ML20052E762
| ML20052E762 | |
| Person / Time | |
|---|---|
| Issue date: | 04/16/1982 |
| From: | Minogue R NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | Fraley R Advisory Committee on Reactor Safeguards |
| Shared Package | |
| ML20052E757 | List: |
| References | |
| IEB-79-01B, IEB-79-1B, NUDOCS 8205110419 | |
| Download: ML20052E762 (55) | |
Text
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p Kalp UNITED STATES
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NUCLEAR REGULATORY COMMisslON
{
g WASHINGTON, D. C. 20555 E
APR 161982 MEMORANDUM FOR:
Raymond F. Fraley,, Executive Director -
Advisory Committee on Reactor Safeguards FROM:
Robert B. Minogue, Director Office of Nuclear Regulatory Research
SUBJECT:
FINAL RULE, SECTION 50.49 0F 10 CFR PART 50 " ENVIRONMENTAL QUALIFICATION OF ELECTRIC EQUIPMENT FOR NUCLEAR POWER PLANTS
'l Enclosed for the Subcommittee on " Qualification Program for Safety-Related Equipment"are 20 copies of the subject final rule (Enclosure 1).
The proposed rule was published in the Federal Register on January 20, 1982 for public comments. The Commission has received 69 letters of public comments.
The resolution of these public comments is also enclosed (Enclosure 2).
This transmittal provides the subcommittee an opportunity to comment on the final rule.
As discussed with your staff, we plan to meet with the Subcommittee on
" Qualification Program for Safety-Related Equipment" on May 5 and the ACRS on May 7,1982.
0 J
RohettB.Minogue, Director Office of Nuclear Regulatory Research
Enclosures:
1.
Section 50.49 of 10 CFR Part 50 2.
Analyses of Public Comments cc:
W. J. Dircks H. R. Denton D. F. Ross Q
R. J. Mattson
,, p, i.
D. G. Eisenhut
@ QB R. H. Vollmer G. A. Arlotto W. V. Johnston
[tFDR09R NO.
O-#/m -
l$
erson Z. Rosztoczy B. D. Liaw J. Roe G. Zech E. Abbott D. F. Sullivan S. K. Aggarwal 1
8205110419 820507 PDR REVGP NRCCR
, [7590-01]
ENCLOSURE 1 NUCLEAR REGULATORY COMMISSION r
?
10 CFR Part 50 Environmental Qualification of Electric Equipment for Nuclear Power Plants AGENCY:
Nuclear Regulatory Commission.
ACTION:
Preposed Final Rule.
SUMMARY
The Nuclear Regulatory Commission is preposing to amending its regulations applicable to nuclear power plants to clarify and strengthen the criteria for environmental qualification of electric equipment.
Spe-cific qualification methods currently contained in national standards, 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.
This amendment will The p, reposed raie would codify these environmental qualification methods and clarify the Commission's requirements in this area.
EFFECTIVE DATE:
[UPON publication in the Federal Register]
SATES:
Eemment period expires (60 days after pubiication in the FedersiRegister):
Eemments received after ------------ wili be censidered 4f it is practicai to de so-but asserance of censideration cannet be given-except as to comments received en er before this dater -
ABERESSES: Written cemments and suggestiens may be maiied te the Secretary of the Ecemissien; Attention: Secketing and Service Branchi 1
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s 8:S: Neciear Regeistery Eemmission; Washingten; B:E: 26555; er hand-deiivered to the Eemmission s Pebiie Becement Room at 1717 H Street 2
NW:-- Washington;- 2:6:7 between the hours of 8:30 arm; and 4:45 p m: on normal work days:
FOR FURTHER INFORMATION CONTACT:
Satish K. Aggarwal, Office of Nuclear Regulatory Research, Eiectricai Engineering Branch; U.S. Nuclear Regula-tory Commission, Washington, D.C. 20555, Telephone (301)443-5946.
SUPPLEMENTARY INFORMATION:
On January 20, 1982, NRC published in the Federal Register (47FR2876) for public comment a proposed rule on environ-mental cualification of electric ecuioment for nuclear power plants.
This effective rule incorporates the resolution of oublic comments, which were received in resconse to the proposed rule.
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 0,esign Criteria for Nuclear Pcwer Plants," to 10 CFR Part 50, " Domestic Licensing of Production and Utilization 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,l'2 " Criteria for Protection Systems for Nuclear Power Generating Stations." This requirement is applicable to equipment located inside as well as outside the containment.
lIncorporation by reference approved by the Director of the Office of Federal Register on January 1, 1981.
2 Copies may be obtained frcm the Institute of Electrical and Electronics Engineers, Inc., 345 East 47th Street, New York, N.Y. 10017.
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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 Equipment for Light-Water-Cooled Nuclear Power Plants," which endorses IEEE 323-1974,2 "IEEE Standard for Qualifying Class IE Equipment for Nuclear Power Generating Stations," subject to supplementary provisions.
Currently, the Commission has underway a program to reevaluata 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 L
IEEE 323-1971 and the second for plants reviewed in accordance with IEEE 323-1974.
i 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 equipment and to address the ques-l tion of backfit.
The Commission also directed that the DOR Guidelines 3
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and NUREG-0588 form the basis for the requirements licensees and appli-
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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.
Recualification of electric ecuipment in accordance with this rule will not be reouired for eouipment oualified or being oualified in accordance with DOR Guidelines and IE Bulletin 79-01B or NUREG-0588, provided the cualification program has commenced prior to 90 days after the effective date of the rule.
The Eemmission's Memerandem and Srder Eti-88-21 directed that the environmentai quaiification of electric equipment in cperating neciear power plants be tempieted by dene-38; 1982-Hewever; en September-23; 1981; the Eemmissien censidered the petition (SEEY-81-4863 to extend this deadline-The prepesed ruie covers the same electric equipment as Eti-88-21 and impicments SEEY-81-486 by incorporating the extension dates recommended by the Ehairman in his memorandem-dated September-39;- 1981.
Inciaded in the preposed raie ir a requirement that each heider of er each applicant for a license to eperate a neciear power piant identify and qualify the electric equipment needed to cempiete one path of achieving and maintaining a ceid shutdown conditien-The Eemmissien specificaily requests comment en this prepesed additional requirement-The scope of the prepesed final rule does n,ot include all electric equipment 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 4
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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 preposed final _ rule are specific technical require ments 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 ef f ects, aging, margins, radiation, and environmental conditions.
- Also, a record of qualification must be maintained.
Revision I to Regulatory Guide 1.89 is being revised to will describe methods acceptable to the NRC for meeting the provisions of this proposed rule and to include a list L
of typical equipment covered by it; a draft-of-the proposed revision is-being published-for pebiic-ccmment-conccrrently with-the proposed-reie.
to the Reculatory Guide will be issued after resolution of public comments.
