that a pressure resulting from such postulated events as inadver-test program be established to ensure that a!! testing, tent valve operation in the supply system, severance of a induding preoperational testing, required to demonstrate system pipe, loss of offsite electric power, loss of d.c.

that structures, systems, and components will perform power, and component malfunction;(2) partial or gradual satisfactorily in service is identified and performed. Instru-loss of system pressure to the entire distribution system or ment and control air systems supply pressurired air to portions thereof resulting from such events; and (3) increases operate various loads, induding components and systems in pressure due to component malfunction or failure.

that are required to perform functionsimportant to safety.

This guide, which replaces Regulatory Guide 1.80, describes Air operated valves and other air operated components are a method acceptable to the NRC staff for complying with norinally designed to respond in a given exu=er, Le., fail open, the Commmion's regulations with respect to preoperational fail dosed, or fail as is, if the mstrument and control air testing to verify that instrument and control air systems' supply is lost or its pressure is reduced orincreased. Ve-ifica-and the loads they supply will operat properly at normal tion of system response to a Icstof air pressure event is an system pressures and to gnsure the operability of functions essential part of testing at the preoperationalstage, at which important to safety in the event that system pressure is lost, time it can be accomplished with a muumum risk to power reduced belotr normal operating level, or increased above plant equipment and personnel. Testing' also provides a the design pressure of the system components.

means for determming the adequacy of operating and emergency procedures for coping with a loss of air supply.

B. DISCUSSION Preoperational testing of the in:trument and ccctrol air Instrument and control air systems typically furmsh system following construction of the pisnt and insta!!ation presmrized air to a wide variety of equfpment in nuclear of the in:trument and control air eystem will help ensure power plants. The extent to which such air systems are used that the air supply equipment (co:aptessors and associ-varies with different designs of both the nuclear and the ated controls and backup air suppliu) and the equipment balance-cf plant portions of the facility, provided to maintain the quality of air supplied (e.g., filters and dryers) will function withm design requirements.

I The recommendaticas of this guide a5ould also be applied to-(1) compressed saa systema that, although not desasnated as instro-

- The applicant is responsible for developing a suitable ment and control mar systems, supply loads that could arfect the overall safety aad artnance of the plant. (2) compressed gas preoperational test program for the instrument and control fo"s2tv aOT[)IystemaYp tossh $ a cam air system. This indudes preparing adequate procedures for P

a same other than air.

carrymg out the program, properly conducting the preopera-USNRC REGut.ATORY GUIDE.5 Comments snould be sent to tne Secretary of the Comenission.

U.S. Nuclear R egulat ory Commiss6on. Wasnington, D.C. 2055s.

Regulato*y Guides are issued to describe and make available to the Attentions Docketing and Serv 6ce Branca.

puoisc metmoos acceptacle to the N RC staff of Im o so m en ting toecific parts of tne CommissJon s regulations. to coonsate tecn-Ttie guides are issued in tfie following ten broad divesJonsa a

nioues used oy the staff an evaluating soectfic problems or costu-lated accioents or to provice guidance to apoi6 cants. Regulatory

1. Power Reectors

6. Products i

G ulc es are nel suestitutes for regulations, and compilance witn

2. nosearcn and Test Reactots

7. Transportation i

enem is not recurred. Methods and so*utions different from those set-

3. Fue*s and Materials Facalities

8. CCCucational >+ earth out in the guices will be acceptanae if tney previos a nanas for tne 4 Environmented and Siting

9. Antitrust and Financial Review findings requisite to the issuance or contJnuance of a permit of S. Materials and Ptant Protection lo. General license ey the Commessson.

Cooles of issued guides may be ourchased at the current Govemment This gulos was issued after consJderation of comments received from Printing Off 6ce oreca. A sucscription service for future guaces in soe-tne oubelt. Comments and suggestions for improvements in toese cific civisions is avaslable tnrougn the Government Printing office.

. gusces are encouraeed at all 16mes, and guides will be revised, as information on the sucscription service and current GPO ofices may acproortate, to accommocate comments and to toflect new informe=

be ottained by wetting the U.S. NucJear Rogulatory Commission, tion or escor6ence.

Wannington, D.C. 2e5 55. Attentions Pubi6 cations Sales Manager.

