ML20039H107
| ML20039H107 | |
| Person / Time | |
|---|---|
| Issue date: | 01/07/1982 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8201190555 | |
| Download: ML20039H107 (19) | |
Text
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COMMISSION MEETING Zl2. tbs h of:
PUBLIC MEETING AFFIRMATION SESSION:
SECY-81-6038 - PROPOSED RULEMAKING
" ENVIRONMENTAL QUALIFICATICE OF ELECTRIC EQUIPMENT j
EUR NUCLEAR POWER PLANTS"
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January 7, 1982 PAG 23:
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1 1
UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
AFFIRMATION SESSIONS 4
SECY-81-603B - PROPOSED RULEMAKING 5
" ENVIRONMENTAL QUALIFICATION OF ELECTRIC EQUIPEENT 8
FOR NUCLEAR POWER PLANTS" 7
PUDLIC REETING 8
Nuclear Regulatory Commission Hoom 1130 8
1717 H Street, N. W.
Washington, D. C.
10 Thursday, January 7, 1982 11 The Commission met, pursuant to notice, at 3:00 p.m.
13 14 BEFORE:
15 NUNZIO PALLADINO, Chairman of the Commission i
VICTOR GILINSKY, Commissioner 18 PETER BRADFORD, Commissioner i
-JOHN AHEARNE, Commissioner i
17 THOMAS ROBERTS, Commissioner 18 ALSO PRESENT:
19 S. CHILK 20 L. BICKWIT F.
REMICK 21 22 23 24 25 ALDERSoN REPo6ENG COMPANY,INC, 400 VIRGINtA AVE., S.W., WASHINGTON. O.C. 20024 (202) 564-2346
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CHAIRNAN PALLADIN0s The meeting will please come 1
3 to order.
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This is an affirmation session.
We have one item 5 shown on the agenda.
I will ask the Secretary to present 6 the item.
7 MR. SCHILKa SECY-81-603B, Proposed Rulemaking 8 " Environmental Qualifications of Electric Equipment for 9 Nuclear Power Plants," in which the Commission is being to asked to approve criteria for the environmental 11 qualification for electrical equipment.
12 All Commissioners have approved a proposed rule, J
13 modified by your comments, which was distributed to you 14 yesterday.
The Commissioners also approved the staff 15 requirement mescrandum, and asked the NRC staff to address a 4
16 certain number of issues.
17 Commissioner Bradford had additional views to 18 which Commissioner Gilinsky agreed, a r.d they will be 19 publishad with the propose rule.
20 Mill you please affirm you; vote.
21 (Chorus of ayes.)
22 CHAIRMAN PALLADINO This completes the items in 23 the affirmation session.
Unless there is more to come 24 bef ore the Commission, the meeting stands adjourned.
25 ADERSoN REPORTING COMPANY. INC.
400 VIRGINIA AVE., S.W., WASH 6NGToN 0.C. 20024 (202) 554 2346
3 1
(Whereupon, at 3:05 p.m.,
the meeting was 2 adjourned. )
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ALDERSON REPORTING COMPANY. INC.
400 VIRONA AVE, S.W. WASHINGTON. D.C. 20024 (202) 564-2346 en-c w
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NUCMAR REGULATORY COW.ISSICN l
This is to certify that the attached ;roceedings before the Commission Meeting - Public Meeting l
t in th a mattar of:
Affirmation Session :
SECY-81-603B - Proposed Rulemaking I "Envircrmntal Qualificati(m of Electric Equipient for Nuclear Power
- Date of Proceeding: Plants" January 7, 1982 Docket flumber:
Place of Proceeding:
Washingtcm, D. C.
were held as herei:1 appears, and that this is the c,riginal :: anscript ther of for the file of the Cocsissicr..
Patricia A. Minson Official Reporter (Typed)
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Official Reporter (Signa:ure) i 4
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ic HUCLEAP, REGULATORY COMMISSION 10 CFR Part 50 Environmental Qualification of Electric Equipment for Nuclear Power Plants AGENCY:
Nuclear Regulatory Commission.