Also-incicced-in-the preposed-raie-is-a requirement 7-which-is-consis tent with-Eemmission-Memorandem and-6tder--Eti-80-Eli-for sabmission---
ef-an analysis-by-licensees-to ensare-that-the plant can-be-safely eperated pending-ccepletien-of-the environmentai qcalification of electric-equip-ment:--The-Ecemis sien-expects-that;-fer each-of-the-ccrrentiy-eperating pewer piants;-tnis-analysis and-its evalcatien-by-the-NR6-staff-will-be cc pieted-weii-in-advance ef-the-effective-date-of-this-reier--if-the licensees-ef-epersting pewer piants-f aii-to provide-these-analyses-in-a timeiy-.anner7-the-Ec. missien expects-the-NRE staff-to-take-the appre-priate-steps-te require-thst-the-infermatien-be provided-and-te enferce 5
[7590-01]
s compiiance-with-this-requirement---This-req =irement-has-been-incieded-in this preposed reie-to previde-a-reguiatery-basis-for enforcement.
NRC will generally not accept analysis alone in lieu of testing.
Experience 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-impracticai-because-of size--or-iimitation-dee-to-the-state-ef l
the-art.
The proposed rule takes into consideration the prior qualifi-i on history of the operating power plants.
For example, the proposed rule recognizes that for those plants which are not committed to either
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l IEEE 323-1971 or IEEE 323-1974 for equipment qualification, and have been tested only for high temperature pressure, and steam, some 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 preposed rule would require that each holder of an operating license provide a list of electric equipment previously qualified based on testing or analysis, or a combination thereof, and a list of equipment that has not been qualified.
These lists and the schedule for completion of equipment, qualification would have to be submitted written 90 days after the effective date of this rule.
However--this-time peried-wili be-adjested-dering-the-finai-reie-making precess,-to aliew-ressenabie-time for-iicensees-to evalcate-NREi -ssfety-reviews-that-are-ccrrently enderway.
s The preposed-r=ie wiii-cedify-the-60mmissien's-current-req =irements for-the envirenmentai geaiification-of eiectric-equipment---Spen pebiica-tien-ef-a-final reie--tne-SER geidelines and-NSRES-95SS wiii-be withdrawn.
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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 rule to include additional electric equipment important to safety.
This matter will be the subject of a future rulemaking.
Additienai-viens-of-Eemmissioner-Bradford:--Semmissioner-Bradford believes-that-the preposed-deadline-(second refueling-octage after March-31--19823-for qualificatien-is-mech-tee-relaxed; given-the-fact that-iicensees and-the-NR6-have-been aware-of-the preciems-in-this-ares since-1978:--The proposed-desdiine-extends-as-mech as-two and ene-half years-beyend-the-dene-30;-1983-date-by which-the-Acemic-incestriai-Ferem concicced-that neariy ali-eiectricai-eqcipment-cecid-be qualified.
Given-the more genereas-deadline;-he aise-believes-that-the-reie shocid have-centained-requirements-for-seismic-and-dynamic quaiificatienv--While the generai-design-criteria-contain-reqcirements-in-this area;-ciarifica-tien-new-wocid-ensere-that-equipment-to-be repiaced-in-the-near-term-will not-have-to-be-ripped oct-in-a-few years-becacse-it was not properly seismicaily qcalified 6emmissioner-6iiinsky-has agreed-with-these-views.
CCMMENTS ON THE PROPOSED RULE The Commission received 69 letters from the public commenting on the proposed rule.
Copies of those letters and an analysis of the oublic comments are available for public inspection and copying for a fee at the Commission's Public Document Room at 1717 H Street, NW, Washington, DC.
Single cooies of the analysis of the comments may be obtained, while 7
[7590-01) the limited supply is available, on written request to the Office of Administration, Document Management Branch, Washington, DC 20555 Multiple comments were received pertaining to the following technical issues:
(1)
Inclusion of cold shutdown requirements t
I (2)
Equipment operating in a mild environment (3) Qualification efforts already undertaken and based on NRC/IE Bulletin 79-018/ DOR Guidelines and NUREG-0588 (4)
Recuirement of maintaining a central cualification file.
(5) Consideration of time-deoendent variation of relative humidity (6)
Agina "cualified life" (7) Margins - Ccnservatism apolied during the derivation of environmental parameters (8) Acceptance of analysis in combination with partial test data restricted to ecuipment ourchased prior to May 1980.
(9)
Resubmittal of justification of continued ooeration for coerating plants (10) Exclusion of seismic and dynamic recuirements - secuence testing on a single prototype Based on the comments received, the following substantive changes have been incorporated into the final rule:
(1) The requirement to cualify ecuicment needed to comolete one oath of achieving and maintaining a cold shutdown condition. has been deleted.
(2) A new Section (f)(5) has been added, covering the cualification of ecuioment located in mild environments 8
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r (3) The statement of considerations has been expanded to recognize qualification efforts already undertaken by the industry, as follows:
Recualification of electric equipment in accordance with this rule will not be required for equipment qualified or being qualified in accordance with 00R Guidelines and IE Bulletin 79-01B or NUREG-0588, provided the qualification program has commenced prior to 90 days after the effective date of the rule.
(4) The requirement to maintain a central cualification file has been deleted.
A oualification file in an "auditable form" shall be maintained.
(5) The recuirement on time-deoendent variation of relative humidity has been deleted.
(6)
The specific recuirement in the area of aging, that ongoing oualification be exclusively done using " prototype equipment naturally aged", has been deleted.
(7)
The section on margin has been clarified.
(See Secti.on (e)(8)]
(8)
Reference to a date (May 23, 1980) for acceptance of analysis in
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combination with partial test data has been deleted.
(9) The requirement to submit justification for the continued ooeration of operating plants has been deleted, since this has already been satisfactorily accomplished.
Paperwork Reduction Act
.The proposed final rule contains recordkeeping requirements that are subject to review by the Office of Management and Budget (OMS).
As required by P.L.96-511, this proposed rule wiii-be was submitted to OMB for clearance of the recordkeeping requirements.
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s 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 preposed final. rule affects the method of qualifi-cation of electric equipment by utilities.
Utilities do not fall within the definition of a small business found in Section 3 of the Small Business i
t I
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 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 existin~g requirements and imposes no new costs or obligations on utilities.
Pursuant to the Atomic Energy Act of 1954, as smended,' 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 10
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Sec. 122, 68 S. tat. 939 (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 uder 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. 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.
2.
A new S 50.49 is added to read as follows:
S 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
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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, 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.
Also-inci::ded-is eqcipment-needed-to-cempiete ene path ef-achieving-and-maintaining-s-coid-sht:tdewn-condition.
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(d) The applicant or licensee shall prepare a list of all electric equipment covered by this section.
and-maintain-it-in an-auditable-forms.
This-iist-of equipment mast--as a-minimem,-inciede:
In addition, the following information for electric eauipment except eouioment located in a mild environment, i.e., an environment that would at no time be more severe than the environment that would occur during normal plant ooeration or during anticioated coerational occurrences, shall be included in a cualification file:
(1) The performance specifications and strecteral-integrity-require-ments under conditions existing during normal and abnormal operation and during design basis events and afterwards. and-the-lengths-of-the periods d: ring which-the-integrity-mest-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.