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l eonai issts, and estabu ing.e v day of *e test,s.as son of),oreans of.e sacmty im-t to afety,es,o.d by adequate review and approval.

in accordanos wie dessa to a loss of air pressue.Tesdag should be =m==tly comprehensve to determine the l

C. REGULATORY POSITION response of loads to complete loss of system pressue, both

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sudden and gradual, and to partial reductions in system As part of the initial preoperational testing program and pressure. The tests should verify the adequacy of design j

also after major modafications or repairs to the instrument roquartments relating to system pressues at which applied l

and control air system or portions thereof (e4 where loads changs state (e.g., fag open, fait closed, fa5 asis, faR j

air Gow rate requirements are significantly altered or upscals, faR downscals, or faa to perform other regered j

where opened systems are abject to conaraine ), the functions). Testing should also verify that the bacimp n

i rystem and loads should be, tested as described below to supplies for the protected loads supplied by the system, J

verify that aR components function propedy at normal e.g, accunulators and bacinap bottled gas mapplies, wlR j

presmres and following possible pressare ic:reases and that mairhis =mmat air pressure to permit these loads to l

the systens resped as designed to aloss of-air pressare event.

Perforn, their design function.

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1. The test program for the instrument and coneot air As part of the above testing, loss of-sar napply tests should system and associated equipment should include the be conducted on aR branches of the instrument and control applicable prerequisite checks, verifications, and' tests air system simultaneously, if practicable, or on t'he largest provided in Section'C.2 of Regulatory Guide 1.68, " Initial number of branches of the system that can be adequately Test Programs for Water-Cooled Nuclear l'ower Plants."

--4 For each test, the valves to be tested should be placed in their normal operating position, and the rest of

2. Compressors, aftercoolers, og separator units, air the plaza should be mainuined in as c!ces to normal ceditions

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receivers, and pressure-reducing stations should_be tested to _ as is practicable. (It should be noted that not an valves can j

verify proper operatics: according to system design _. The_ opera-be placed in the aquired normal operating position because l

_ tion of compressor unloaders, autonatic and manualstart and of operating procedure requirements or persoccel or equip-j stop gircuits of standby compressors, high and low-pressure ment safety factors.) The foDowing tests should ba performed:

d alarms, pressure indicators, and temperature indicators j

should be checked. Relief valve settings should be renfied,

s. Shut off the instrument and control air system in a manner that would simulate a sudden air pipe break and

3. Air dryer units should be tested for proper function-verify that the affected components respond property.

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ing, and the units should be operated through at least one 1

regeneration cycle. Acceptable operation at maximum flow

b. Repeat test a., but shut the instrument ad cortrol air rates should be verified. The appropriate differential system off very slowly to simulate a graduallos of preanus.

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pressures and proper operation of pressure switches, high-i i

and low-pressure alarms, safety and relief valves, bypass

9. Tests should be conducted, as appropriate, to demon-l valves, and alarms and resets should be verified.

strate that plant equipment designated by design to be nap

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plied by the instrument and control air system is not being [

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4. It should be veriCed by test that the instrument and napplied by other compressed air supplies (such as service

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l control air system win meet specifications relating to Dow, air) that may have less restrictree air quality requirements.

pressum, and temperature of the product air.

10. Plant components requiring large quantities of

5. It should be established by appropriate measurements instrument and control air for operation (such as large valve

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or observations that the total air demand at normal steady-operators) should be operated simultaneously while the l state conditions, including leakage from4he system, is in system is operating at normal steady-state conditions k accordance with design.

(unless it can be shown that simultaneous operation is prohibited by interlock or appropriate procedure) to verify j

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6. The ability of the system to meet the quality require-that pressure transients in the distribution system do not 1

7 ments of ANSI /ISA S7.3-1975, " Quality Standard for exceed acceptable values.

Instrument Air,"' with respect to oil, water,and particulate j

I matter contained in the product air should be vertfied by

11. Functional testing of instrument and control air analyzing the air at the end of each feederline using con-

_ systems important to safety should be performed to ensure i

tinuous flow techniques or by analyzmg a discrete sample, that credible failums resulting in an increase in the apply,

I system pressure win not cause peak transient pressures

7. When redundant components and air napplies are above the design pressure of the system components.,

provided in the facility design to meet the single-failure i

criterion for a given safety function,it should be verified by D. IMPI.EMENTATION

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test that the single-failure criterion is met.

