ML20053E634
| ML20053E634 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 06/04/1982 |
| From: | Rawson R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Brenner L, Carpenter J, Morris P Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8206090096 | |
| Download: ML20053E634 (2) | |
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June 4, 1982 Lawrence Brenner, Esq.
Dr. James L. Carpenter Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Peter A. Morris Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear RegulatoryCommission Washington, D.C. 20555 In the Matter of Long Island Lightirig Company (Shoreham Nuclear Power Station, Unit 1)
Docket No. 50_322 (0L)
Dear Administrative Judges:
The enclosed document, SECY 82-207, was released by the Commission on Tuesday, June 1, 1982.
The final rule which is the subject of the document has not been approved by the Commission. This document is transmitted to the Board and the parties by the Staff as information which may be relevant and material to matters pending before the Board.
Sincerely, Richard J. Rawson Counsel for NRC Staff
Enclosure:
As stated cc:
See page two DS07 0FC :0 ELD
_ _ _ _ _ : _ _ _/_(_d _(_ _, _ : 0 E LD: _ _ _ _ _ _<7
,f__________:____________:-___________:____________:___________
NAME :R.Rawson/ls :E.Reis
_____:____________:____________:7 DATE :06/03/82
- 06/03/82 8206090096 820604 PDR ADOCK 05000322 O
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cc:
(w/ enclosures)
Matthew J. Kelly, Esq.
Ralph Shapiro, Esq.
Howard L. Blau, Esq.
W. Taylor Reveley, III, Esq.
Stephen B. Latham, Esq.
John F. Shea, III, Esq.
Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Appeal Loard Panel Herbert H. Brown, Esq.
Lawrence Coe Lanpher, Esq.
Karla J. Letsche, Esq.
Docketing and Service Sectior Edward I'.. Barrett, Esq.
l'ir. Brian licCaffrey 1: arc U. Goldsmith David H. Gilmartin, Esq.
Mr. Jeff Smith MHB Technical Associates Hon. Peter Cohalan Mr. Jay Dunkleberger l
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RULEMAKING ISSUE (Affirmation)
For:
The Commissioners From:
William J. Dircks, Executive Director for Operations l
Subject:
FINAL RULE, " ENVIRONMENTAL QUALIFICATION OF SAFETY-RELATED ELECTRIC EQUIPMENT FOR NUCLEAR POWER PLANTS"
Purpose:
To obtain Commission approval for publication.of the notice of a final rulemaking, " Environmental Qualification of Safety-Related Electric Equipment for Nuclear Power Plants," in the Federal Register.
Background:
Ouring the Affirmation Session on January 7, 1982, the Commission approved (5 to 0) the publication of the notice pf proposed rulemaking, "Environinental Qualification of Electric Equipment for Nuclear Power Plants" (SECY-81-6038, dated November 16, 1981).
The notice of proposed rulemaking was published in the Federal Register on January 20, 1982.
The comment period expired on March 22, 1982.
Sixty-nine comment letters raising ten major issues were received by April 6, 1982.
An additional ten comment letters were received by April 21, 1982, but no new issues were raised.
The major issues are discussed below.
Discussion:
Resolution of Public Comments Five of the ten issues have been readily resolved.
Resolution consisted of (1) deleting testing requirements related to time-dependent varia-tions of relative humidity, (2) recognizing that a precise qualified life cannot be determined by artificial pre-aging of equipment and modifying the rule accordingly, (3) removing a requirement that could have caused excessive margins in test parameters, (4) allowing analysis based on partial qualification test data for all plants subject to the rule, and (5) removing a requirement for justifying continued operation pending qualification (since the action has already been accomplished).
l The detailed responses to the 69 letters of public comment are included l
as Enclosure 2.
Contact:
Satish K. Aggarwal, RES 443-5946 q;tAl-
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l' Thh Commissioners 2
I I
The remaining five issues have been more difficult to resolve and have been the subjects of lengthy discussions among members of the staff and among members of the staff and industry representatives.
These issues and their resolutions are:
1.
Mild Environment i
I The staff believes that the requirements for equipment located in mild environments are not " qualification requirements" but "E requirements." The staff further believes that the general quality and surveillance requirements applicable to safety-related equipment as a result of other Commission regulations (including 10 CFR Part 50, Appendix B) and Regulatory Guide 1.33 are sufficient to ensure the adequate performance of safety-related electric equipment located in a mild environment.
The final rule doas not include the safety-related equipment located in mild environments.
i 2.
Cold Shutdown The industry stated that the rule introduces a new requirement to qualify equipment needed to complete one path of achieving and maintaining a cold shutdown condition, and that a change of this magnitude, at this advanced stage of industry's qualifi-cation effort, introduces significant new costs and obligations with no demonstrated improvement in safety.
The staff agrees that this is a new requirement that may introduce significant costs. The licensing basis of the majority of operating reactors does not require that all electric equipment and systems neccessary to bring the reactor from normal operating conditiocs to cold shutdown be designed to Class 1E standards.
Therefore, to require tha',all plants environmentally qualify the electric equipment and systems needed to complete one path of achieving and maintaining a cold shutdown condition may require the upgrading of a significant amount of e'quipment and systems that do n6t currently meet Class 1E standards for operating reactors.
However, electric equipment and systems necessary to mitigate the consequences of design basis accidents should be required to meet Class 1E standards for all reactors and therefore, would be covered by the rule.
The staff is currently studying the requirements for shutdown decay heat removal under Unresolved Safety Issue (USI) A-45.
The overall purpose of A-45 is to evaluate the adequacy of current licensing requirements to ensure that failure to remove.1utdcwn de.:ay h 2t doec not pose an unacceptable risk:
Und:.it A-45 a c"aprehensive and consistent
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set of shutdown cooling requirements for existing and future plants are being developed.
The final resolution of A-45 is presently scheduled for October 1984.
The staff believes it would be premature at this time to impose the requirement to environmentally qualify electric equipment and systems necessary to achieve and maintain cold i
shutdown prior to the final resolution of A 45.
Therefore, i
this requirement is not included in the final rule.
3.
Seismic and Dynamic Qualification Some commenters stated that seismic and dynamic qualification are an integral part of environmental qualification.
It is-therefore inappropriate to codify these requirements separately.
Safety-related electric equipment at operating nuclear power plants was generally qualified for environmental and seismic stresses separately, i.e., by using separate prototypes for environmental and seismic qualification tests. This issue will be pursued at a future date through the issuance of an advance notice of proposed rulemaking.
Any seismic qualification testing of equipment in operating plants that aay be required by future rulemaking will not require retesting for environmental stresses solely because a single prototype was not used during the original qualification.
The final rule does not cover seismic and dynamic qualification.
l 4.
Previous Qualification Efforts The irriustry stated that the proposed rule did not recognize that l
operating plants have just completed qualification of equipment to the 00R Guidelines or NUREG-0588.
Without such recognition, industry efforts will go down the drain.
The final rule does not require requalification of equipment previously qualified.
5.
Central File The industry stated that the requirement for a central file is not cost effective and has no safety benefit.
The staff has deleted this requirement from the final rule.
However, a record of qualification must be maintained in an "auditable form" but not necessarily in a " central file."
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l Review by Advisory Committee on Reactor Safeguards (ACRS)
Staff met with the ACRS Subcommittee on Qualification Program for Safety-Related Equipment on May 5, 1982, and the full ACRS on May 7, 1982.
ACRS has raised the following istaes:
1.
Deferment of the seismic response and cold shutdown require-ments fragments the qualification.
The staff views on this issue are stated earlier.
2.
Issuance of the revision to Regulatory Guide 1.89, " Environ-mental Qualification of Safety-Related Electric Equipment for Nuclear Power Plants," should be expedited.
The issuance of Regulatory Guide 1.89 will be expedited.
Issuance is expected in September 1982.
3.
Industry has c'laimed that it will be difficult to comply with the new rule and that heavy financial burdens will be incurred in qualifying equipment.
These industry concerns were based on:
a.
the requirement for qualification of electric equipment needed for cold shutdown.
b.
the requirement for qualification of equipment located in a mild environment.
c.
the requirement for a central file.
All these requirements have been deleted from the final rule.
Review by Committee to Review Generic Reouirements (CRGR)
During the review on May 12, 1982, CRGR raised the following issues:
1.
Previous qualification efforts should be in clear language.
A new paragraph 50.49(k) has been added.
2.
The scope of equipnent covered by the rule should be con-sistent with current staff policies.
The equipment and systems covered by the final rule have been classified as " safety-related."
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Tha Commissioners 5-3.
The* rule should address the question of replacement parts.
Specific guidance on replacement parts will be included in Regulatory Guide 1.89.
The licensees and applicants are expected to utilize the replacement process to upgrade the quality of electric equipment to the provi-sions of this rule.
4.
The requirement for equipment located in a mild environment should be deleted.
The' final rule has been modified accordingly.
See para-graph 50.49(a).
Recommendation:
That the Commission:
1.
APPROVE a..
Publication of'the final rule $50.49, !' Environmental Qualification of Safety-Related Electric Equipment for Nuclear Power Plants," as an amendment to 10 CFR Part 50 to be effective upon publication in the Federal Register (Enclosure 1).
b.
In order to satisfy the requirements of the Regulatory Flexibility Act 5 U.S.C. 605(b), certify that this rule, will not have a significant economic impact on a sub-stantial number of small entities.
This final rule affects only the licensing and operation of nuclear power plants.
This finding is made in the enclosed Federal Register notice.
l 2.
NOTE a.
That the final rule should take immediate effect upon publication because it relieves a restriction under sub-section (d)(1) of Section 553 of the Administrative Proce-dure Act.
This is so because all operating reactor licensees are currently under a June 30, 1982, deadline to complete environmental qualification of safety-related electric equipment.
The final rule's implementation schedule, as explained above, supplants this date and thus gives licensees additional time to complete environmental i
qualification of safety related electric equipment.
In-l addition, the Commission finds that there is good cause-pursuant to subsection (d)(3) of Section 553--to make the rule's requirements effective upon publication.