(3) The environmental conditions, including temperature, pressure, humidity, radiation, chemicals, and submergence, and-the predicted-varia-tiens 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:
(1)
Temperature and Pressure.
The time-dependent temperature and pressura at the location of the equipment must be established for the most iimiting severe of the applicable postoiated accidents design basis events and must be used as the basis for the environmental qualification of electric equipment.
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f (2) Humidity.
Time-dependent-variatiens-ef-relative Humidity during normal operation and design basis events must be considered.
j (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 recircula-tion 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 the total dose and-dose rate-of-the-radiation environment 2
expected during normal operation over the installed life of the equipment pies and the radiation environment, includina dose-rate effects, 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 recircu-
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lating lines.
(5) Aoing.
Equipment qualified by test must, practicabie be preconditioned by natural or artificial (accelerated) aging to its installed end-of-life condition.
Electromechanicai equipment mest-be eperated-to-the-mechanical wear and electricai-degradatien-expected-dering its-installed-iife.
Where precondi.tioning 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 demonstrates of prototype equipment-nstersily-aged-in plant service shew--by artificisi eging-snd-type-testing that the item has additional qualified life.
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s 1
(6)
Submergence (if subject to being submerged).
(7)
Synergistic Effects.
The precenditioning-and-testing-of-equip-
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ment mest consider-known Synergistic effects must be considered when these effects are 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-dering-the-derivation-of-the envirenmental conditions-any conservatisms aoplied during the derivation of environ-mental condition unless these conservatisms can be quantified and shown to contain appropriate margin.
(f)
Each item cf electric equipment must be qualified by one of the following methods:
(1) Testing an identical item of equipment under identical conditions, or under similar conditions with a supporting analysis to show that the eouipment to be cualified is acceotable.
(2) Testing a similar item of equipment with a supporting analysis to show th'at the equipment to be qualified is acceptable.
(3)
Experience with identical or similar equipment under similar conditions witn a supporting analysis to show that the equipment to be qualified is acceptable.
(43--Analysis-in-iieu-of-testing-in-the-fellowing-esses:
(13--if-type-testing-is preieded-by-the physiesi-size-of-the-equip.
ment-or-by-the-state-of-the-art.
(4)
By Analysis in combination with partial type test data which supports the analytical assumptions and conclusions.
't t-the-eqeipment perchase-order wss-executed prier-to-May-23--1988-14
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(5)
Design or purchase specifications, if the eouipment is in a mild environment.
The specification must contain a description of the functional requirements and the specific environments during normal and abnormal conditions and must be s'upported by a certificate of compliance based on test data and analysis.
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4 l
l i
I Or For equipment, purchased prior to the effective date of this
. rule, which is located in a mild environment, the qualification can be demonstrated by (a) a ceriodic maintenance, insoection, and/or replace-
)
i ment crogram, (b) a periodic testing programs, and (c) an eouioment surveillance program.
(g)
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 specifi'ed in accord-ance with paragraph (d)(1) of this section for all conditions as speci-fled in accordance with paragraphs (d)(2) and (3) of this section.
The j
test profile (e.g., pressure, temperature, radiation vs. time) must I
include margins as set forth in paragraph (e)(8) of this section.
(3)
The test profile must be either (i) a single profile that i
envelops the environmental conditions resulting from any design basis event during any mode of plant operation where the ecuioment must per-form its safety functions (e.g., a profile that envelops the conditions J
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produced by the postulated spectrum of main steamline break (MSLB) and loss-of-coolant accidents (LOCA)) or (ii) separate profiles for each type of event (e.g., separate profiles for the MSLB accidents and for LOCAs).
(4) The same piece of equiriment must be used throughout the complete test sequence under any given profile.
(h)
Each holder of an operating license issued prior to (insert the effective date of this amendment) must, by'(insert a date 90 days af ter the effective date of this amendment), identify the electric equip-ment already qualified to the provisions of this rule 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 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 compli-cations, 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 of the completion date within 30 days of its discovery..
(j)--For-the-continced-eperation-of-a neciesr piant-esch-heider-of sn-eperating-iicense-isseed prier-to-the-ef fective-date of-this-r=le-shall perform sn-ansiysis-to ensere-that-the piant-can-be-safely-eperated pending ecmpietion-of-the enviren entsi qualification---The-detsiied-snsiysis-fer esch equipment-type with spprepriate-jestificatien-mest-be-sebmitted-te 16
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Birector-ef-Heciear-Reacter-Regulatory-by-(insert-the effective-date of the reic3-and mest-inci=de-where-apprepriate--censideratien of:
(13--Accempiishing-the safety-f=nctien-by seme-designated aiternative equipment-that-has-been-edeq=ately qualified-and satisfies-the singie faiiere-criterien-if-the principai-equipment-has-not-been-demonstrated-to be-faily gesiified (23--The-vaiidity of partiai-test-data-in-support of-the-originai qualification:
(33--Limited ese-of administrative contreis ever equipment-that-has net-been-demons trated-to-be-feliy qualified:
(43--Gempletion-of-the-safety-fenctien prior-to exposcre-to-the ens:-
ing accident environment-and-the s=bseq=ent-f aiiere-of-the equipment-does not-degrade any se.fety-fenction-or-mislead-the-operator:
(53--No significant-degradation-of-any-safety-function or-misiesding ef-the-eperator-as-a rescit-of-faii=re of equipment ender-the-accident envirenment:
(k) O)
The applicant for an operating license that is granted on or after the effective date of this amendment, 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) ef-this sectien-exc.ept-that-this analysis This analysis must be submitted to. the Director.of Nuclear Reactor Regulation for consideration prior to the granting of an operating license and must include, where accrocriate, consideration of:
(1)
Accomolishing the safety function by some designated alternate eauio ent if the orincipal ecuicment has not been demonstrated to be fully cualified.
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s (2) The validity of partial test data in succort of the original qualification.
(3)
Limited use of administrative controls over ecuipment that has not been demonstrated to be fully qualified.
(4) Comoletion of the safety function orior to exposure to the ensu-ing accident environment and the subsequent failure of the ecuioment 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.
(1) (k)
A record of the qualification includino documentation in paragraoh (d) of this section must be maintained in a centrai-file an auditable form to permit verification that each item of electric equip-ment 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 per. form its safety function up to the end of its qualified life.
Dated at this day of
, 1982.
For the Nuclear Regulatory Commission.
Samuel J. Chilk Secretary of the Commission I/
18
r ENCLOSURE 2 ANALYSES OF PUBLIC COMMENTS ON 10 CFR 50.49 (47FR2876, Jan. 20, 1962)
~
1.
Seismic Reouirements:
A.
Comment:
Seismic and dynamic qualifications are an integral part of environmental qualification, it is therefore inappropriate to codify environmental qualification first and then to codify seismic qualifi-cation separately at a later date.