ACTION:
Proposed Rule.
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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,
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regulatory guides, and certain NRC publications for equipment qualifica-tion have been given different interpretations and have not had the legal force of an agency regulation.
The proposed rule would codi.fy these environmental,qua,lification 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.
i 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 Commissio.n's Public Document Room at 1717 H Street NW.,
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Enclosure A l
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Washing'on, D.C., between the hours of 5:30 a.m. and'4: 25 p.m. on normal t
work days.
FOR FURTHER INFORMATION CONTACT: Satish K. Aggarval, Office of Nutlear Regulatory Research, Electrical Engineering Branch, U.S. Nuclear Regula-tory Commission, Washington, D.C. 20555, Telephone (301)443-5946.
f SUPPLEMENTARY INFORMATION:
Nuclear power plant equipment important to l
safety snust be able to perform the safety functions throughout its installed life.
This requirement is embodied in General Design Criter,ia 1, I
2, 4, and 23 of Appendix A, " General Design Criteria,for Nuclear Power
~
Plants," to 10 CFR Part 50, " Domestic Licensing of Production and Uti.li-i zation Facilities"; in Criterion'III, " Design Control," and Criterion XI,
" Test Coni.rol," of Appendix B, " Quality Assurance Criteria for Nucl. ear I
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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 Prior requirements are met for electric equipment important to safety.
to 1971, qualification was based on the fact that the electric c'omponents l
were of high industrial quality.
For nuclear plants licensed to operate i
after 1971, qualification was judged on the basis of IEEE 323-1971.
For plants whose Safety Evaluation Reports were issued since July 1, 1974, th'e Commission has used Regui'atory Guide 1.89, " Qualification of Class IE IIncorporation 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.
Enclosure A 2
f 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 :epplementary 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 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 Commission d'irected the staff to proceed with a rulemaking on environ-mental qualification of. safety grade equipment and to address the ques-tion of backfit.
The 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 p~roposed rule is generally based on the requirements of the Division of Operating.
Reactors (DDR) Guidelines and NUREG-0588.
The Commissi.on's Memorandum and Order CLI-80-21 directed that the env'ironmental qualification of electric equipment in operating nuclear power plants be completed by June 30, 1982.
However, on September 23, ffg(
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Enclosure A
m CLI-80-21 and implements SECY-El-435 by incorperating the extension dates recommended by the Chairman in his memorandum dated September 30, 1981.
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" Included in :the proposed rule is a requircraent thai-each holder of.or each applicant for a license to. operate 1et-i-
- . a nuclear power plant is require _d to Mentify gnd qualify
..!4 the electric equipment needed to complete one path of...:a c
achieving and' maintaining a cold shutdown condition." m
.i 7The scope of the p5cposed rule does not include all electric e piiF ~
ment important'to safety in its various gradations of importance..
It g
7 includes that portion of equipment important to safety commonly referred u
l 5l to as " Class 1E" equipment in IEEE national standards and some additional O
non-Class 1E equipment, and systems whose failure under extreme environ,-
a E
mental conditions could' prevent the satisfactory accomplishment of safety E
functions by accident-mitigating equipment.
E 3S Included in the proposed rule are specific technical requirements f
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,$f pertaining to (a) qualification parameters, (b) qualification methods, uu
- ij s and (c) documentation.
Qualification parameters include temperature, EE pressure, humidity, radiation, chemicals, and submergence.
Qualification mo aa:
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methods include (a) testing as the principal means of qualification and E15 (b) analysis and. operating experience in lieu of testing.
The proposed a$y s
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rule would require that the qualification program include synergistic e o'l effects, aging, margins, radiation, and'environmenthi conditions.
Also,.
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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 draf t of the proposed revision is being published for public comment. concurrently with the proposed rule.
Also included in the pr6 posed rule is a requirement, which is con-sistent with Commission Memorandum and Order, CLI-80-21, for submission of an analysis by licensees to ensure that the plant can be safely operated 4
Enclosure A
t pending completion of the environmental quclification of electric equip-ment.