The first licensee actions under the rule are not required until 90 days after the effective date of the rule.
This 90-day period is intended to include the s:..tutory 30 days and allow 60 additional days to make the submitta! required 1
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The Commissioners 6
by paragraph 50.49(g) of the rule.
The overall effect of making the rule effective on publication is to relieve licensees of the June 30, 1982, deadline and to provide a sufficient period after the effective date of the rule for licensees to achieve compliance with the near-term requirements of the rule.
b.
That the information collection requirements in this final rule have been submitted to the Office of Management and Budget as a part of tha general clearance for 10 CFR Part 50.
That, pursuant to paragra c.
Commission's. regulations,ph 51.5(d) of Part 51 of the neither an environmental impact statement nor a negative declaration need be prepared in connection with the amendment since the amendment is nonsubstantive and insignificant from the standpoint of environmental impact.
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d.
That the Subcommittee on Energy and the Environment of the House Committee on Interior and Insular Affairs, the Subcommittee on Energy Conservation and Power of the House Committee on Energy and Commerce, the Subcommittee on Environment, Energy and Natural Resources of the House Committee on Government Operations, and the Subcommittee on Nuclear Regulation of the Senate Committee on Environment and Public Works will be informed.
That the Federal Register Notice' of final rulemaking will e.
be distributed by the Office of Administration to power reactor licensees / permit holders applicants for a construction permit for a power r,eactor, public interest l
groups, and nuclear steam system suppliers, and all other interested persons.
f.
That a public announcement will be issued.
That the Chief Counsel for Advocacy of the Small Business g.
Administration will be informed of the certification and the reasons for it as required by the Regulatory Flexibil-ity Act.
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Sch:duling:
Recommend this rule be considered at an open meeting.
Commission approval is needed by June 18, 1952 in order to ensure publication in the Federal Register Notice by June 30, 1982.
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- h. William J. Dircks t
Executive Director for Operations
Enclosures:
1.
Federal Register Notice for Final Rulemaking 2.
Analysis of Public Comments 3.
Value/ Impact Statement Ccmnissicners' cxxrents or consent should be provided direct].y to the Offi of the Secretary by cob Wednesday, June 9,.1982.
g Ccmnission Staff Office carents, if any, should be sutreitted to t% Ccmissioners NLT Wednesday, June 2,1981, with an infortration copy to the Office of the Secretary.
If the paper is of such a nature that it requires additional tire for analytical review and c2 rent, the cemmusicners and the Secretariat shculd be apprised of when ccnments tray be expected.
a.: :_
This paper is tentatively scheduled for affir: ration at an Open meeting during t%
week of June 7, 1982. Please refer to the apprcpriate weekly Ccmission Schedule, when published, for a specific date and time.
DISTRIHRIOT Ccmnissioners Ccmnission Staff Offices EDO OEID ACPS ASLEP ASIAP l
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ENCLOSURE 1 e
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[7590-01]
t NUCLEAR REGULATORY COMMISSION 10 CFR Part 50 E'nvironmental Qualification of Safety-Related Electric Equipment
' for Nuclear Power Plants AGENCY:
Nuclear Regulatory Commission.
ACTION:
[ Proposed] Final _ rule.
The [Heciear-Regeistory] Commission is [preposing-te] amending
SUMMARY
its regulations applicable to nuclear power plants to clarify and strengthen
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the criteria for environmental qualification of safety-related electric
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Specific qualification methods currently contained in national equipment.
standards, regulatory guides, and certain NRC publications for equipment qualification have been given different interpretations and have not had the legal force of an agency regulation. This amendment [The preposed raie-wenid] codifyies the[se] environmental qualification methods and criteria that meet the [and-ciarify-the] Commission's requirements in this area.
EFFECTIVE DATE:
[UPON oublication in the. Federal Reaister]
Eemment peried expires (60 days after publication in the
[ BATES-FederaiRegister3-Eemments received after ------------ wiii be considered if it is practical to de so-but asserance of censideration cannot be given except as to comments received on or before this date-Written cemments and suggestions may be mailed to the ABBRESSES-1
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[7590-01]
Secretary of the Eemmission; Attentient Becketing and Service Branch; 8:S; Neeiear Regeistory Eemmission; Washington; B:E: 28555; or hand-delivered to the Eemmission's Pebiie Becement Reem at 1717 H Street NW:-- Washington;- 8:E:7 between the-heers of 8:30 a:m: and 4:45 p:m: en normai work days ]
FOR FURTHER INFORMATION CONTACT:
Satish K. Aggarwal, Office of Nuclear Regulatory Research, [Eiectrical Engineering Branch;] U.S. Nuclear Regula-tory Commission, Washington, D.C. 20555, Telephone (301)443-5946.
SUPPLEMENTARY INFORMATION:
Previous Notice On January 20, 1982, NRC published in the Federal Register'a notice of crocosed rulemakina on environmental cualification of electric eouio-ment for nuclear power plants (47 FR 2876).
The comment oeriod expired March 22, 1982.
A total of 69 comment letters raisina 10 major issues were received by Acril 6, 1982.
An additional 10 comment letters were received by April 21, 1982, but no new issues were raised.
The major issues are discussed below.
Nature and Scoce cf the Rulemaking Nuclear power plant equipment important to safety must be able to perform the safety functions throughout its installed life.
This require-ment is embodied in General Design Criteria 1, 2, 4, and 23 of Appendix A,
" General Design Criteria for Nuclear Power Plants," to 10 CFR Part 50,
" Domestic Licensing of Production and Utilization Facilities"; in Cri-terion III, " Design Control," and Criterion XI, " Test Control," of Appen-dix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel 2
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[7590-01]
e Reprocessing Plants," to 10 CFR Part'50; and in paragraoh 50.55a(h) of 10 CFR Part 50, 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 requirements are met for safety-related 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 1,1374, the Commission has used Regulatory Guide 1.89,
" Qualification of Class 1E Equipment for Light-Water-Coolad Nuclear Power Plants," which endorses IEEE 323-1974,2 "IEEE Standard for Qualifying Class I,E Equipment for Nuclear Power Generating Stations," subject to supplementary provisions.
Currebtly, the Commission has under way a program to reevaluate the qualification of electric equipment in all operating nuclear power plants.
As a part of this program, more definitive crit.eria for environmental qualification of safety-related electric equipment [important-to-safety]
have been developed by the NRC.
A document entitled " Guidelines for Evaluating Environmental Qualification of Class 1E Electrical Equipment in Operating Reactors" (00R Guidelines) was issued in November 1979.
In addition, the NRC has issued NUREG-0588, " Interim Staff Position on 1 Incorporation 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 Yc k, N.Y.10017.
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l Equipment," which Environmental Qualification of Safety-Related Electrica the first for plants originally reviewed contains two sets of criteria:
ts reviewed in a
l 323-1971 and the second for p an in accordance with IEEE 323-1974.
accordance with IEEE 1980, the ByitsSemorandumandOrderCLI-80-21datedMay23, a
l king on environ-Commission directed the staff to proceed with a ru ema d to address the ques-mental qualification of safety grade equipment an The Commission also directed that the 00R G tion of backfit.
licensees and appli-and NUREG-0588 form the basis for the requirements ltd This proposed cants must meet until the rulemaking has been comp e e.
Division of Operating rule is genersify based on the requiraments of the i
Recualification of electric Reactors (00R) Guidelines and NUREG-0588. l not be required eouloment in accordance with this rule wil DDR Guidelines or NUREG-0588 oualified or beino qualified in accorcance with nt has commenced orior tq i
provided the cualification of electric eou eme i mendment]._
[ Insert a date 90 days after the effective date of th s a i
mental _
The dates soecified in this rule for completion of env ron ly to all licensees _
oualification of safety-related electric couiement aco l
imoosed.
No changes tq and acolicants and supersede any date previous y flect these licenses or technical soecifications are necessary to re new comoletion dates _.
t d that the
[The Eemmission's Memorandum and Order E t in eperating neciear i
environmentai qualifiestion of efectrie equ pmenHeweveri en S 1982-pewer piants be cempieted by dene-387 1 4863 to extend this the Eemmission considered the petition (SEEY 19817 4
[7,590-01]
The preposed rule eevers the same electric equipment as deadline:
Ebi-80-El and implements SEEY-81-486 by incorperating the extension date recemmended by the Ghairman in his memerandem-dated September Incinded in the preposed rule is a requirement that each heider of or each appiicant for a license to operate a n=ciear power piant identify n
and quaiify the electric equipment needed to complete one path of The Eemmission achieving and maintaining a ceid shutdewn cendition:
specifically requests comment en this preposed additional requiremen The scope of the [preposed] final _ rule does not include all electric It equipment important to safety in its various gradations of importance.
[ includes] covers that portion of equipment important to safety commo referred to as " safety-related." [er.u61 ass-iEu-equipment-in-iEEE-natio standards-and-some additionai-non-Siass-iE-equipment-and-systems-whose failure-ender-extreme-environmentai-cenditions-cosid prevent-the-satis-fettery-accomplishment-of-safety-fenetiens-by-accident-mitigating equipment ] Safety-related electric eouipment is essentially " Class 1E eouipmentdsdefinedinIEEE 323-1974'.
Included in the (preposed] final _ rule are specific technical require ments pertaining to (a) qualification parameters, (b) qualification meth Qualification parameters include temperature, and (c) documentation.
Qualification pressure, humidity, radiation, chemicals, and submergence.
d methods include (a) testing as the principal means of qualification an The [propesed]
(b) analysis and operating experience in lieu of testing.
final _ rule weeid requires that the qualification program include syn
- Also, effects, aging, margins, radiation, and environmental conditions.
I Procosed Revision 1 to a record of qualification must be maintained.
j Regulatory Guide 1.89, [is being revised te] which has been issued fo 5
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public comment, will describe methods acceptable to the NRC for meeting the provisions of this [ proposed] rule and [te] will include a list of typical equipment covered by it [a-draft-of-the proposed]. Revision 1 Eis-being pebiished-for pebiie-eemment-concerrentir with-the proposed-reier to Reculatory Guide 1.89 will be issued after resolution of public i
Soecific guidance on reolacement parts will be included in comments.