Response
Electric equipment at operating nuclear power plants was generally qualified for environmental and seismic stresses sepsrately; i.e., by using separate prototypes for environmental and seismic qualification tests.
The proposed Regulatory Guide 1.89 (Feb. 1982) specifies " single prototype" testing (sequence testing) as an acceptable method for i
qualifying electric equipment.
The implementation section of this guide will include NT0L's and future plants, and will not extend to operating plants.
Thus, any seismic qualifi< :'c:om testing of equip-ment in operating plants that may be rc~- ' ad y f uture rulemaking will not require retesting for environ;;anta),;resses.
j Also refer to resolution of comment IC.
t i
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.04/15/82
t B.
Comment:
The proposed rule has introduced a new term, " dynamic qualification" without definition.
Response
"DynamicQualification"isoutsidetilescopeofthis rulemaking.
Therefore, no specific definition is required at this i
time.
The term will be specifically defined as part of the future rulemaking.
C.
Comment:
In the absence of seismic requirements in Section 50.49, equip.nent which may be replaced in the near term may have to be ripped out if it fails to meet the backfitting requirements, if any.
Response
Replacement parts are not specifically covered by this rule.
However, the guidance on replacement parts currently in the proposec Regulatory Guide 1.89 will be revised in response to the above comment.
The revision will be to the effect that for plants operating prior to the effective date of the final rule, replacement parts which have been environmentally and seismically qualified by the use of separate prototypes prior to the effective date of this rule will not require " ripping out" simply because a single prototype was not used.
D.
Comment:
It is appropriate that seismic and dynamic qualification requirements should not be included in Section 50.49.
It must, however, be stated that qualification to IEEE 344-1975 is one acceptable method for seismic qualification.
04/15/82 2
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a i
Response
Regulatory Guide 1.100 already endorses IEEE 344-1975 in this area.
2.
Establish Qualification Programs I
A.
Comment:
The rule should recognize previous submittals pursuant to the 00R Guidelines and NUREG-0588.
Response
The statement of consideration in the final rule has been expanded to recognize the abovementioned concern as follows:
For equipment' qualified in accordance with DOR Guidelines and IE Bulletin 79-01B or NUREG-0588 prior to 90 days after the effective date of the rule, requalification in accordance with this rule will not be required.
3.
Scope of the Rule A.
Comment:
This section seems to be much greater in scope as compared to NRC interim requirements.
Resoonse:
This statement is not correct.
The rule covers the Class 1E I
systems and equipment and some. additional non-Class 1E equipment, for example, certain post-accident monitoring equipment.
The very nature of this equipment requires qualification.
B.
Ccmment:
The scope of the proposed rule should be limited to Class 1E or safety related equipment.
08/15/82 3
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s
Response
By using terms " Class 1E" or " safety related," the scope
~
of Section 50.49 wil1 exclude certain post-accident monitoring equipment and other equipment (e.g., associated circuits) which are of sufficient importance to be included in the scope.
C.
Comment:
The scope should be reworded (47FR2878, Col. 2, Line 3) as:
... shutdown, maintain the integrity of the reactor coolant pressure boundary, containment isolation..."
Response
The language for the scope of the rule has been extracted in part from " Class 1E" definition in IEEE 323-1974.
The meaning of this terminology has been in place for past eight years and is well understood.
The staff believes that the safety functions included
~
in the final rule provide adequate protection to public safety.
D.
Comment:
The proposed rule introduces a new requirement to qualify
" equipment needed to complete one path of achieving and maintaining a cold shutdown condition" and this modifies the licensing basis for the majority of operating nuclear power plants.
A change of this magnitude, at this advanced stage of industry's qualification effort, most certainly introduces significant new costs and obligations with no demonstrated improvement in safety.
Response
This requirement has been delected.
The staff requires qualification of all safe shutdown equipment consistent with the power plants' licensing bases.
Consistent with draft Regulatory Guide 1.139, 0416/82 4
PUBLIC COMMENTS EQ RULE
the regulatory position is that, for power plants where the applica-tions for construction permits were docketed on or after January 1, 1978, the design should be such that the reactor can be taken from normal operating conditions'to colo snutdown using only safety grade systems that satisfy General Design Criteria 1 to 5.
As long as the equipment and systems needed for cold shutdown are designed to safety grade criteria, the qualification of such systems is covered by the Section 50.49'.
E.
Comment:
The scope includes, "... systems that should be qualified, those systems that could fail in such a way that would make a safety system unable to perform its function."
The wording could also imply that qualification encompass systems that could mislead the operator to the extent that the required safety functions would not be accomplished.
Qualification of non-safety instrumentation should not be required where such instrumentation is not the primary source of data used by the operator in controlling events.
Response
The interpretation is correct.
4.
List of Equipment Covered by Rule A.
Comment:
There is no distinction made between equipment located in a harsh or mild environment.
Restanse:
The proposed rule will be modified to include the require-ments for equipment located in a mild environment.
Further guidance 04/16/92 5
PUBLIC CCMMENTS EQ RULE
l for demonstration of qualification of equipment in mild environment will be included in Regulatory Guide 1.89.
B.
Comment:
Lists of equipment which have been compiled in response to NRC bulletins and letters should be used instead of requiring genera-tion of a new 1ist in another data format.
An alternative could be to identify on existing lists the equipment covered by this rule, and to reference other 1icensing documents, such as FSARs, design calcula-tions, and equipment specifications, where additional information is available.
1 Resoonse:
It has been the experience of the staff that simply referencing other licensing documents as referenced in the above-mentioned comment can result in uncoordinated and incomplete reviews of the qualification status of equipment.
Fon this reason, a separate list of equipment covered by this rule is required.
See also resolution of ccament 2A.
C.
Comment:
Equipment located in a mild environment should be excluded from the proposed rule since the NRC has indicated that qualification requirements for this equipment would be less stringent than for those in harsh environments.
Resoonse:
See resolution of comment 4A.
04/15/82 6
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5.
Performance Characteristics A.
Comment:
Environmental qualification should not be limited to design j
basis events, but should consider Class IX accidents.
Also, the rule omits the serious risk of internal missiles from pumps, valves, and burst pipes to electrical wiring and equipment.
Resolution:
Severe accidents (Class IX accidents) are being considered in other rulemakings.
Environmental qualification does not include con-sideration of missiles.
Protection against missiles must be provided in order to satisfy the requirements of GDC 4.
B.
Comment:
Structural integrity requirements should be deleted from the rule.
Resolution:
Staff agrees.
1
{
The terms " performance characteristics" and " structural C.
Comment:
integrity" are open to diverse interpretations.
Suggestions have been made to use the terms " safety functional requirement," per-formance " specifications" or "the safety related functions" in place of " performance characteristics."
t Resolution:
With regard to structural integrity, see resolution of
(
The term " performance characteristic" has been changed comment 4.B.
to " performance specifications".
l 44/16/82 7
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s D.
