ML20049A726
| ML20049A726 | |
| Person / Time | |
|---|---|
| Issue date: | 09/10/1981 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | Advisory Committee on Reactor Safeguards |
| References | |
| ACRS-1883, NUDOCS 8110010461 | |
| Download: ML20049A726 (12) | |
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Q SUBCOMMITTEE ON ELECTRICAL SYSTEMS JULY 22, 1981
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The ACRS Subcommittee on Electrical Systems held a meeting on July 22, 1981 in Room 762, 1717 H St., NW, Washington, D.C.
The purpose of the meeting was to review and comment on a proposed rule " Environmental and Seismic Qualification of Electric Equipment Important to Safety for Nuclear Power Plants" and the proposed Revision 1 to Regulatory Guide " Environmental Qualification of Electric Equipment Important to Safety for Light-Water-Cooled Nuclear Power Plants". Notice of this meeting was published in the Federal Register on Wednesday July 8,1981. A copy of this notice is in-cluded as Attachment A.
A list of attendees for this meeting is included as Attachment B, the schedule for the meeting is included as Attachment C, and a list of all reference material for this meeting is included as Attach-ment D.
A complete set of handouts has been included in the ACRS files.
The meeting began at 2:00 p.m. with a short executive session open to the public in which Dr. Kerr, the Subcommittee Chairman, summarized the ob-jectives for the day's meeting. The meeting was adjourned at 6:20 p.m.
The meetin'g was conducted entirely in open session.
The Subcommittee heard presentations from the NRC Staff and from a representative of Westinghouse.
8110010461 810910 PDR ACRS 1883 PDR
i 2-NRC Staff Presentation of the Proposed Rule and Reg. Guide Revision:
Prior to this Subcommittee meeting the Commissioners directed the Staff to proceed with developing a rule on the environmental qualification of safety-grade equipment and to address the question of backfit.
The NRC Staff presented to the Subcommittee their proposed rule and regu-latory guide on the environmental and seismic qualification of electric equipment important to safety. The Staff stated that specific quali'ication methods currently contained in national standards, regulatory suides, and certain NRC pu'blications for equipment qualification have been given different The interpretations and have not had the legal force of an agency regulation.
proposed rule would codify these qualification methods and clarify the Com-mission's requirements in this area. The proposed rule addresses backfit and is generally based on the requirements of DOR guidelines and NUREG-0588.
These documents currently promulgate the requirements which must be met by licensees and applicants. The technical areas addressed by the rule include:
(a) testing as the principal means of qualification (b) use of analysis and operating experience in lieu of testing, (c) ongoing qualification, (d) accelerated aging, (e) synergistic effects, (f) test parameter envelopes, (g) source terms, (h) margins, (i) documentation, and (j) backfit requirements.
Regulatory Guide 1.89 is being revised to describe methods acceptable to the NRC Staff for meeting the provisions of the rule; a draft of the proposed re-vision will be published for public comment concurrently with the proposed rule.
Upon publication of a final rule, the D0R guidelines and NUREG-0588 will be with-
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5 P As part of their presentation, tts. Staff made the following points:
a.
The Staff knows of no technical issues requiring resolution prior to issuance of the Rule or Regulatory Guide.
b.
The Staff considers Class IE electrical equipment to be a subset of equipment "important to plant safety".
The Staff clarified the definition of a mild environment (see c.
proposed Reg. Guide 1.89, Section C.4.2, p.11).
Equi pmeni lo-cated in a mild environment is not required to be qualified by test. A mild environment is an environment that at no time is more severe than the environment thdt would occur during normal power plant operation or during anticipated operational occur-rences.
d.
The Staff stated that there was no impact on industry due to backfit as the requirements treated in the proposed rule were already in force under a Commission order. This statement was later disputed by Mr. Gallagher of Westinghouse.
He used NRC documentation to show that equipment "important to safety" in-cluded both safety snd non-safety grade' equipment (see Attachment A). He further stated that systems affected by the proposed rule would include virtually 1.11 of tne electrical systems in the plant. Presently and under the proposed rule, the specific list of systems "important to safety" will be determined by the utility
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and N"4 jointly. This list can vary considerably using the pro-posed rule. Dr. Rosztoczy (NRC Staff, EQB) contends that the proposed rule is intended to include only a small class of equipment beyond that which is now treated as safety-grade equipment.
The Staff agreed to modify the text of the proposed rule to clarify its scope.
Subcommittee Comments and
Conclusions:
The Subcommittee discussed the proposed rule and the regulatory guide.
1.
The Subcommittee recommended that there should be a systematic evalu-ation of all plant systems to determine what environmental quali-fications are necessary.
Particular ettention should be given to those systems which have not been categorized as safety-grade but which can significantly affect the risk associated with the operation of a nuclear plant.
2.
The Subcommittee recommended that the value impact evaluation be improved. The evaluation should address the impact on industry of the proposed rule and the regulatory guide revision.
It appears that compliance with the proposed NRC guidelines aill result in subs *.antial costs. A clear case for the need for and safety benefits of thi.s additional regulation has not been presented. The Subcommittee suggested that the NRC Staff should consider using risk assessment in evaluating the value and the impact of the proposed regulation.
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3.
The Subcommittee recommended that clear guidelines as to what systems 1
and equipment require e.vtronmental qualification should be formul ated. The criteria in the proposed rule and regulatory guide are intended to be applied to " equipment important to safety".