The Commission exoects that licensees and acoli-Regulatory Guide 1.89.
cants will utilize the replacement crocess to upgrade the cuality of electric equioment to the provisions of this rule.
[Aiso-incieded-in-the proposed-reie-is-a-requirement--which-is-censis te nt-wi th-Eemmi s s i e n-Memo r andem-and-B rde r-- EEf El-- f o r-s ub y
of-an-analysis-by-iieensees-to-ensere-that-the piant-esn-be-safely-operated pending-eempletien-of-the-environmentai qualification-of-electrie-eqeip-mentr--The-Eemmission expects-that--for-each-ef-the-currently-eperating power piants--this-analysis-and-its-evaiestion-by-the-NRS-staff-wiii-be completec weli-in-advance-of-the-effective-date-of-this-reier--if-the licensees-of-eperating pewer piants-faii-to provide-these-analyses-in-a ti mely-manner-- th e-G e mmi s s i o n-exp e cts - th e-NRE-s taf f-to-take-the-ap p re-priate-steps-to-require-that-the-information-be provided-and-to-enforce compii ance-wi t h-thi s-re qui re me n t---Thi s-requi reme nt-has-b e e n-i n ei e d this preposed-reie-to provide-a-regeistory-basis-for-enforcementr]
l 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 To ensure integrity of a testing procram, the same event conditions.
piece of eauiement must be used throughout the comolete test secuence.
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[ Analysis-may-be-acceptable-if-testin'g of-the quipment-is-impractical because-of size; or-limitation-dee-to-the state-of-the-art:--ifie pre-posed-ruie-tak.es-inte-consideratien-the prier qualification-history of the-eperating pewer plants:--For exampie--the proposed reie-recognizes that-for-these piants-which-are not-cemmitted-to either-iEEE-323-1971-or IEEE-323-1974-for equipment qualifiestion; and-have-been-tested eniy-for high-temperature pressure;-and steam 7 seme-equipment-may-not-need-to-be tested-again-to-inciede-ether service-cenditions-such-as-radiatien-and chemicai-sprays:--The qualification-of equipment-for-these-service-condi-tiens-may-be-established-by-analysis:]
The [preposed] final rule weeld requires, that each holder of an operating license provide a list of safety-related electric equipment previously qualified based on testing, 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 weeld-have-to must be submitted written by [ Insert a date 90 days after the effective date of this amendm'ent]. refer (Hewever7-this-time peried-wiiae-adjested-dering-the-final-ruie-making process-to-allow reasenabie-time-for-iieensees-te evalcate-NRE2s-safety-reviews-that-are-currently enderway.
The preposed-reie wiii-codify-the-Ecemissien's-cerrent requirements
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for-the environmentai qualification-of electrie equipment:--Upon publica-tien-of-a-finai-reie7-the-88R guidelines-and-NBRE6-0588-wi44-be-withdrawn:]
The general requirements for seismic and dynamic qualification for electric equipment are contained in the General Design Criteria.
Pending I
development of specific requirements in this area, the general require-ments will continue to apply.
NRC is considering expansion of the scope 7
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t of this rule to include additional electric equipment important to safety.
This matter will be the subject of a future rulemaking.
[ Addi ti o nsi-v i ews-of-E emmi s si o ne r-B rs df e rd--- Se=mi s si oner-B believes-thst-the preposed-desdiine-(second-refeeiing-eetage-after Harch-31--19823-for qualifiestion-is-mech-tec-reiaxed; given-the-fact i
thst-iieensees-and-the-NRS-have-been-aware-of-the probiems-in-this-ares since-1978---The proposed-deadline-extends-as-mech-as-two-and-ene-half ye ars-b ey o nd-th e-d e n e-30;-1983-date-by-w hi ch-the-Atemi c-ind us tri ai-Fo re eencieded-that-nesriy-sii-electriesi-equipment-ceeld-be qualified.
Given-the-more generees-desdiine;-he-sise-believes-that-the-reie-shecid have-centsined-requirements-for-s,eismie-and-dynsmie qesiifiestien---While 1
the genersi-design-criteria-contain-requirements-in-this-area;-clarifies-ti o n-new-we el d-ens er e-that-e qui pme n t-to-b e-re pi s ce d-i n-the-ne ar-term-will net-hsve-to-be-ripped-ect-in-a-few years-beesese-it-was-net preperly seismiesily qcsiified-6emmissioner-Siiinsky-has-agreed-with-these-views-]
Comments On The Proposed Rule The Commission received and censidered the comments on the prooosed rule contained in the 69 letters received from the public by Aoril 6, 1982.
Copies of those letters and a staff resconse to each comment are available i
for cublic inspection and cooying for a fee at the Commission's Public Single cooies of Document Room at 1717 H Street NW., Washington, D.C.
the analysis of the comments may be obtained throuch written reouest to i
the Office of Administration, Document Manacement Branch, U.S. Nuclear l
Regulatory Commission, Washington, O.C. 20555.
The major issues raised by the comments and NRC staff responses are as follows:
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[7,590-0,1]
(1) Seismic and Dynamic Qualification - Paragraoh 50.49(a) 1 Issue:
Seismic and dynamic qualifications are an integral part of environmental qualifi'ation.
It is therefore inacoropriate to c
codify these requirements separately.
i
Response
Safety-related electric equioment at ooerating nuclear power plants was generally qualified for environmental and seismic stresses separately, i.e., by using separate prototypes for environmental and seismic qualification tests.
The Commission has decided, after considerable deliberation, to oursue this issue at a future date through I
the issuance of an advance notice of proposed rulemaking.
Any seismic qualification testing of equipment in ooerating plants that may be required by future rulemaking will not require retesting for environmental stressesso1@lybecauseasingleprototypewasnotusedduringtheoriginal qualification.
(2) Scoce - Cold Shutdown Requirement - Paragraph 50.49(c) l Issue: The rule introduces a new requirement to qualify " equipment needed to amplete one path of achiev'ing and maintaining a cold shutdown condition." A change of this magnitude, at this advanced stage of the industry's qualification effort, most certainly introduces significant 9]
new costs and oblications with no demonstrated improvement in safety.
Resconse:
The Commission agrees that this is a new requirement that may introduce significant costs.
The licensing basis of the majority of L
operating reactors does not require that all electric equipment and systems necessary to bring the reactor from normal operating conditions ll to cold shutdown be designed to Class 1E standards.
Therefore, to I,
require that all plants environmentally qualify the electric equipment
)
and systems needed to comolete one path of achieving and maintaining I
9
J
[7590-01]
i.
a cold shutdown condition may require the uograding of a significant amount of eouioment and systems that do not currently meet Class 1E standards for coerating reactors.
However, electric eouiement and systems necessary to mitigate the consequences of design basis accidents should be required to meet Class lE standards for all reactors and there-fore, would be covered by the rule.
1 The Commission is currently studying the recuirements for shutdown decay heat removal under Unresolved Safety Issue (USI) A-45.
The overall purpose of A-45 is to evaluate the adequacy of current licensing recuire-ments to en:ure that failure to remove shutdown decay heat does not pose l
an unacceptable risk.
Under / 45 a comorehensive and consistent set of
\\
shutdown cooling requirements for existing and future plants are being developed.
The final resolution of A-45 is presently scheduled for October 1984.
The Commission believes it would be premature at this time to impose the requirement to environmentally qualify electric eouipment and systems necessary to achieve and maintain cold shutdown prior to the final resolution of A-45.
Therefore, this requirement is not included in the final rule.
(3)
Scoce - Eouiement in a Mild Environment - Paragraph 50.49(c)
Issue:
The rule makes no distinction between eouioment located in a harsh or mild environment.
The stresses for equioment in a mild environment are less severe than for those in a harsh environment.
j
Response
The final rule does not cover the electric equipment i
located in a mild environment.
The Commission has concluded that the general quality and surveillance recuirements acolicable to safety-related electric equipment as a result of other Commission regulations, 10 l
1
i,-
[7590-01]
l including 10 CFR Part 50, Apoendix B'(see for examole, Regulatory Guide 1.33) are sufficient to ensure adeouate performance of safety-related electric equi'pment located in mild environments.
Since it has been concluded that no further environmental cualification reouirements are needed for such eouipment provided they fully satisfy all other applicable regulations, the Commission has determined that no additional requirements are necessary with resoect to safety-related eouioment located in mild environments in order for licensees to satisfy, with respect to such eouipment, existing license conditions or technical s[ecifications calling for qualification of safety-related electric equipment in accordance with 00R Guidelines or NUREG-0588.
f4] Scope - Previous Qualification Efforts - Paragraoh 50.49(c)
Issue:
The rule does not recognize that operating plants have just comcleted qualification of eouioment to the DOR Guidelines or NUREG-0588.
Without such recognition, industry efforts, mancower, and billions of dollars will go down the drain.
Respon'se:
The final rule has been exoanded to alleviate this concern.
I (5) Humidity - Paragraph 50.49(e)(2)
Issue:
The effects of time-decendent variations of relative humidity I
during normal oceration cannot be considered for all equipment.
There are no detailed standards for how this type of testing should be performed.
Resoonse:
The Connission agrees.
The words " Time-decendent variation
(
of relative" have been deleted from Paragraoh 50.49(e)(2).
(6) Aging - Paragraph 50.49(e)(5)
Issue:
The reouirement that engoing oualifications be done using
" prototype equipment naturally aged" is overly restrictive.
Use of i
11
[7590-01]
I is not technically accelerated aging to define a cualified life
' 8' this feasible.
Paragraph 5d.49(e)(5) has been modified to alleviate
Response
concern._
Margins - Paragraoh 50.49(e)(81 a
i lead The margins acolied in addition to known conservat sms (7) l psue:
of equioment in unrealis-_
l to excessive stress that could lead to fai ures This paragraph is in conflict with Regulatory tic qualification tests.