Comment:
The proposed requirement of paragraph (d)(1) is redundant, unnecessary, and arbitary since equipment technical specifications contain design criteria and requirements for safety equipment which is sufficient.
Resolution:
See resolution of comment 4.B.
E.
Comment:
The required list of equipment should not include perform-ance characteristics.
This will lead to recording of extraneous l
r information, diluting the importance of safety related parameters information.
Resolution:
Performance characteristics are not extraneous i
information.
9 6.
Electrical Characteristics A.
Comment:
Change "can" to "must" on last line of paragraph (d)(2).
2sponse:
The use of word "can" is appropriate; since the require-ment in Section (d)(1) only pertains to listing of performance characteristics of the equipment.
B.
Comment:
Requiring the " range" to be qualified is overly restrictive, unnecessary, and will have a large cost impact on testing.
Response
Staff agrees.
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i a.
C.
Comment:
Delete paragraph (d)(2).
Resconse:
See resolution of. the comment 6.8.
D.
Comment:
Testing conducted in the past typically did not consider all possible electrical conditions.
Therefore, the requirements of paragraph (d)(2) should be removed from the proposed rule at least for equipment previously evaluated to the COR Guidelines or NUREG-0588, Category II.
Response
See resolution of comment 2.A.
7.
Environmental Conditions n
A.
Comment:
The term "where applicable" needs to' be added after.the list of environmental parameters in paragraph (d)(3).
Response
Paragraph (d)(3) states that the environmental conditions apply to the location where the equipment must perform.
The staff recognizes that all the environmental parameters listed are not applicable at all equipment locations.
B.
Comment:
The term " chemical" is too broad and should either be defined or specific chemicals named.
Clarification regarding qualification-for chemical spray Resconse:
environments is given in paragraph (e)(3) of this section.
Additional guidance is provided by Regulatory Guide 1.89.
9 PUBLIC CCMMENTS EQ RULE 04/15/82
C.
Comment:
Predicted variations in environmental conditions are not l
necessary if extreme conditions are identified and used in the i
qualification program.
~
Resoonse:
Extreme environmental conditions cannot be identified for some parameters, e.g., temperature and pressure, until their time-dependent variations have been predicted.
The proposed rule does not state that the use of identified extreme conditions, with appropriate margin, are unacceptable.
Also see staff response to comment 7.E.
D.
Comment:
It is suggested that paragraph (d)(3) be supplemented with the following:
"These environmental conditions may be determined using realistic inputs."
Response
The bases for determination of environmental conditions must be justifiable.
Guidance concerning the determination of environmental conditions is provided in Regulatory Guide 1.89.
E.
Comment:
It is recommended that paragraph (d)(3) be deleted because of the phrase "the predicted variations of..."
04/15/82 10 PUBLIC COMMENTS EQ RULE
?
e
Response
The requirement of paragraph (d)(1) concerning the pre-dicted variations of environmental conditions with time has been deleted.
Requirements in this area are specified for the individual environmental parameters elsewhere in this section.
'l 8.
Temcerature and pressure A.
Comment:
The phrase "most limiting" needs clarification.
Resoonse:
For clarity, the phrase "most limiting" is changed to "most severe."
B.
Comment:
For consisting, " design basis events" should be used in paragraph (e)(1) rather than " postulated accidents."
Resoonse:
Staff agrees.
9.
Humidity A.
Comment:
The effects of time dependent variations of relative humidity during normal operation cannot be considered for all equipment.
There are no detailed standards,for how this type of testing should be performed.
Resconse:
Staff agrees.
The rule has been modified accordingly.
04/15/82 11 PUBLIC COMMENTS EQ RULE
s 10.
Chemical Effects A.
Comment:
Since corrosion effects of various chemical components are l
generally well known, this paragraph should provide latitude to allow analysis that justifies using different chemical spray con-stituents or less severe concentrations than specified by plant i
environmental requirements.
Response
Analysis is acceptable if adequately justified.
11.
Radiation A.
Comment:
In general, the aging and accident radiation cannot be j
r combined, i.e., the word "plus" is misleading or incorrect since it implies integrated effects.
Response
Staff agrees.
The word "plus" has been changed to "and."
B.
Comment:
The requirement that the dose rate be as in the power plant is totally impractical.
The normal operation dose occurs over a 35 to 40 year period.
Obviously dose rate acceleration must be permitted.
Resoonse:
The rule states that the radiation environment must be based on the dose rate, and not that the actual dose rate be used during testing.
The intent is that any non-conservatisms used resulting from using a higher than normal dose rate during testing must be taken into account.
12 PUBLIC COMMENTS EQ RULE
.04/16/82
i 12.
Aging A.
Comment:
The requirement that on going qualifications be done using
" prototype equipment naturally aged" is overly restrictive and is not in harmony with (f).
There are other,-equally acceptable methods of extending qualified life and it is not appropriate to single out just one of them.
Response
Staff agrees.
The rule has been modified.
~
B.
Comment:
The specific inclusion of aging requirents for electro-mechanical equipment is inappropriate in the rulemaking.
Such details should be included in the revision to R.G. 1.89.
w
Response
Staff agrees. Reference to "electromechanical equipment" has been deleted from the rule.
Comment:
Use of accelerated aging to define a qualified life is not technically feasible.
Resoonse:
Based upon research, the staff beli. eves that precondition-ing by accelerated aging is technically feas.ible for both simple and complex electric equipment for shorter specified qualified life and that it is technically feasible for simple systems for full lifetime testing.
Staff recognizes that state-of-the-art technology will be utilized in any aging program.
R.G. 1.89 will be revised frem time to time to reflect the state-of-the-art.
Oel1%222 13 PUBLIC COMMENTS EQ RULE
13.
Synergistic Effects I
I A.
Comment:
"known synergistic effects...." must be considered.
NRC should be more specific.
1
Response
The word "known" has been deleted from the rule.
l t
f 14.
Margins A.
Comment:
The proposed rule states that margins are used to account for inaccuracies in test instruments.
Test instrument inaccuracies are a QA problem associated with required calibration programs and should not be encompassed under margins.
w su
Response
The staff disagrees.
The/ test instruments errors must be 7
.N accounted for.
l B.
Comment:
The margins applied in addition to known conservatisms lead to excessive stress which could lead to failures of equipment in unrealistic qualification tests.
l l
l
Response
Staff agrees.
Paragraph on margi.n has been accordingly l
l modified.
I 15.
Methods of Qualification A.
Comment:
Qualification by analysis should not be allowed.
(
04/15/82 14 PUBLIC COMMENTS EQ RULE
Response:, Analysis alone is generally inadequate to demonstrate qualification and type testing is the preferred qualification method.
Although some analysis may be used, as identified in the rule, that analysis should b'e limited to extrapolations of data or to analyzing similarities in equipment or materials.
In any case, analytical assumptions should be verifiable or supported by test data.
16.
Testing of similar Items and Analysis A.
Comment:
Paragraph (f)(2) should state that it is acceptable to test a similar item of equipment under similar conditions with a supporting analysis that shows the equipment to be qualified is acceptable.