Except in (hose 1:ases in which an,[ applicant p j

8. It should be veriGed by tests that the air operated or acmptable'altersatiire method for complying with spened

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air-powered loads that are a part of (or support the opera-portions' f'the' Commiwien's regulations'the method de in thIis guide will be usediir!'The evaluatid/

appUutionW cperating ucesses me iveda@une 1,

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VALUE/ IMPACT STATEMENT BACKGROUND.

for peak loads and increased leakass that may occur as the system is used.

Regulatory Guide 1.80 provides methods for preopere-tional testing of instrument air systems to enmare that the Impact - Although not specificany mentioned, it has instrument air systems and components as densned and been the latent that the tests caBed for in this poetica be installed win function property and that they are free from accomp!!shed. The position is stated explicitly to improve fomaan matter that could cause malfunctions durzng opera-guidance. For those plants that were not already obtmams tion. De guide also contains provisons for tests to d' mon-the information, the impact should be minimal as the data e

strate that the systems win respond as expected to a losspot.

can be obtained by normal system observations and ample instrument-sir accident. '

maassementa.

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Erperience in using the guide has shown that there have

.J. Regulatory Position 9, which cans for tests, measuo-been problems in applying the guide where there is a relation-ments, and observations to be conducted,to demonstrate ship between the instrument air system and the control air that air supp!!as such as the service air supply are not synem. Therefore, the scope of Regulatory Guide 1.80 was inadvertently. tied into the instrument and control air expankd to include the control air system because of the systems, was added.

pwhnity that it may be asoc2ated with systems important l

fo sdcty. However, the expanded guide is being issued as Value - De tests caHed for in this position wCI demon-1 j

Regulatory Guide 1.68.3 in order to group it with other strate that air systems with poor quality air are not inadver-I j

guides in the initial test program subseries, and Regulatory tently tied into the systems that supply air to loads that are 1

Guide 1.80 is being withdrawn.

important to safety. Since air systems are generally field

-j run, verification of independence by test is esential j

VALUE/ IMPACT l

Impact -The impact will be minimal The demonstration

1. The scope of the guide has been expanded toinclude

.that there are no crossties from the service air system can

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control air systems as weD as instrument air systema, be accomplished by cutting off the instrument and control air source with an other air systems under pressure and 1

Value - his change will make it clear that snme testing showing that no air is being introduced into the system.

I is needed for an instrument and control air systems. Some j

applicants have taken the posicion that their plants are so 4: Regulatory Position 10, which states that plant j

designed that failure of the instrument air system (i.e.,

components requiring large quantitiet of air for operation total loss of pressum) win cause no safety problems. The should be operated simultanecusly toertahsh that pressure instrument airsystem of these plants has not been designated trannents created by such operation do not exceed accept-i as important to safety and therefon, by thislogic, Regula-able values, was added.

l tory Guide 1.80 is not s'pplicable. This argument ignores I

the fact that, although loss of system pressure may not be Value - This test wiB demonstrate that the maximum j

serious, malfunction of the air system (e.g., introduction of operating transients on the system are within limits that i

dirt, cil, or moisture also addressed by Regulatory Guide will not adversely affect the operation of loads that are 1.80) could lead to failure of loads that are important to important to safety.

safety. The revised guide makes it clear that the testing,

Impact - There should be mmimal impact since the test.

applies to 4R air systems that supply air to loads that are j

important to safety.

can be run by simple operational proceduas and data

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observations.

Impeer - There may be some impact if applicants have

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not been testing because their systems have beenidentified

5. He regulatory position that provided for a test of the

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by names different from those used in the guide. However, loss of air with valves placed in other than the failed posi-the staff position has always been that systems important tion was deleted.

to safety should be tested to demonstrate proper operation i

and to enmre that the functioning ciloads fraportant to Value - An unnecessary system test was deleted. The i

safety is not jeopardized by failure of associated systems, response of components to a loss of or pressure (when the valves are placed in a position other than the failed position)

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2. Regulatory Position 5, which caEs ferenfication by can be verified, where required, on anindividual component l

testa that the total air demand at normal steady-state

basis, j

conditions, including leakage from the system,is in accord-ance with design, was added.