Guide 1.89._
The paragraoh has been modified The Commission agrees.
Resconse:
I 1
()k41 accordingly.
Analysis and Dartial test data - Paragraph 50.49 f If partial tyoe test data that adeouately succort the (8) ilable, their analysisL Issue:
a_nalytical assumotions and conclusions are ava these results for should be allowed to extracolate or in'terpolate eouipment, regardless of purchase date. Reference to " purchase The Commission agrees.
Response
t.as been deleted._
(fl Recuirement for a central file - Paragraoh 50.49d since The recuirement for a central file should be de
{9)
Issue:
fi t._
it is not cost pffective and has no safety beneThe reautrem The Commission acrees.
Resoonse:
has been deleted._
l ts._
Justification of continued coeration for operatino o an ti nue_d (10)
The recuirement to submit justification for the con I_ssue:
d since this information coeration of coeratino plants should be delete has been previously submitted to NRC..
12
[7590-01]
Response
This reouirement has'been satisfactorily met and Paragraph 50.49(j) of the prooosed rule has been deleted in its entirety i
from the final rule.
- In addition, Paragraph 50.49(g) of the prooosed rule has been deleted from the final rule since it is too prescriptive.
It will be included in Regulatory Guide 1.89.
Effective Date:
This rule is effective uoan publication in the Federal Register.
The Commission has determined that the final rule should take immediate effect uoan publication because it relieves a restriction under sub-section (d)(1) of Section 553 of the Administrative Procedure Act.
This is so because ill operating reactor licensees are currently under a June 30, 1982, deadline to comolete environmental qualification of safety-related electric equioment.
The final rule's imolementation schedule, as exclained above, sucolants this date and thus gives licensees additional time to comolete environmental cualification of safety-related electric ecuioment.
i t
In addition, the Commission finds that there is good cause--pursuant to subsection (d)(3) of Section 553--to make the rule's requirements effec-tive uoan oublication.
The first licensee actions under the rule are not reouired until 90 days after the effective date of the rule.
This 90-day period is intended to include the statutory 30 days and allow 60 additional l
days to make the submittal required by Paragraoh 50.49(o) of the rule.
The overall effect of making the rule effective on oublication is to relieve licensees of the June 30, 1982, deadline and to provide a sufficient period after the effective date of the rule for licensees to achieve ccmoliance with the near-term recuirements of the rule.
13
i
[7590-01]
Paperwork Reduction Act The [ proposed] final rule contains recordkeeping requirements that i
are subject to review by the Office af Management and Budget (OMS).
As required by P.L.96-511, thise proposed rule [wiii-be] was 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 premuigated-]
will not have a significant economic impact on a substantial number of This [ propose,]. final rule affects the method of qualifica-d small entities.
\\
tion of electric equipment by utilities.
Utilities do not fall within the definition of a small business found in Section 3 of the Small Business Act, 15 U.S.C. 632.
In addition, utilities are required by the Commission's Memorandum and Order CLI-80-21, dated May 23, 1980, to meet the requirements contained in the 00R " Guidelines for Evaluating Environmental Qualification of Class 1E Electrical Equipment in Operating Reactors," (November 1979) and NUREG-0588, " Interim Staf f Position on Environmental Qualification of Safety-Related Electrical Equipment," which form the basis of this [ proposed]
rule.
Consequently, this rule codifies existing requirements and imposes no new costs or obligations on utilities.
List of Subjects in 10 CFR Part 50 Antitrust, Classified information, Fire prevention, Intercovern-mental relations, Nuclear power olants and reactors, Penalty, Radiation protection, Reactor siting criteria, Reporting reouirements.
I 14
1
[7590-01]
Pursuant to the Atomic Energy Adt 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-adeption of-thethe following amendment to Title 10, Chaoter I, Code of Federal Regula-tions, Part 50, 10-6FR-Part-58-is-centemplated is oublished as a docu-4 ment subject to codification.
The authority citation for Part 50 continues to read as follows:
AUTHORITY:
Secs. 103, 104, 161, 182, 183, 185, 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 also issued under sec. 184, 68 Stat. 954, as amended \\(42 U.S.C 2234).
Sections. 50.100-50.102 issued under sec. 186, 68 Stat. 955 (42 U.S.C. 2236).
For the purposes of sec. 223, 68 Stat 958, as amended (42 U.S.C.
2273), SS50.10(a), (b), and (c), 50.44, 50.46, 50.48, 50.54, and 50.80(a) are issued under sec.161b, 68 Stat. 948, as amended (42 U.S.C. 2201(b));
SS50.10(b) and (c) and 50.54 are issued under sec. 1611, 68 Stat. 949, as amended (42 U.S.C. 2201(i)); and SS50.55(e), 50.59(b), 50.70, 50.71, 50.72, and 50.78 are issued under sec. 161o, 68 Stat. 950, as amended
~
(42 U.S.C 2201(o)).
i i
15
~
[7590-01]
2.
A new $ 50.49 is added to read as follows:
5 50.49 Environmental qualification of safety-related electric equipment for nuclear power plants.
(a) Requirements for seismic and dynamic qualification of safety-related electric equipment are not included in this section.
Also not included are the requirements for safety-related electric eouioment located in a mild environment.
A mild environment is an environment that would at no time be significantly more severe than the environment that would occur during normal plant operation or during anticioated operational occurrences.
(b) Each holder of or each applicant for a license to operate a nuclear power p-lant shall establish a program for qualifying the electric equipment as defined in paragraph (c) of t:11s section.
(c) Safety-related electric equipment and systems covered by this section include electric equipment and systems that are [essentiai-te emergency reacter-shetdown--centainment-isciation-reacter-core-ceciing-and-centainment-and-reacter-heat-removai-er-that-are-otherwise-essential in preventing-significant-release-of-radioactive-materiai-to-the environ-ment---inc~.oded-is equipment-(13-that performs-the-above-fenetiens-acto-maticaliy--(23-that-is-esed-by-the-eperater-to perform-these-fenetions l
l manually--and-(33-whose-faifere-can prevent-the-satisfactory-accemplish-ment-of-ene-or-mere-of-the-above-safety-functions----Aise-incieded-is equipment-needed-to-cempiete-ene path-of-achieving-and-maintaining-a ceid-shetdewn-condition-] designed to remain functional for costulated i
l accidents and are necessary to assure (1) the integrity of the reactor coolant pressure boundary, (2) the caoability to shut down the reactor and maintain it in a safe condition, and (3) the capability to prevent i
16 l
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[7590-01]
or mitigate the consecuences of accidents which could result in poten-tial offsite exoosures comoarable to the 10 CFR Part 50 quidelines.
(d) The applicant or licensee shall prepare a list of ali safety-related electric equipment covered by this section.
[and-maintain-it-in an-ac'ditabie-forms---This-list-of equipment-mest--as-a-minimem--inciede-]
In addition, the acolicant or licensee shall include the following information for safety-related electric eouioment in a cualification file:
(1) The performance specifications [and-structurai-integrity require-ments] under conditions existing during normal and abnormal operation and during design basis events and afterwards. [and-the-iengths-of-the perieds during-which-the-integrity-mest-be-maintained-]
(2) [The range-of] The 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 con'ditions, including temperature, pressure, humidity, radiation, chemicals, and submergence [and-the predicted-varia-tions of-tYese environmentai-cenditichs-with-time] at the location where the equipment must perfom as specified in accordance with paragraphs (d)(1) and (2) of this section.
(e) The electrical' equipment qualification program must include the following:
(1) Temoerature and Pressure.
The time-dependent temperature and pressure at the location of the equipment must be established for the ecost [iimiting] severe of the applicable [posteisted-accidents] design basis events and must be used as the basis for the environmental qualification of safety-related electric equipment.
l 17
i
[7590-01]
(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 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-dese-rate-of-the-radiatien-environment]
2 1
expected during'normel operation over the installed life of the equipment,
[ pies] and 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 recirculating fluids for equipment located near the recirculating lines and including dose-rate effects.
(5) Aging.
Equipment qualified by test must [practicabie] be preconditioned by natural or artificial (accelerated) aging to its installed end-of-life condition.
[Eiectromechanicai-equipment-mest-be opersted-to-the-mechanicai wear-and aiectricai-degradation-expected-dering its-instailed-fife-] M Where preconditioning to an installed end-of-life condition [a qualified-iife-equai-to-the-instalied-life] is not [pessibie]
i practicable and technically meaningful, the equipment may be preconditioned to a shorter [qesiified) designated life. The equipment must be replaced or refurbished at the end of [its qualified] this designated life unless i
l ongoino cualification (of] demonstrates [pretetype-equipment-natersiiy-aged l
18 f
[7590-0,1]
~
in plant-service-shew--by-artificiai-aging-and-type-testing] that the item has additional [ qualified] life.
(6) Submergence'(if subject to being submerged).
(7) Synergistic Effects.
[The preconditioning-and-testing-of-equip-ment-mest-consider-knewn] Synergistic effects must be considered when these effects are [known] believed 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-environmental conditions-] any conservatisms acolied during the derivation of environ-mental conditions unless these conservatisms can be quantified and shown to contain aoorocriate maroins.
(f) Each item of safety-related 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'succorting analysis to show that the eouipment to be cualified is acceptable.
(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 similar conditions with a supporting analysis to show that the equipment to be qualified is acceptable.
[( 43 - A n niy s i s -i n-i i e u-o f-t.e s ti n g-i n-th e-f e i i ewi n g-c a s e s - :
l (i3--if-type-testing-is preieded-by-the physicai-size-of-the-equip.
l ment-or-by-the-state-of-the-art-]
i i
19
l
[7590-01]
(4) fii) [By] Analysis in combination with partial type test data
[which] that supports the analytical assumptions and conclusions.
[7-if-the equipment perchase-order-was-executed prier-to-May-23 -1980.