A senior NRC Staff member stated that tnis is not intended to apply to a very much larger class of equipment beyond what is currently classified as " safety-grade".
(Other NRC Staff members in attendance did not dispute this statement). The definition of the "e,quipment important to safety" given in the proposed rule could be interpreted as applying to a much larger class of equipment.
4.
The Subcommittee recommended that the need for and usefulness of the proposed requirements for maintaining an extensive central file of qualification records be reexamined from a cost-benefit perspective.
5.
The Subcommittee made numerous comments to the Staff regarding the wording and content of the proposed rule and regulatory guide.
An inf,ormal compilation of these comments was to be provided to the Staff af ter the meeting.
6.
The proposed rule and regulatory guide are scheduled to be discussed by the. Subcommittee chairman at the August full ACRS meeting. ACRS
. comments from that meeting will be combincJ with those from the
' Subcommittee meeting.
ACRS comments on the proposed rule and regu-latory guide will be provided to the Staff by letter through Mr.
Dircks, the Executive Director for Operations.
a-6-
The meeting was adjourned at approximately 6:20 p.m.
- ,2, NOTE: For additional details, a complete transcript of the meeting is avail-able in the NRC Public Document Room,1717 H St., NW, Washington, D.C.
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% alluim G. Walston. d.b.a. Karl Plaza 2 p.m. until the conclusion of business.
Ite entire meeting wi!! be open to j {
l Phntmacy. Doch et No. 80-32. 45 FR During the initial portion of the pubhc attendance except for those g I 82 r.1) Arcordmely. pursuant to the meeting. the Subcommittec. cleag with sesens which wi!! be closed to profet t authonty vested in the Attorney General any of its consultants who may be proprietary information (Sunshine Act l
by Sectrons 303 and 304 of the present. will exchange preliminary Exemption 4) One or more closed i
Controlled Substances Act.21 U.S.C.823 views regardmg matters to be sessions may be necessary to discuss i
and a:4. and redelegated to the considered donng the balance of the such information. To the extent 1
practicable. these closed sedions will l
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Administrator of the Drug Enforcement meeting.
Administration. 6t is the Administrator's The Subcommittee will then hear be held so es to minimize inconvenience decision and order that Certificate of presentations by and hold discussiens to members of the pubhc in attendance.
Remstration AW7513408. issued to with representatives of the NRC Staff.
The a;rnda for subiect meeting shall j
Wouciield Drugs. Inc. t/a Crest,
their consultants, and other micrested be as follows: Tuesday. July 21,1931 Pharmacy be. and hereby is tes oned, persons regarding thL review.
8 30 a.rn until the conclusien of effectise july 9.1981.
Further information regarding topics business.
g to M Oscussd wh. der de mc@g During the initial portion of the Dated luly 1.1981.
een cancM e redhM da meeting. the Subcommittee, along with as
't Peter B. Bensinger.
Chairman s ru!ing on requests for the any of its consultants who may be opportunity to present oral statements in om suwa rw v.r-ei e4s.*8 and the time a!!otted thercfor can be present, will exchange prehminary I
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obtained by a prepaid telephone call to views regarding matters to be 1
considere i ounng the balance of the
__.- the cognizant Designated Federal
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Employee. Dr. Richard Savio (telephone The Subs.ummittee will then hear j
NUCLEAR REGULATORY 202/634-3267) between 8.15 a.m. and presentations by end hold discussions COMMISSION SSO p.m.. EDT.
I a ed e ne accord nee with th pr entative f th n
and Advisory Committee on Reactor consultrats, and other interested Advisory Committee Act. that it may be ectr calS stems;M eting necessary to close portions of this Persons regarding this review.
The ACRS Subcommittee on Electrical meeting to public attendance to protect Further information regarding topics q
to be discussed. whether the meetmg Systems will hold a meeting on July 22, proprietary information. The authority l
1981. Raom 1167, at 1717 H Street. NW, for such closure is Exemption (4) to the has beca cancelled or rescheduled the g
Washmgton. DC to discuss the proposed Sunshine Act. 5 U.S.C. 552b(c][4).
Chairman's ruling on requests for the rulemakmg. Section 50 49 of 10 CFR Part opportunity to present oral statements Dated. july 1.1981.
and the time allotted therefor can be 50 " Environmental and Seismic Qualification of Electric Equipment John C Hoyle.
obtained by a prepaid telephone ca!! to l
Important to Safety far Nuclear Power A dvisory Committee. Management Officer.
the cognizant Staff Engineer.Mr. David Plants" and the proposed Revision 1 to in om ei.:xw rw r.r-ei a-
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PROPOSED AGENDA ELECTRICAL SYSTEMS SUBCOMMITTEE JULY 22, 1981 1
2:00 2':15 1.
EXECUTIVE SESSION 15 MIN 1
2:15 3:30 2.
PRESENTATIONS BY THE NRC STAFF 75 MIN 3.
PRESENTATIONS BY MEMBER OF THE.Pustic 60 MIN 3:30-4:30 AND INDUSTRY AS REQUESTED 4.
SuBc0MMITTEE COMMENTS AND CONCLUSIONS 30 MIN
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ATT Atuht4T C l
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ELECTRICAL SYSTEMS SUBCOMMITTEE JULY 22,1981 REFERENCE MATERIAL l.
R. Minougue memo to' R. Fraley dated June 17, 1981 re environmental qualification of electrical equipment.
l ATTAC fENT D
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