Response
The staff disagrees.
The intent of paragraph (f)(2) is to cover both "similar" and " identical" environments.
17.
Exoerience and Analysis A.
Comment:
Experience has proven to be of very limited use in qualification because of the lack of supporting documentation.
It is suggested, therefore, that the words " Adequately documented" be inserted at the beginning of paragraph (f)(3).
Resoonse:
All information used to demonstrate the qualification of equipment, including test results, analytical assumptions, and
' 04/15/82 15 PUBLIC COMMENTS EQ RULE
i s
experience with identical or similar equipment, must be adequately documented.
18.
Analysis A.
Comment:
Are subparagraphs (f)(4)(i) and (f)(4)(ii) independent?
Response
No.
The rule has been modified.
19.
Analysis and Partial Test Data A.
Comment:
If partial type test data is available which adequately.
supports the analytical assumptions and conclusions, then analysis should be allowed to extrapolate or interpolate these results for equipment, regardless of purchase date.
Resoonse:
Staff agrees.
The rule has been modified.
20.
Prerequisites for Testing A.
Comment:
This paragraph is written specifically for equipment employed for hostile environment applications and does not recognize alleviations appropriate for equipment located in mild environments.
Response
Environmental testing is not required for equipment located in mild environments.
04/15/82 16 PUBLIC COMMENTS EQ RULE
I
~
B.
Comment:
Strict application of these requirements will r.egate testing already completely for earlier plants.
The relief in 4
must be included in the Reg. Guide 1.89.
Response
Requalification is not required for the electric equipment qualified in accordance with IE Bulletin 79-018 (DOR Guidelines) or NUREG-0588 prior to 90 days after the effective date of this rule.
C.
Comment:
Paragraph 50.49g should be deleted as it limits the options available for qualification testing.
Response
The staff does not believe that this paragraph should be deleted, since this section specifies the minimum testing criteria.
O.
Comment:
As written, this requirement applies to all equipment which has or will undergo qualification testing.
This paragraph should not be applied to equipment which predated the requirements of IEEE 323-1974.
Response
See response to comment no. 2.8.
E.
Comment:
This paragraph should.also make provisions for acceptance of testing that does not totally envelop all plant environmental conditions by supporting analysis.
Response
Section (f)(2) covers the similar conditions.
04/16/82 17 PUBLIC CCMMENTS EQ RULE
F.
Comment:
The detailed requirements for qualification by testing should not be contained in a rule, but should instead be discussed in Reg. Guide 1.89.
Response
Since testing is the principal means for qualification of electric equipment, the specified requirements are appropriate.
G.
Comment:
The first sentence should be changed to "If an item of electric equipment is to be qualified by test or analysis..."
Response
Staff disagrees.
All of the requirements listed are not appropriate for analysis as a qualification method.
21.
Acceotance Criteria A.
Comment:
The requirement for acceptance criteria does not clearly say that they must be relevant.
Acceptance criteria are application dependent.
Resconse:
The staff disagrees that the acceptance criteria are necessarily plant dependent.
B.
Comment:
The establishment of acceptance criteria before testing should be deleted.
" Failure" is often a plant specific consideration.
Resconse:
The staff disagrees.
Acceptance criteria, whether generic or specific, should be established prior to testing.
04/15/82 18 PUBLIC CCMMENTS EQ RULE
C.
Comment:
If the documentation in paragraphs d(1), (2), and (3) are established, a clear record that the equipment provides the perform-ance required will have been established.
Therefore, this~ require-ment for acceptance criteria'should be eliminated.
Response
Staff disagrees.
The referenced paragraphs (d)(1), (d)(2),
and (d)(3) refer to performance.
Performance and acceptable criteria are not necessarily identical.
D.
Comment:
This paragraph precludes reevaluating test criteria following the actual test.
When equipment does not meet the acceptance criteria, system redesign, reconfiguration, and analysis should be allowed in order to verify that the initial acceptance criteria were in fact valid.
Response
The rule specifies the methods for deinonstrating successful qualification.
Failures during testing due to faulty test equipment or invalid acceptance criteria are outside the scope of the rule.
l 22.
Demonstration by Test A.
Comment:
Delete reference to paragraphs (d)(1), (d)(2), and (d)(3) concerning characteristics, electrical characteristics and environ-mental conditions, respectively.
Response
See resolution of comment No. 21C.
04/15/S2 19 PUBLIC COMMENTS EQ RULE
4 s
B.
Comment:
Paragraph g(2) requires that a radiation dose rate exposure profile vs. time be established and enveloped by the qualification i
testing. ; Testing at qualification dose rates exceeding accident dose rates, and total exposures exceeding the ac'cident and normal exposure, is a conservative approach.
Response
Reference to " dose rate" has been deleted. ' Margin of
+10% for total dose,,in accordance with IEEE 323-1974 is acceptable.
C.
Comment:
The radiation vs. time simulation requirement should be deleted from paragraph g(2).
Response
See resolution of comment No. 228.
D.
Comment:
The radiation dose rate should be simulated to the best extent possible within the limitations of the test facility and measuring instruments.
Response
See resolution of comment No. 228.
E.
Comment:
The rule should state that the accident radiation dose exposure with appropriate margin may be perf,ormed as a part of the preconditioning procedure.
Also, margin need not be applied if the methods in Appendix 0 of NUREG-0588 have been employed.
i Resconse:
See resolution of comment No. 2A and comment No. 228.
[
04/15/82 20 PUBLIC COMMENTS EQ RULE
o z
F.
Comment:
Many utilities have undergone expensive qualification testing to service' conditions unique to their plant in accordance with IEEE 323-1971 and demonstrated compliance with previous NRC regulations.
New increased margins should not be applied to these existing tests.
Response
See resolution of comment No. 2A.
23.
Test Profile A.
Comment:
The option presented in this paragraph is excessive in its limitations.
The envelope should not be that which results from any design basis event during any mode of operation but rather the envelope that results during any mode of operation during which the subject equipment must perform its function.
Response
Staff agrees.
For clarity the rule is modified to read,
"...any mode of plant operation where the equipment must perform its safety functions (... ). "
24.
Single Prototype A.
Comment:
Does this section apply to aging also?
For example, could parts of a component be aged ;eparately, then assembled, then tested as per g(3)?
04/15/82 21 PUBLIC COMMENTS EQ RULE
Response
This is acceptable.
However, the intent of section (g)(4) is that the test stresses; e.g., aging and radiation, are not shared among two or more pieces of equipment.
B.
Comment:
Paragraph 50.49 g(4) requires qualification by sequential test.
Without direction on seismic and dynamic requirements, sequential. tests cannot be done.
Response
See resolution of comments lA and 1C.
C.
Comment:
This section may be interpreted as requiring MSLB and LOCA qualification tests of the same device.
Testing to either is suf-ficient, provided that the limiting accident is identified.
r
Response
Testing to the most limiting condition is acceptable.
D.