7 (g3--if an-item-ef-electric-eqc.ipment-is-to-be qualified-by-test--
(13--The-acceptance-criteria-mest-be-established prier-to-testing:
(23--The-tests-mest-be-designed-and-conducted-to-demonstrate-that the-equipment-can perform-its-required-functien-as specified-in-accerd-ance-with paragraph-fd3(13-of-this-section-for-ali-conditions-as-speci-fied-in-accordance-with paragraphs-(d3(23-and-(33-ef-this-section:--The test profiie-te:g:- pressere--temperature;-radiation-vs:-time 3-must inciede-margins-as-set-forth-in paragraph-fe3(8,3-of-this-section:
(33--The-test profiie-mest-be-either-fi)-a-singie p\\refile-that l
- c. veieps-the-environmentai-conditions-resciting-frem-any-design-basis e v ent-dering-any-mede-of piant-eperation-fe g---a profile-that-envelops l
~
he-cenditions produced-by-the pestulated-spectrem-of-main-steemiine break-(MSEB3-and-ioss-of ceciant-seeidents-(ESEA33-er-fii3-separate pre-files-for each-type-of-event-fe:g:--separate profiles-for-the-MSEB-acci-dents-and-for-teEAsht (43--The-same piece-of-equipment-mest-be-used-threegheet-the-complete test-sequenes-ender-any given profiie;]
[(h3] B)_ Each holder of an operating license issued prior to (insert the effective date of this amendment) must, shall, by (insert a date 90 days after the effective date of this amendment), identify the safety-related electric equipment already qualified to the provisions of this rule and submit a schedule for the cualification [ testing] or replacement of the remaining safety-related electric equipment.
This schedule must establish a goal of final environmental qualification by the end of the second 20
[7590-0,1]
refueling outage after March 31,1985.
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 [sech]
these requests 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.
[(i3] (h) Each licensee shall notify the Commission of any signifi-cant equipment qualification problem that may require extension of the completion date within [30] 60 days of its discovery.
[(j)--For-the-continued-eperatien-of-a-neelear piant-each-heider-of an-eperating-4icense.sseed prier-to-the effective-date-of-this-reie-shah perform-an-analysis *.e-ensere-that-the piant-ean-be-safeiy-eperated pending completion-of-the-environmentai qualifiestion---The-detailed-anaiysis-for each equipment-type-with-sppropriate-justificatien-mest-be-schmitted-to
\\
Bi re c t o r-o f-N e ci e ar-R e a cte r-R e g ul ato ry-by-(i n s e rt-th e-eff e c ti v e-date-o f the-ruie)-and-mest-inciede-where-appropriate--eensideratien-of:
(13--Accompiishing-the-safety-functien-by-seme-designated-af ternative f
equipment-that-has-b len-adequately qualified-and-satisfies-the-singie failure-criterien-if-the principai-equipment-has not-been-demonstrated-to be-feliy qualified-I-
l (23--The-vaiidity-ef partiai-test-data-in-support-ef-the-original l
qualificatien-(33 -- t. i mi ted-us e-o f-admi ni s trati v e-ce ntroi s-ev e r-e qui pme nt-th at-h a s i
not-baen-demonstrated-to-be-fcliy gesiified-1 I
l l
21
[7590-01]
(43--Eempietion-of-the-safety-fenetion prier-to-exposure-to-the-ense-ing-accident-environment-and-the-subsequent-failure-of-the-equipment-dees i
net-degr ide-any-s af ety-f eneti en-er-mi si e sd-the-operaterr
( 53 - - N o-si gni fi cant-degradati e n-o f-a ny-s af ety-f eneti e n-e r-mi si e sdi ng ef-the-operator-as-a reseit-of-f ailure-of-equipment-ender-the-setident environmentr]
[fk3] (i) The applicant for an operating license that is granted on or after [ insert the effective date of this amendment] but prior to November 30, 1985, mest shall perform an analysis to ensure that the plant can be safely operated pending completion of environmental qualification.
[in-accordance-with paragraph-fj)-ef,-this-section-except-that-this-analysis]
This analysis must be submitted to the Director of Nuclear Reactor Regulation for consideration prior to the c. anting of an operating license ar f must include, where aooropriatr, consideration of:
Accomolishing the safety function by some designated alternative (1) equicment if the principal eouioment has not been demonstrated to be fully qualified.
(2) The validity of cartial test data in succort of the original qualification.
(3)
Limited use of administrative et,trols over eouioment that has not been demonstrated to be fully cualified.
(4) Comoletion of the safety function orior to exoosure to the ensu-ino accident environment and the subsecuent failure of the eouiement does
/
not degrade any safety function or mislead the operator.
No significant degradation of any safety ftiction or mi aading (5) of the operator as a result of failure of eouioment under the accident
(
1<
1 environment.
4 -
e 22
[7590-01]
4
/
.. s
[(H] fil A record of the qualification including documentation t
M regraoh (d) of this section must be maintained in [a-centrai-file]
an auditable form fcF the'atire ceriod during which the covered item is
() jnstalledin'thenulearocverplantorisstoredforfutureusetopermit
~
trification that(aach item of safety-related electric equipment covered
\\
by this section (1) is qualified for its application and f\\
l * (2) meets its specified performance requirements when it is subjected
^
M the conditiccs predicted to be present when it must perform its safety si fu'nction. up to the end of its qualified life.
fkhLicenseesarenetreouiredtoqualifyelectriceouiomentin accordance with the requirements of this rule provided the following conditions are met:
(1) Qualification of safety-related electric equipment c,menced prior to [ insert date 90 days after effective date'of this rul d, and l
(2) Qualifichtice!ofelectricequipmentwasdoneinacetrdancewith l
i' l
the existing license consitiens or technical soecifications requiring l
such equipm\\ent to be qualified according to " Guidelines for Evaluating ir 3
4 Environmental Qualification of Class 1E Electrical Equioment in Operat-ing Reactors," November.1979. or NUREG-0588 (For Comment version),
" Interim Staff Position o'n Environmental Qualification cf Safety-Related 4
~
Electrical Equipment."
4 -,
t p
Dated at this day of
, 1982.
i 1;
for the Nuclear Regulatory Commission.
i'
t+
t I
i I~
1<
Samuel J. Chilk Secretary of the Commissica
/
4 l
23 4
w a
na a
e 8
'e es g
4 et 4
i 4
9 b
i 9
4 e
t i
a 4
t l
e ENCLOSURE 2 1
__-4
--e..
ANALYSIS OF PUBLIC CONNENTS ON 10 CFR 550.49 (47 FR 2876, Jan. 20, 1982) 1.
650.49(a) - Seismic Requirements:
A.
Comment:
Seismic and dynamic qualification is an integral part of environmental qualification.
It is therefore inappropriate to codify environmental qualification first and then to codify seismic qualifi-cation s'eparately at a later date.
Response
Electric equipment at operating nuclear power plants was generally qualified for environmental and seismic stresses separately; i.e., by using separate prototypes for environmental anc seismic qualification tests.
\\
The proposed revision to Regulatory Guide 1.89 (Feb. 1982) specifies
" single prototype" testing (sequence testing) as an acceptable method for qualifying safety-related electric equipment.
The implementation section of this guide will include NTOL's and future plants and not l
operating plants. Thus, any seismic qualification testing of equip-ment in operating plants that may be required by future rulemaking I
l will not require retesting.for environmental stresses.
Also refer to response to of comment 1.C.
i 05/22/82 1
'PUBLIC COMMENTS EQ RULE-
B.
Comment:
The proposed rule has introduced a new term, " dynamic qualification" without definition.
Response
" Dynamic Qualification" is outside the scope of this rul'emaking.
Therefore, no specific definition is required at this time.
The term will be specifically defined as part of the future rulemaking.
C.
Comment:
In the absence of seismic requirements in 550.49, equipment 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
For plants operating prior to the effective date of the final rule, replacement parts that were 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.
l l
D.
Comment:
It is appropriate that seismic and dynamic qualification requirements should not be included in 550.49.
It must, however, be stated that qualification to IEEE 344-1975 is one acceptable method for seismic qualification.
Response
Regulatory Guide 1.100 already endorses IEEE 344-1975 in this area.
05/22/82 2
PUBLIC COMMENTS EQ RULE
2.
650.49(b) - Establishment of a Oualification Program Comment:
The rule should recognize previous submittals pursuant to the 00R Guidelines and NUREG-0588.
Response
The final rule has been expanded to recognize this concern.. Requalification of electric equipment in accordance with this rule will not be required for equipment qualified in accordance with DOR Guidelines or NUREG-0588, provided the qualification of electric equipment has commenced prior to 90 days after the effective date of the rule.
See 550.49(k), which has been saded in the final rule.
3.
650.49(c) - Scope of the Rule A.
Comment:
This section seems to be much greater in scope as compared l
to NRC interim requirements.
Response
For clarity 550.49(k) has been added.
B.
Comment:
The scope of the proposed rule should be limited to Class IE or safety related equipment.
l l
Resoonse:
The scope of $50.49 is limited to " safety-related electric equipment," which is essentially Class 1E.
A typical list of equipment and systems covered by this rule has been included in a l
l revision to Regulatory Guide 1.89.
05/22/82 3
PUBLIC COMMENTS EQ RULE
it
'e 2
C.
Comment:
The scope should be reworded (47 FR 2878, Col. 2, Line 3) t as:
"... shutdown, maintain the integrity of the reactor coolant i
pressure boundary,' containment isolation..."
Response
The language for the scope of the rule has been redrafted in terms of safety-related electric equipment.
Safety-r31ated electric equipment is essentially " Class 1E" equipment as defined in national standards.
D.
Comment:
The proposed rule introduces a new requirement to qualify
" equipment needed to complete one pat 5 of achieving and maintaining a cold shutdow'n condition" and this modifits the licen\\ sing basis for the majority of operating nuclaar power plants.
A change of this magnitude, at this advanced stage of industry's qualification effort, a
most certainly introduces significant new costs and obligations with l
no demonstrated improvement in safety.
Response
The staff agrees that this is a new requirement that may introduce significant costs.