Impeer - There is no impact since no new position is

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imposed.-

Value - ne tests caHed for by this provision will verify actual air demands so that air supply capacity can be

6. The regulatory position calling for the test results to l

verified as adequate with the necessary mar 2n to account be included in the startup report was deleted.

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g VsJue - An unnecessary reporting provisios waa removed, trsasient presstres cbon the % sign prture of the Jyste:S This provision was inappropriate since preoperational components, was added.

testing pncedes the startup test prognm.The test results should be retained as part of the plant historical acord.

Value - Operating experience (e.g., PSgrun) has shown that prvssure transients above the design pressue of some components can cause those components to znalfunction, Impser - There is no impact since no new posinon is which could cause taufe conditions to exist.

s imposed.

Impser - There should be minimal impact. Mditiond

7. Regulatory Position 11, which provides for functional testing win be required. However, the test wtup shouM be ~

testing to ensure that credible faDures resulting in an no diffennt from that needed to conduct the to. eof pressure increase in the supply system passare wC1 not cause peak tests, hence increased. test tims wou:.1 be the only factor.

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.f UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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MEMORANDUM FOR: Harold Denton, Director s

Office of Nuclear Reactor Regulation; Richard DeYoung, Director Office of Inspection and Enforcement Robert Minogue, Director Office of. Nuclear Regulatory Research FROM:

Victor Stello, Jr.

Deputy Executive Director

• Regional Operations and Generic Requirements

$UBJECT:

E0.UIPMENT QUALIFICATION RULEMAKING The enclosed letter from Chairman Palladino to Mr. Vandenburgh of Yankee

. Atomic Electric Company notes that the proposed requirements in the area of Equipment Qualification will include a value-impact assessment and will provide an estimate of the potential risk reduction that can be obtained from implementation of the requirements.

In your plans for developing the proposed Equipment Qualification Rule, you should plan on submitting the Rule to the CRGR for review. We are scheduling a briefing for the CRGR on this topic for Thursday, January 7, 1982.

Please have representatives from your offices coordinate a briefing on the background, plans and schedules for developing the Equipment Qualification Rule.

Victor S llo rN Deputy Executive Director Regional Operations and Generic Requirements

Enclosure:

As stated cc:

W. Dircks CRGR Members I

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December 2 1981 CHAIRMAN *

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Dear Mr. Vandenburgh:

'This is.in response to your letter of September 14, 1981' which discusses your concern with current commission actions on ecuionant q"e14#4 cation and with use of interim reouire-ments unsupported by aooropriate 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 cle'ar to the Commission that resolution of the qualification issues was not receivi.ng the atten tion it deserved.

Since the staff ' guidelines and applicable NUREG do'cubent apply progress'ively 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 i

the lines of the~'1974' requirements in NUREG-0586 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 all alternative means tosachieve sa'ety objectives be given fu'll consideration.

You have pointed out the importance-of value-impact anaiysis.

.[1-in the setting of.new requirements.

It is our view that.= - 10. --M.-; '.

' consideration o'f costs-is,always appropriate in deciding P..

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safety.

These factors are being considered and will be applied in the ongoing rulem~aking 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 safe.ty consideratioris.

Finally, you expr'essed concern about the overall implemen-tation of seismic, dynamic and environmental qualification of safety-related electrical and mechanical equ.ipment.

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

These assessments will be evaluated by the Commission during

• our deliberations on the requirements.

Sincerely, Original Signed b'y Victor Cinany Nunzio J. Palladino Distribution:

W. Dircks

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E. Cornell T. Rehm H. Shapar R. Minogue E. Case H. Denton PPAS.

R. Vollmer W. Johnston Z. Rosztozcy D. Reiff~

Glessf'W.ith all Cmrs' Offi?es by SECY C/R:

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.29 R. Mattson T. Murleyv B. Snyder H. Berkson S. Cavanaug'h EDO 10877 M. Bridgers ED0 10877 L. Miller D. Eisenhut S. Hanauer Originating Office:,ED0/NRR

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