Comment:
Allowance for justifications for deviations from using the same piece of equipment throughout a test sequence should be allowed.
The present 50.49 g(4) conflicts with the proposed Revision 1 of Regulatory Guide 1.89.
Resoonse:
See resolution to comment 2A.
No change in 50.49 g(4) is necessary.
04/15/82 22 PUBLIC COMMENTS EQ RULE
r 25.
Extension Date and Schedule Submission A.
Comment:
The proposed rule's extended deadline for compliance with environmental criteria is unjustified and too liberal....
Resoonse:
In developing the position on the extension of the dead-line for qualification of electric equipment, the NRC has corisidered information supplied by equipment vendors, utilities, test labora-tories, consultants, and other interested parties.
The amount of work, the availability of qualified personnel and equipment, and the impact on overall plant safety were factored into the Commis-sion's decision to extend the deadline.
Licensees have submitted information to the NRC showing that the plant cIn be safely operated a
pending completion of the required environmental qualification.
B.
Comment:
Mild en.'ironment equipment should be excluded from the schedule for equipment testing or replacement to be submitted to the NRC 90 days after the effective date of the rule.
Response
Staff agrees.
See resolution of comment 4A.
C.
Comment:
Within 90 days of the effective date of the rule, a schedule for " testing or replacement" of unqualified equipment is to be provided to the NRC.
The word " testing" should be replaced by
" qualification."
N128 8
' PUBLIC COMMENTS EQ RULE
4 i
s
Response
The staff disagrees.
Although the word qualification could be substituted for testing, in accordance with Section f of 10 CFR 50.49 some form of testing is required for qualification.
The intent of the Commission is that qualification by analysis alone will no longer be acceptable.
D.
Comment:
We assume the goal of final environmental qualification is for the second refueling outage starting after March 31, 1982.
Response
Staff agrees.
E.
Comment:
The requirement f r " testing" of equipment identified in the submittal due 90 days after the publication of the final rule is P
inconsistent with 50.49f concerning qualification methods and with the proposed revision to Regulatory Guide 1.89-(Section C.5.9) regarding qualification in mild environments.
Response
Staff agrees.
See resolution of comment 4A and 20A.
F.
Comment:
The rule should recognize that previous submittals to the NRC containing equipment identification and schedules for qualifica-tion are adequate for fulfilling the requirements in 50.49h.
Response
Prior submittals have not satisfied the requirements.of Section 50.49h.
For example, the schedule for qualification had never before been required.
04/16/82 2'4 PUBLIC CCMMENTS EQ RULE
o t
G.
Comment:
The words "but prior to November 30, 1985" in 50.49h and 50.49.4 should be deleted.
As currently written, no recourse is pro-vided for plants receiving operating licenses after November 30, 1985.
Response
Plants licensed after November 30, 1985 will be required to be in compliance with this rule.
H.
Comment:
The requirement to submit a schedule for the testing or replacement of equipment is not warranted.
The date for submitting a schedule for testing and replacement has no safety significance whatsoever.
Response
The achievement of full qualification by the November 30, 1985 deadline depends on the early identification of deficiencies and a commitment to a firm plan for systematic, corrective action.
I.
Comment:
The requirement for submission of schedules for qualifica-tion within 90 days of the rule should be revised to allow more time for mild environment equipment.
Resconse:
See resolution of comment 4A.
J.
Comment:
The proposed rule appears to require a new round of sub-mittals (90 day letters) covering information that has already been submitted to the NRC.
A statement should be included to indicate that this requirement applies only to plants that did not submit a 90 day response.
PUBLIC CO.MENTS EQ RULE Y
0AGAIM 25
Response
The date for completion of environmental qualification would be extended by Section 50.49, new schedules for completion of qualification must be submitted.
Duplicate submittals are not required.
26.
Significant' Problem Notification A.
Comment:
The schedule for notification of the Commission.of any significant qualification problem within 30 days of its discovery should be separated from the technical requirements of the rule.
Resoonse:
Staff disagrees.
The purpose of this requirement is to provide advance notice and basis for possible extensions.
r B.
Comment:
We believe the' requirements to notify the Commission of potential problems within 30 days of discovery may be too stringent, s
particularly if a scheduled completion'date is six months or longer from the date of discovery of a potential problem that may require extension.
Response
The staff agrees.
See resolution of comment 26.C C.
Comment:
The notification period of 30 days to allow industry to evaluate minor qualification problems should be extended to 90 days.
This would minimize the number of insignificant problems to be addressed by the Commission and industry.
04/15/82 26 PUBLIC COMiiENTS EQ RULE
Resoonse:.The staff agrees.
The rule has been modified to extend time from "30" to "60" days.
~
, 27.
Justification for Continued Operation A.
Comment:
The proposed rule requires " analyses" to justify continued operation with unqualified equipment.
These analyses are-vague and l
insubstantial and will allow licensees to rationalize the use of unsafe equipment based on its behavior during normal operating conditions.
Response
This paragraph has been-deleted from the final rule.
The licensees of the operating plants have justified the continued operation of nuclear power plants based on the criteria as stated in paragraph (j) of the proposed rule.
17.7 Comment:
The submittal of justification for continued operation should be required 90 or 180 days after the effective date of this l
amendment, not on the effective date, to be consistent with the Supplementary Information section.
l 1
Response
See resolution of comment 27A.
C.
Comment:
The provisions of the rule concerning justification for continued operation should be deleted as this information has been i
previously submitted in response to IES79-018.
i 27 PUBLIC COMMENTS EQ RULE '
04/15/82
Response
Staff agrees.
See resolution of comment 27A.
{
28.
Desionated Alternative Sinole Failure Criterion / Partial Test Date e
A.
Comment:
If redundant, qualified, " alternative" equipment is avail-able to perform a safety function in lieu of unqualified equipment, then compliance with the regulation has already been achieved and the unqualified equipment may be exempted from the program.
This require-ment should be deleted.
Resoonse:
The staff disagrees.
Terms " alternative"-(or alternate) and " principal equipment" are used in the context of section 4.7.4.1 of IEEE 279-1971.
Specifically, the alternate and principal equip-ment is mutually diverse (to protect against common mode failures.)
However, each set of equipment separately should meet the provisions of IEEE 279-1971.
In this rule, the terms are not restricted to equipment in the protection systems.
B.
Comment:
The requirement for satisfaction of the single failure criterion for justification for continued cperation is overly restrictive.
If this requirement were met, no justification for interim operation would be needed.
Response
Staff agrees.
The rule has been modified.
The phrase "and satisfies the single failure criterion" is unclear C.
as used in this section.
Also define the term " adequately qualified."
04/15/S2 28 PUBLIC CCMMENTS EQ RULE
Response
The word " adequately" has been deleted.
See resolution of comments 28A and 288.
D.
Comment:
If there is designated alternative equipment which is qualified and satisfies the single failure criterion, the principal equipment need not be c14.sified as safety related and hence need not be qualified.
Response
See resolution of comment 28A.
E.