The licensing basis of the majority of operating reactors does not require that all electric equipment and
- 1 systems necessary to bring the reactor from normal operating conditions to cold shutdown be designed to Class lE standards.
1 Therefore, to require that all plants environmentally qualify the electric equipment and systems needed to complete one path of achieving and maintaining a cold shutdown condition may require the upgrading of a significant amount of equipment and systems that do I
not currently meet Class 1E standards for operating reactors.
05/22/82 4
PUBLIC COMMENTS EQ RULE
However, electric equipment and s'ystems necessary to mitigate the consequences of design basis accidents should be required to meet Class 1E standaras*for all reactors and therefore, would be covered by the rule.
The staff is currently studying the requirements for shutdown decay heat removal under Unresolved Safety Issue (USI) A-45.
The overall purpose of A-45 is to evaluate the adequacy of current licensing requirements to ensure that failure to remove shutdown decay heat does not pose an unacceptable risk.
Under A-45 a comprehensive and consistent set of shutdown cooling requirements for existing and future plants are being developed.
The final resolution of A-45 is presently scheduled for October 1984.
The staff believes it would be premature at this time to impose the requirement to environmentally qualify electric equipment and systems necessary to achieve and maintain' cold shutdown prior to the final resolution of A-45.
Therefore, this requirement is not includea in the final rule.
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 wculd net be accomplished.
Qualification of non-safety instrumentation should not 05/22/82 5
'PUBLIC COMMENTS EQ RULE-i
/
be required where such instrumentation is not the primary source of data used by the operator in controlling events.
Response
The scope has been redrafted in terms of safety-related electric e,quipment.
The interpretation that the, qualification of non-safety instrumentation is not required if such instrumentation is not the primary source of data used by the operator in controlling events, is correct.
4.
650.49(d) - List of Eouipment A.
Comment:
Th'ere is no distinction made '? tween equipment located in a harsh or mild environment.
Resoonse:
The final rule does not cover equipment located in a mild environment.
B.
Comment:
Lists of equipment which have been compiled in response to NRC bulletins and letters should be used instead of requiring genera-l tion of a new list in another data format.
An alternative could be to identify on existing lists the equipment covered by this rule, and to reference other licensing documents, such as FSARs, design calculations, and equipment specifications, where additional information is available.
Resoonse:
It has been the experience of the staff that simply referencing other licensing documents as suggested in this comment 05/22/82 6
PUBLIC COMMENTS EQ RULE
can result in uncoordinated and incomplete reviews of the qualifica-tion status of equipment.
For this reason, a separate list of equipment covered by this rule is required.
See also response to comment 2.
C.
Comment:
Equipment located in a mild environment should be excluded from the proposed rule since the NRC has indicated that the stresses for this equipment would be less severe than for those in harsh environments.
Response:.See response to comment 4.A.
5.
650.49(d)(1) - Performance Characteristics A.
Comment:
Environmental qualification should not be limited to design basis events, but should consider' Class IX accidents.
Also, the rule omits the serious risk to electric equipment caused by internal missiles from pumps, valves, and. burst pipes.
Resoonse:
Severe accidents (Class IX accidents) are being considered in other rulemakings.
Environmental qualification does not include consideration 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.
05/22/82 7
PUBLIC COMMENTS EQ RULE
l
~
Response
Staff agrees.
Paragraph 50.49(d)(1) has been accordingly r
modified.
The terms " performance characteristics" and " structural C.
Comment:
integrity" are open to diverse interpretations.
Suggestions have i
been made to use the terms " safety functional requirement," per-formance " specifications" or "the safety-related functions" in place of " performance characteristics."
With regard to structural integrity, see response to
Response
comment 5.B.
The term "perf,ormance characteristic" has been changed
\\
to "performa~nce specifications".
The proposed requirement of paragraph (d)(1) is redundant, D.
Comment:
unnecessary, and arbitary since equipment technical specifications contain design criteria and requirements for safety equipment which
~
is sufficient.
Resconse:
See response to comment 4.B.
I The required list of equipment should not include perform-E.
Comment:
ance characteristics.
This will lead to recording of extraneous information, diluting the importance of safety related parameters l
l I
information.
See response to comment 5.f Performance characteristics Resoonse:
f l
are not extraneous information.
PUBLIC COMMENTS EQ RULE 8
05/22/82
6.
650.49(d)(2) - Electrical Characterist'ics A.
Comment:
Change 4'can" to "must" on last line of paragraph (d)(2).
Response
The use of word "can" is appropriate since the requirement in paragraph (d)(1) pertains only to the listing of performance specification of the equipment.
B.
Comment:
Requiring the " range" to be qualified is overly restrictive, unnecessary, and will have a large cost impact on testing.
Resoonse:
Staff agrees.
The words "The range of" have been deleted from paragraph 50.49(d)(2).
C.
Comment:
Delete paragraph (d)(2).
\\
Resoonse:
See response to comment 6.B.
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 00R Guidelines or l,
NUREG-0588, Category II.
U Resoonse:
See response to comment 2.
d 05/22/82 9
'PUBLIC COMMENTS EQ RULE' l
t
7.
650.49(d)(3) - Environmental Conditions A.
Comment:
The term "where applicable" needs to be added after the list of environmental parameters in paragraph (d)(3).
Resoonse:
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.
Response
Clarification regarding qualification for chemical spray environments is given in paragraph 50.49(e)(3).
Additional guidance is provided by Regulatory Guide 1.89.
C.
Comment:
Predicted variations in environmental conditions are not necessary if extreme conditions are identified and used in the qualification program.
Response
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 margins, is unacceptable.
05/22/82 10 PUBLIC COMMENTS EQ RULE
,o See also 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 determinating environmental conditions must be justifiable.
Guidance in this area 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..."
Resoonse:
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 environ' mental parameters elsewhere in this section.
8.
650.49(e)(1) - Temperature and Pressure A.
Comment:
The phrase "most limiting" needs clarification.
l Resoonse:
For clarity, the phrase "most limiting" is changed to l
"most severe."
h B.
Comment:
For consistency, " design basis events" should be used in paragraph (e)(1) rather than " postulated accidents."
05/22/82 11 PUBLIC COMMENTS EQ RULE
--r,w y-
.-,,ur
- - = -
e r
w-m vr ww w--ww n
tww--
Respense:
Staff agrees.
The rule has been modified accordingly.
9.
650.49(e)(2) - Humidity' Cc= ment:
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.
Response
Staff agrees.
The rule has been modified accordingly.
10.
650.49(e)(3) - Chemical Effects I
A.
Comment:
Since corrosion effects of various chemical components are generally well known, this paragraph should provide latitude to allow analysis that justifies using different chemical spray constituents or less severe concentrations than specified by plant environmental I
requirements.
Resoonse:
Analysis is acceptable if adequately justified.
l l
11.
650.49(e)(4) - Radiation 1
i A.
Comment:
In general, the aging and accident radiation cannot be combined, i.e., the werd "plus" is misleading or incorrect since it implies integrated effects.
l 05/22/82 12 PUBLIC COMMENTS EQ RULE
I a
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 reference to dose rate has been deleted with regard to normal operation.
12.
650.49(e)(5) - Aging A.
Comment:
The requirement that on going qualification 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 cualified life and it is not appropriate to single out just one ofthem.
Resconse:
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.
4 I
Resoonse:
Staff agrees. Reference to "electromechanical equipment" I
has been deleted from the rule.
05/22/82 13 PUBLIC COMMENTS EQ RULE-
C.
Comment:
Use of accelerated aging to define a qualified life is not technically feasible.
Response
The staff believes that preconditioning by accelerated aging is technically feasible for both simple and complex electric equipment for shorter. designated life.
Staff recognizes that state-of-the-art technology will be utilized in any aging program.
Reference to " qualified life" has been deleted from the final rule.
13.
650.49(e)(7) - Synergistic Effects "known synergistic effects...." mus.t be co\\nsidered.
NRC Comment:
should be more specific.
Resoonse: The word "known" has been deleted from the rule.
14.
650.49(e)(8) - Margins The proposed rule states that margins are used to account i
A.
Comment:
i j
for inaccuracies in test instruments.
Test instrument inaccuracies are a QA problem associated with required calibration programs and should not be encompassed under margins.
Resoonse:
Staff disagrees.
The test instrument errors must be accounted for.
05/22/82 14 PUBLIC COMMENTS EQ RULE
,--.4--
8.
Comment:
The margins applied in~ addition to known conservatisms lead to excessive stress which could lead to failures of equipment in unrealistic qualification tests.
Response
Staff agrees.
The paragraph on margin has been accordingly modified.
15.
650.49(f) - Methods of Oualification Comment:
Qualification by analysis should not be allowed.
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 be 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.
650.49(f)(2) - Testino of Similar Items and Analysis 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.
05/22/82 15 PUBLIC COMMENTS EQ RULE
Resoonse:
The staff disagrees.
The intent of paragraph (f)(2) is to cover both "similar" and " identical" environments.
17.
950.49(f)(3) - Experience and Analysis Comment:
Experience has proven to be of very limited use in qualification because of the lack of sLpporting documentation.
It is suggested, therefore, that the words " Adequately documented" be inserted at the beginning of paragraph (f)(3).
Response
All information used to demonstrate the qualification of
~
equipment, including test results, analytical assumptions, and experience with identical or similar equipment, must be adequately documented.
18.
650.49(f)(4) - Analysis 50.49(f)(4)-Comment:
Are subparagraphs (f)(4)(i) and (f)(4)(ii)'
l l
independent?
Response
No.
Paragraph (f)(4)(i) has been deleted.
19.
650.49(f)(4)(ii) - Analysis and Partial Test Data i
Comment:
If partial type test data are available which adequately l
supports the analytical assumptions and conclusions, then analysis l
05/22/82 16 PUBLIC COMMENTS EQ RULE
should be allowed to extrapolate *or interpolate these results for equipment, regardless of purchase date.
Response
Staff agrees.
The rule has been modified (see paragraph (f)(4) of the final rule).
20.
650.49(g) - 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.