The Commission expects that, for each of the currently operating power plant, this analysis and its evaluation by the NRC staff will be completed well in advance of the effective date of this rule.
If the licensees of operat,ing power plants fail to provide these analyses in a timely manner, the Commission expects the NRC staff to take the hppro-priate steps to require that the information be provided and to enforce compliance with this requirement.
This requirement has been included in this proposed rule to provide a regulatory basis for enforcement.
NRC will generally not accept analysis in lieu of. testing.
Experi-ence has shown that qualification of equipment.without test data may not be adequate to demonstrate functional operability during design basis event conditions.
Analysis may be acceptable if testing of the equip-ment is impractical because of size, er limitation due to the state of the art.
The proposed rule takes into consideration the~ prior qualifi-fan E mn m. cf cation history of the operating power plants. /he proposed. rule, the n j for-e, recogriizes that for those plants which are not committed to either IEEE 323-1971 or IEEE 323-1974 for equipment qualificatior., and have -
been tested only for high temperature pressure, and steam,,ome equip-ment may not need to be tested again to include other service conditions such as radiation and chemical sprays.
The qualification ~ of equipment for these service conditions may be established by analysis.
The proposed rule would require that each holder of an operating 9
license provide a list of electric equipment previous 1 ualified bas'ed on testing or analysis, or a combination thereof, and a. list of equipment that has not been qualified.
-The unqualified equipmnt
- t t; wiifick 4tcsting or by anclys-is4ased-or. tecting, er it must be rephcedr These j
5 Enclosure A
lists and the schedule for completion of equipment, qualification would have to be submitted within 90 days after,the effective date of this rule.
However, this time period will be adjusted during the final, rule making process to allow reasonable time for licensees to evaluate NRC's safety reviews that are currently underway.
The proposed rule will codify the Commission's current requirements for the environmental qualification of electric equipment.
Upon publica-tion of a final rule, the DDR guidelines and NUREG-0588 will be withdrawn.
The general requirements for seismic and dynamic qualification for electric equipment are contained in the General Design, Criteria.
Pending development of specific requirements in this area, the general require-ments will continue to apply.
NRC is considering expansion of the. scope of this proposed rule to include additional electric 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 Offic.e 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 6
Enciosure A h
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definition of a small business found in Section 3 cf 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 DOR " 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 Eqdipment," which form the basis of this proposed rule.
Consequently, this rule codifies existing requirements and imposes no new costs or obligations on utilities.
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.
The authority citation for 10 CFR Part 50 reads as follows:
AUTHORITY:
Secs.103,104,161,182,183,189, 68 Stat'. 936, 937, 948, 953, 954, 955, 956, as amended (42 U.S.C. 2133, 2134, 2201, 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. 939 (42 U.S.C. 2152).. Sections 50.80-50.81 a.lso 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);
~
5 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.
7 Enclosure A
2.'
A new 5 50.49 is added to read as follows:
5 50.49 Environmental qualification of electric equipment for nuclear power plants.
(a)
Requirements for seismic and dynamic qualification of electric equipment are not included in this section.
-(b)
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 (c) of this section.
(c)
Electric equipment and systems covered by this section include electric equipment and systems that' are essential to' emergency reactor shutdown, containment isolation, rea: tor core cooling, and containment and reactor heat removal or that are otherwise essential' in preventing Included significaht release of radioactive material to the environment.
is equipment (1) that performs the above functions automatically, (2) tha is used by the operator to perform these functions manually, and (3) w' hose failure can prevent the satisfactory accomplishment of one or more of b
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the above safety function $s. A-pe~~,.L2i
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g ('d D he app D. wEnt or licen$see shall prep'are a list of
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equipment covered by this section and maintain it in an auditable forms.
This list of equipment must, as a minimum, include:
l (1)
The performance characteristics and structural integr.ity require-ments 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 (d)(1) of this section can be ensured.