Comment:
The new rule states that partial test data may be used as justification for continued operation.
Both this rule and the current requirements recognize that analysis and partial test data, appropriately applied, constitute qualification.
Response
Partial type test data and analysis, appropriately applied to envelop the predicted environmental conditions, are sufficient for
~
~
l qualification.
Where the test data are insufficient to demonstrate full qualification, partial test data may be utilized to justify continued operation.
29.
Comoletion of Safety Function A.
Comment:
The proposed rule states that justification for continued operation may be determined if equipment performs its safety function prior to exposure to the accident environment, and subsequent equip-04/16/82 29 PUBLIC COMMENTS EQ RULE i
9 ment failures do not degrade the safety functions or mislead the operator.
This should be sufficient for full qualification.
Response
A demonstration with appropriate margins that equipment fulfills the above requirements can constitute full qualification.
B.
Comment:
The evaluation of whether the failure of a single piece of equipment will, of itself, mislead the operator is subject to inter-pretation and engineering judgement.
Because redundant equipment would be available, the justification for interim operation should not consider the aspect of unqualified instrumentation misleading the operator.
Response
Licensees should examine on a case-by-case basis the impact of equipment failures on operator actions.
The li~censees should decide whether the erroneous information subsequent to accomplishment of protection systems can mislead the operator.
l 30.
Significant Degradation A.
Comment:
One of the considerations for justification for continued operation is the occurrence of no significant degradation of a safety function or misleading of the operator as a result of failure of equipment under the accident environment.
Assurance of the above should comply with the Commission's intent in the rulemaking process.
L
'"*"' ' ""?' * ""?
"l
Response
This section applies to relatively new power plants and assumes that the majority of the equipment already is fully quali-fied prior to issuance of an operating license.
This provision is intended to justify operation where alternats qualified equipment
~7 can compensate for the potential malfunction of relatively items j
which may not be " fully" qualified.
31.
JC0 for NT0Ls A.
Comment:
The provision allowing applicants for new licenses (to be granted on or after the effective date of the amendment and prior to November 30, 1985) to submit " analyses" in lieu of test results to demonstrate environmental qualification should not be permitted.
Licensees have been under directives to document the qualification of safety equipment since 1977.
Response
See resolution of comment 30A.
8.
Comment:
Previous submittals by NTOLs pursuant to NUREG-0588 which contain justification for operation ;5ould be acknowledged.
Response
This rule does not require duplicate submittals.
32.
Reouirement of a Central File A.
Comment:
the requirement t'o maintain a record identifying that the equipment meets its specific performance requirement exceeds the 04/16/82 31 PUBLIC CCMMENTS EQ RULE
s verification necessary to establish the performance of safety i
function.
l i
Resoonse:
The qualification' test by nature is limited to verifying I
the performance characteristics, and not the actual safety function performed by the equipment; e.g., cooldown of a core.
B.
Comment:
the requirement for a central file should be for equipment located and potentially subject to a harsh environment only.
Resoonse:
The extent of the documentation required for mild environment equipment will be addressed in Regulatory Guide 1.89.
C.
Comment:
The requirement for a central file should be deleted because some records may be kept in the utility general file.
Response
This paragraph has been revised to require that auditable files permitting verification of qualifications be available.
D.
Comment:
The terms " application" and " specific performance require-ments" should be changed to state that safety functions will be performed when subjected to the conditions p,redicted.
Response
See resolution of comment 32A.
E.
Comment:
we suggest that it may~ be difficult, if not impossible, to obtain the record of qualification required, particularly for equip-04/15/82 32 PUBLIC CCMMENTS EQ RULE
e ment. in older plants, and we suggest that for equipment that has significant successful operating experience this record should not be
'necessary.
i
Response
The requirements of section (f) (3) must be met.
F.
Comment:
The contents of the central file may vary considerably depending on whether the file. is a record of qualification to _the f
1 harsh or mild environment.
Recognition of content requirements by reference to any proposed regulatory guide would be appropriate.
Response
See resolution of comment'328.
7 G.
Comment:
Qualification central file information should include equipment in a harsh environment only and should only support the equipment's ability to perform its safety function.
Response
See resolution of comments 32A & 328.
H.
Comment:
Please clarify as to exactly where the licensee shall maintain qualification records, particularly with respect to files l
which are proprietary to the NSSS vendor.
Resocnse:
Qualification files must be maintained in an auditable form, under the control of licensee.
4 a
04/16/82 33 PUBLIC CCMtENTS EQ RULE
t 33.
Supolementary Information A.
Comment:
The term "important to safety" should be replaced by Class IE throughout this rule.
Response
Staff disagrees.
See resolution to comment 38.
B.
Comment:
The term " safety-related" should be used in place of "important to safety."
Response
The applicable equipment covered by this rule is specified in 50.49c.
Expansion of the scope of this rule to include additional equipment important to safety will be subject of a future rulemaking.
y C.
Comment:
The scope of the proposed rule should include all electric equipment "important to safety" since that is the same as " safety-related" or " safety grade" equipment.
Response
Equipment "important to safety" includes " safety-related" and other equipment.
The scope of the rule includes equipment designated in " Class 1E" and some additional non-Class IE equipment.
The staff believes that, for electric equipment, " Class 1E" is the same as " safety-related."
See also the staff resolution of comments 3C and 338.
34 PUBLIC COMMENTS EO RULE 04/16/82
6 0
34.
Qualification History A.
Comment:
It should be noted that prior to 1971 qualification of electric and electronic equipment was based on [the] use of good engineering practices which included conservative application and design, high quality equipment, and some environmental testing.
Response
Staff agrees.
Additional detail,s are inappropriate in the final rule.
35.
Rule Basis Current Recuirements A.
Comment:
The proposed rule is primarily based on NUREG 0588 Category I.
Therefore, it is appropriate that this rule clarifies and recognizes the fact that equipment eval'uated in accordance in accordance with [the] 00E guidelines and NUREG 0588 Category II are considered to satisfy the requirements of this rule.
Response
See resolution of comment 2A.
B.
Comment:
The Federal Register notice states that this rule codifies existing requirements and imposes no new costs or obligations on utilities.
We take strong exception to this statement.
i Resoonse:
The new rule will codify the current requirements in the 00R Guidelines, IE Bulletin 70-01B and NUREG 0588.
04/15/82 35 VJBLIC COMMENTS EQ RULE
s a>
C.
Comment:
The rule does not recognize that operating plants have j
just completed qualification of equipment to the 00R Guidelines or NUREG 0588 Category II.
Resoonse:
See resolution of comment 2A.
D.
Comment:
The statement made in the Supplementary Information Section should also state that the requirements of IE Bulletin 70-01B are being codified.
Resoonse:
See resolution to comment 2A.
36.
Reolacment Parts A.
Comment:
The rule does not address replacement parts.
Resoonse:
Guidance concerning replacement parts will be included in Regulatory Guide 1.89.
04/15/82 35 PUBLIC COMMENTS EQ RULE