Paragraph (g) of the proposed rule has been deleted since it is too prescriptive.
It will be included in Regulatory Guide 1.89.
See response to comment 4.A.
\\
B.
Comment:
Strict application of these requirements will negate testing already conipleted for earlitr plants.
The relief must be i
included in the Reg. Guide 1.89.
Response
See response to comment 2.
C.
Comment:
Paragraph 50.49g should be deleted as it limits the options available for qualification testing.
Response
Staff agrees.
See response to comment 20.A.
05/22/82 17 PUBLIC COMMENTS EQ RULE.
1.
D.
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 commerit 2.
E.
Comment:
This paragraph should also make provisions for acceptance t
of testing that does not totally envelop all plant environmental conditions by supporting analysis.
\\
Response
Paragraph (f)(2) covers "similar" conditions.
F.
Comment:
The detailed requirements for qualification by testing should not be contained in a rule, but should instead be discussed in 1
i
Response
See response to comment 20.A.
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 See also appropriate for analysis as a qualification method.
response to comment 20.A.
05/22/82 18 PUBLIC COMMENTS EQ RULE
21.
650.49(o)(1) - Acceptance Criteria A.
Comment:
The requirement for acceptance criteria does not clearly say that they must be relevant.
Acceptance criteria are application dependent.
Response: The staff disagrees that acc'eptance criteria are necessarily plant-dependent.
See also response to comment 20.A.
B.
Comment:
The establishment of acceptance criteria before testing should be deleted.
" Failure" is often a plant-specific consideration.
Response
The staff disagrees.
Acceptance criteria, whether generic or specific, should be established prior to testing.
See also response to comment 20.A.
\\
C.
Comment:
If the documentation in paragraphs d(1), (2), and (3) is f
established, a clear record that-the equipment provides the perform-f ance required will have been established.
Therefore, this require-ment for acceptance criteria should be eliminated.
Response
Staff disagrees.
Paragraphs (d)(1), (d)(2), and (d)(3) refer to performance.
Performance and acceptance criteria are not i
necessarily identical.
See also response to comment 20.A.
l 05/22/82 19 PUBLIC COMMENTS EQ RULE
This paragraph precludes reevaluating test criteria D.
Comment:
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.
The rule specifies the methods for demonstrating
Response
successful qualification.
Failures during testing due to faulty test equipment or invalid acceptance criteria are outside the scope of the rule.
See also response to comment 20.A.
22.
950.49(g)(2) - Demonstration by Test Delete reference to paragraphs (d)(1), (d)(2), and (d)(3)
A.
Comment:
concerning characteristics, electrical characteristics and environ-mental conditions, respectively.
See response to of comment 21.C.
Response
Paragraph g(2) requires that a radiation dese rate exposure B.
Comment:
profile vs. time be established and enveloped by the qualification Testing at qualification dose rates exceeding accident dose t
testing.
rates, and total exposures exceeding the accident and normal exposure, is an overly conservative approach.
See response to comment 20.A.
Response
PUBLIC COMMENTS EQ RULE 20 05/22/82
~
C.
Comment:
The radiation vs. time simulation requirement should be deleted from paragraph g(2).
Response
See response to comment 20.A.
D.
Comment:
The radiation dose rate should be simulated to the best extent possible within the limitations of the test facility and measuring instruments.
Resoonse:
See response to comment 20.A.
E.
Comment:
The rule should state that the accident radiation dose exposure with appropriate margin may be performed 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.
Responde:
See response to comments 2 and 20.A.
F.
Comment:
Many utilities have carried out expensive qualification testing to service conditions unique to their plants in accordance with IEEE 323-1971 and demonstrated compliance with previous NRC regulations.
New increased margins should not be applied to these existing tests.
Resoonse:
See response to comment 2.
05/22/82 21 PUBLIC COMMENTS EQ RULE.
23.
650.49(g)(3) - Test Profile 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
See re.coonse to. comment 20.A.
24.
650.49(g)(4) - Single Prototype
)
A.
Comment:
Does this section apply to aging also? For example, could parts of a component be aged separately, then assembled, then tested as per g(3)?
Response
This is acceptable.
However, the intent of paragraph (g)(4) is that the test stresses, e.g., aging and radiation, are not shared among two or more pieces of equipment.
See response to comment 20.A.
B.
Comment:
Paragraph 50.49g(4) requires qualification by sequential test. Without direction on seismic and dynamic requirements, sequential tests cannot be done.
Response
See resolution of comments 1.A, 1.C, and 20.A.
05/24/82 22 PUBLIC COMMENTS EQ RULE
C.
Comment:
This section may be interpreted as requiring MSLB and LOCA qualification tests of the same device.
Testing to either is sufficient, provided the limiting accident is identified.
Resoonse: Testing to the m'ost limiting condition is acceptable.
See response to comment 20.A.
D.
Comment:
Allowance for justifications for deviations from using the same piece of equipment throughout a test sequence should be allowed.
The present 50.49g(4) conflicts with the proposed Revision 1 of Regulatory Guide 1.89.
Response
See resconse to comments 2.A and 20.A.
I 25.
650.49(h) - Extension Date and Schedule Submissicn l
l
\\
A.
Comment:
The proposed rule's ext' ended deadline for compliance with anvironmental 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 considered 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 I
impact on overall plant safety were factored into the Commission's l
05/24/82 23 PUBLIC COMMENTS EQ RULE
. Enclosure 2
l decision to extend the deadline.
Licensees have submitted informaticn to the NRC showing that plants can be safely operated pending comple-tion of the required environmental qualification.
B.
Commint:
Mild environment 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 response to ccmment 4.A.
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".
I Resoonse:
Staff agrees.
The word " testing" has been replaced by
" qualification".
D.
Comment: We assume the goal of final environmental qualification is for the second refueling outage starting after March 31, 1982.
l
Response
Staff agrees.
The requirement for " testing" of equipment identified in E.
Comment:
l the submittal due 90 days after the publication of the final rule is l
inconsistent with 50.49(f) concerning qualification methods and with l
l 05/24/82 24 PUBLIC COMMENTS EQ RULE Fnclncure 2
1 the proposed revision to Regulatory Guide 1.89 (Section C.5.9) eegarding qualification in mild environments.
Response
Staff agrees.
See resolution of comment 4.A and 20.A.
i F.
Comment:
Tne rule should recognize that previous submittals to the NRC containing equipment identification and schedules for qualifica-tion are adequate for fulfilling the requirements in 50.49(h).
Response
Prior submittals have not satisfied the requirements of paragrcph 50.49(h).
For example, the schedule for qualification had never before been required.
l I
G.
Comment:
The words "but prior to November 30, 1985" in 50.49(h) and 50.49(k) should be deleted.
As currently written, no recourse is provided for plants receiving operating licenses after November 30,
~
1985.
Response
Plants licensed after. November 30, 1985, will be required I
l to be in compliance with this rule.
i r
H.
Comment:
The requirement to submit a schedule for the testing or i
replacement of equipment is not warranted.
The date for submitting a schedule for testing and replacement has no safety significance l
whatsoever.
l 05/24/82 25
?UBLIC COMMENTS EQ RULE-
1
Response
The achievement of full qualification by the November 30, 1985, deadline depends on the early identification of deficiencies 3
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.
Response
See resolution of comment 4.A.
J.
Comment:
The proposed rule appears to require a new round of sub-mittals(90'dayletters)c'overinginformationthathhsalreadybeen submitted to the NRC.
A statement should be included to indicate that this requirement applies only to plants that did not submit a T----
90-day response.
Response
Although the date for completion of environmental quali-fication would be extended by 650.49, new sched'les for completion of u
qualification must be submitted.
Duplicate submittals are not required.
26.
650.49(i) - Significant Problem Notification the Commission of any A.
Comment:
The schedule for notift+r.ust significant qualification problem within 30 days of its discovery should be separated from the technical requirements of the rule.
05/24/82 26 PUBLIC COMMENTS EQ RULE.
t 4
Response
Staff disagrees.
The purpose of this requirement is to provide advance notice and basis for possible extensions.
B.
Comment:
We believe the requirements to notify the Commission of potential problems within 30 days of discovery may be too stringent, particularly if a scheduled completion date is six months or longer from the.date of discovery of a potential problem that may require extension.
Responsa:
The staff agrees.
See response to comment 26.C.
C.
Comment:
The notification period of 30 days to allow industry to evaluate mine rualification problems should be extended to 90 days.
i This would 9'.nimize the number of insignificant problems to be addressed ay the Commission and industry.
Response
The staff agrees with the general point.
The notification period has been extended to 60 days.
l 27.
650.49(j) - Justification for Continued Ooeration I
i 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 l
unsafe equipment based on its behavior during normal operating conditions.
l 05/24/82 27 PUBLIC COMMENTS EQ RULE l
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 stated in paragraph (j) of the proposed rule.
B.
Comment: The submittal of justification for continued operation should be required 90 or 180 days after the effective date of this rule, not on the effective date, to be consistent with the Supplementary Information section.
Response
See response to comment 27.A.
C.
Comment:
The provisions of the rule concerning justification for continued operation should be deleted as this information has been previously submitted in response to IE Bulletin 79-018.
Response
Staff agrees.
See resolution of comment 27A.
28.
650.49(j)(1) - Designated Alternative Single Failure Criterion / Partial Test Date 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 requirement should be deleted.
l 05/24/82 28 PUBLIC COMMENTS EQ RULE
Response
Staff disagrees.
The~ terms alternative" (or alternate) and " principal equipment" are used in the context of section 4.7.4.1 of IEEE 279-1971.' Specifically, the alternative and principal equip-ment are mutually diverse (to protect against common-mode failures.)
Ho' wever, 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 operation is overly restrictive.
If this requirement were met, no justification for i
interim op'eration would be needed.
4 Resoonse:
Staff agrees.
The final rule has been modified.
See e
paragraph 50.49(i)(1) of the final rule.
C.
Comment:
The phrase "and satisfies the single failure criterion" is unclear as used in this section.
Alsu define the term " adequately quali fied."