8 Enclosure A
(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 (d)(1) and (2) of this section.
'(e) The electrical equipment qualification program must include the following:
l (1)
Temperature and Pressur_e.
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 a's 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 mu;t I
be at least as severe as that resulting from the mos: limiting mode of plant operation (e.g., containment spray, emergency core cooling, or recirculation,from containment sump).
If the composition of the chemical l
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'.
t (4)
Radiation.
The radiation environment must be based on' x
the type of radiation and the dose and dose rate of the radiation environ-ment expected during normal operation over the installed li'fe 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.
9 Enclosure A
(5)* Agihc.
Equipment qualified by test must, where practi-L J
cable, be preconditioned by natural or arti.ficial (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 equi.pment 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.
(6)
Submeraence (if subject to being submerged).
(7)
Synergistic Effects.
The preconditioning and testing of equip-ment must' consider known synergistic effects when these effects are, known to h' ave a significant effect on equipment performance.
(8)
Margins.
Margins must be applied to account for production variations and in. accuracies in test instruments.
These margins are in addition to margi,ns applied during the derivation of the environmental conditions.
(f)
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 simil'ar 1
l conditions with a supporting analysis to show that the equipment to be qualified is acceptable.
10 Enclosure A
'(4)
(i)
By analysis, in lieu of testing, where type testing is precluded by the physical size of the equipment er by the state of the art.
(ii) By analysis in combination with partial type test data which adequately supports the analytical assumptions and conclusions, where the equipment
~ -
purchase order was executed prior to May 23, 1980.
(g)
If an item of electric equipment is to be qualified by' test -
'(1)
The acceptance criteria must be established prior to testing.
f (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 (d)(1) of this section for all con'ditions as speci-fied in accordance with paragraphs (d)(2) and (3) of this section.
The test profile (e.g., pressure, temperature, radiation vs. time) must include margins as set forth in paragraph (e)(9) of this section.
(3) 'The test profile must be either (i) a single profile that-1 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 ac'ci-
-dent: and for LOCAs).
(4)
The same piece of equipment ~must be used throughout the complet~e test sequence under any given profile.
(h)
Each holder of an operating license issued p~ior to (insert the r
ef fective date of this rule) must, by (insert a date 90 days after the effective date of this rule),. identify the electric equipment already T~o 'rt" l* R O V ' S '* MS
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qualified and submit a schedule for the testi.ng or replacement of the f
A remaining electric equipment.
This schedule must establish a goal of final envirohmental qualification by the end of the second refueling 11 Enclosure A
outage after March 31, 1932.
The Director of Nuclear Reactor Regulation l
may grant requests for extensions of this deadline to a date no later.
l than November 30, 1985, for specific pieces of equipment if such requests l
l are filed on a timely basis and demonstrate good cause for the extension, such as procurement lead time, test complications, and installation problems.
In ' exceptional cases, the Commission itself may consider and grant extensions beyond November 30, 1985 for completion of environmental qualification.
(i)
Each licensee shall notify the Commission of, any significant equipment qualification problem that may require extension oY the comple-tion date within 30 days of its discovery.
(j)
For the continued operation of a nuclear plant, each holder of 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 pending completion of the environmental qualification.
The detailed arialysis for each equipment type with appropriate justification must be submitted to Director of Nuclear Reactor Regulation by (insert the effective date of the rule), and must include, where appropriate, con-sideration of:
(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 d.constrated to be fully qualified.
(2)
The validity of partial test data in support of the original qualification.
(3)
Limited use of administrative contt-ols over equipment that has not been demonstrated to be fully qualified.
12 Enclosure A
(4)
Completion of the safety function prior te exposure to the ensu-i ing accident environment and the subsequent failure of the e,quipment 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 accident environment.
(k)
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 qualification.in accordance with paragraph (j) of this section except that this analysis must be submitted to the Director of Nuclear Reactor Regulation for consideration prior to the granting of an operating license.
(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 h
a 13 Enclosure A
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