Response
The word " adequately" has been deleted.
See response to comments 28.A and 28.B.
D.
Comment:
If there is designated alternative equipment which is qualified and satisfies the single failure criterion, the principal 1
equipment need not be classified as safety related and hence need not U
be qualified.
05/24/82 29 TUBLIC COMMENTS EQ RULE-
Response
See response to comment 28.A.
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 qualification.
If the test data are insufficient to demonstrate full qualification, partial test data may be utilized to justify continued operation.
29.
650.49(j)(4) - Completion 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-ment failures do not degrade the safety functions or mislead the operator.
This should be sufficient for full qualification.
A demonstration with appropriate margins that equipment
Response
fulfills the above requirements can constitute full qualification.
The evaluation of whether the failure of a single piece of B.
Comment:
equipment will, of itself, mislead the operator is subject to inter-
~
Because redundart equipment pretation and engineering jut'cament.
30 PUBLIC COMMENTS EQ RULE 05/24/82
would be available, the justification for interim operation should not consider the aspect of unqualified instrumentation n.isleading the operator.
Response
Licensees should examine en a case-by-case basis the impact of equipment failures on operator actions.
The licensees shoulc decide whether the erroneous information subsequent to accom-plishment of protection function can mislead the operator.
30.
650.49(j)(5) - Significant Degradation 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.
t Response: This section applies to relatively new power plants and assumes that the majority of the. equipment is already fully qualified F
prior to the issuance of an operating license.
This provision is intended to justify operation if alternative qualified equipment can compensate for the potential malfunction of relatively few items that may not be " fully" qualified.
05/24/82 31 PUBLIC COMMENTS EQ RULE l
~
31.
650.49(k) - Justification for Continued Operation for Near-Term Operatina Licensees 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) t 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 response to comment 30.
\\
B.
Comment:
Previous submittals by NTOLs pursuant to NUREG-0588 which contain justification for operation should be acknowledged.
Response
This rule does not require duplicate submittals.
32.
650.49(1) - Reouirement of a Central File A.
Comment:
The requirement to maintain a record identifying that the equipment meets its specific performance requirement exceeds the verification necessary to establish the performance of safety function.
Response
The qualification test by nature is limited to verifying the performance characteristics and not the actual safety function performed by the equipment, e.g., cooldown of a co v.
05/24/82 32 PUBLIC COMMENTS EQ RULE Fnt1nture 2.
B.
Comment:
The requirement for a central file should be for equipment located and poten,tially subject to a harsh environment only.
Response
See response to comment 4.A.
C.
Comment:
The requirement for a central file should be deleted because some records may be kept in the utility general file.
Resoonse:
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 predicted.
Resoonse:
See resolution of comment 32.A.
s E.
Comment: We suggest that it may be difficult, if not impossible, to obtain the record of qualification required, particularly for equip-ment in older plants, and we suggest that for equipment that has significant successful operating experience this record should not be necessary.
Resoonse:
The requirements of paragraph (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 t'..the 05/24/82 33 PUBLIC COMMENTS EQ RULE'
harsh or mild environment.
Recngnition of content requirements by reference to any proposed regulatory guide would be appropriate.
Response
See response to comment 32.B.
i G.
Comment:
Central file qualification information should include equipment in a harsh environment only and should only support the i
equipment's ability to perform its rafety function.
Response
See response to comments 4.A, 32.A, and 32.B.
i H.
Comment:
Please clarify as to exactly where the licensee shall maintain qualification records, particularly with respect to files i
which are proprietary to the NSSS vendor.
Response
Qualification files must be maintained in an auditable form.
l 33.
Supolementary Information A.
Comment: The term "important to safety" should be replaced by
" Class IE" throughout this rule.
Response
See response to comment 3.B.
l B.
Comment:
The term " safety-related" should be used in place of "important to safety."
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05/24/82 34 PUBLIC COMMENTS EQ RULE Fnclnsure 2
Response
" Safe-related" equipment is a subset of equipment "important to safety." The scope of the final rule is limited to safety-related electric equipment.
Expansion of the scope of this rule to include additional equipment important to safety will be subject of a future rulemaking.
C.
Comment:
The scope of the proposed rute should include all electric equipment "important to safety" since that is the same as " safety-related" or " safety grade" equipment.
Response
See response to comments 3.C and 33.B.
34.
Qualification History A.
Comment:
It should be noted in the rule that prior to 1971 qualifi-cation of electric and electronic equipment was based on [the] use of t
good engineering practices which' included conservative application l
l and design, high quality equipment, and some environmental testing.
1
Response
Staff agrees with the comment.
However, the additional details are inappropriate in the final rule.
35.
Basis of Rule 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 evaluated in accordance in 05/24/82 35 PUBLIC COMMENTS EQ RULE e
t accordance with [the] DOE guidelines and NUREG-0588 Category II are considered to satisfy the requirements of this rule.
i
Response
See response to comment 2.
B.
Comment:
The Federal Register notice states that this rule codifies existing requirements and imposes no new costs or obligations on
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utilities. We take strong exception to this statement.
Response
The new rule will codify the current requirements in the 00R Guidelines and NUREG-0588.
C.
Comment:
The rule does not recognize that operating plants have just completed qualification of equipment to the 00R Guidelines or NUREG-0588 Category II.
Response
See response to comment 2.
D.
Comment:
The Supplementary Information section should also state that the requirements of IE Bulletin 79-01B are being codified.
Response
Reference to DOR Guidelines includes IE Bulletin 79-01B.
05/24/82 36 PUBLIC COMMENTS EQ RULE
o 36.
Replacement Parts A.
Cominent: The rule does not address replacement parts.
Response
Specific guidance on replacement parts will be included in Regulatory Guide 1.89.
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ENCLOSURE 3
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'VALUE/ IMPACT STATEMENT
'1.
PROPOSED ACTION 1.1 Description The applicant (licensee) of a nuclear power plant is required by the
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Commission's regulations to verify that structures, systems, and components important to safety will perform their intended functions in spite of the environments that may result from anticipated operational occurrences or postulated accidents. This verification includes environmental qualification by test, operating experience, and analysis, or a combination of these. The proposed rule sets forth the Commissioii's requirements for the\\ environmental qualification of safety-related electric equipment by test and analysis.
- 1. 2 Heed for Proposed Action The current general requirements for qualification of electric equipment important to safety are found in General Design Criteria 1, 2, 4, and 23 of Appendix A to Part 50; Sections III and XI of Appendix B to Part 50; and Paragraph 50.55a(h) of Part 50, which incorporates by reference IEEE 279-1971,*
" Criteria for Protection Systems for Nuclear Power Generating Stations." The NRC has used several methods to ensure that these general requirements are met for safety related electric equipment.
Prior to 1971, qualification was based f
on the fact that the electric components were of high industrial quality.
For l
nuclear plants licensed to operate after 1971, qualification.was judged on the basis of IEEE 323-1971.
However, no regulatory guide was ever issued endorsing l
IEEE 323-1971, although some of the plants referenced the standard in their I
licensing submissions to the Commission.
For the plants whose safety evaluation reports were issued after July 1, 1974, the Commission has issued Regulatory l
Guide 1.89, which enderses IEEE 323-1974* subject to supplementary provisions.
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- Copies ma'J *.a obtained from the Iistitute of Electrical and Electronics Engineers, Inc., 345 East (/tn street, New York, N.Y. 10017.
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Currently, the Commission has under way a program to reevaluate the quali-
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fication of safety-related electric equipment in all operating reactors. As part of this program, the staff has developed more definitive criteria for the environmental qualification.
The Division of Operating Reactors (00R) issued
" Guidelines for Evaluating Environmental Qualification of Class IE Electrical Equipment in' Operating Reactors" in November 1979.
In addition, for reactors under licensing review, the staff has issued NUREG-0588, " Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment."
In its Memorandum and Order CLI-80-21 issued on May 23, 1980, the Commis-
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sion endorsed the staff's actions to use the DOR Guidelines to review operating plants and NUREG-0588 to review plants under licensing review.
Further, the Commission ordered that these two documents form the basis for requirements that licensees and applicants must meet in order to satisfy those aspects of Appendix A to 10 CFR Part 50 that relate to the environmental qualification of electric equipmert.
The Commission also ordered that licensees of operating reactors must conply with these requirements so that the applicable equipment in all operating plants will meet the 00R Guidelines or NUREG-0588.
l 1.3 Value/ Impact of Proposed Action 1.3.1 NRC Operations Since regulations specifically setting forth requirements for the qualifi-cation of safety-related electric equipment in new and operating plants have never been issued, the proposed action should result in more effective effort by the staff in reviewing applications for construction permits and operating licenses and in the backfitting of these requirements to operating plants.
The proposed action will codify an NRC position by taking advantage of previous staff effort (1) in completion of a generic activity (A-24), " Qualification of Class 1E Safety-Related Equipment," (2) in the preparation of the DOR Guidelines and NUREG-0588, (3) in IEEE standards committee work, and (4) in the development, l
funding, and monitoring of related research programs.
There should be little impact on the staff at the time the rule is approved.
l Approximately two man years of effort have been spent in preparation of the rule.
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1.3.2 Other Government Agencies Not applicable, enless a government agency is the applicant.
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._ t 1.3.3 Industry The licensees and applicants currently must meet the requirements for qualification of safety-relited electric equipment in accordance with the Commission's Memorandum and Order CLI-80-21.
If the final rule is published as now presented, the rule will not have s'ignificant impact on industry because of backfit. '
The value of this rule is that the industry will have clearly specified requirements to follow with respect to the qualification of safety-related electric equipment for new and existing plants.
This, in turn, should ease the licensing process for industry by eliminating delays resulting from
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misinterpretation of NRC's requirements.
1.3.4 Public The proposed action will improve public safety by further ensuring that electric equipment will perform its safety functions in spite of environments that may result from design basis events. These is no perceived impact on the public.
1.4 Decision on Proposed Action The proposed action has been mandated by the Commission in its Memorandum and Order CLI-80-21 dated May 23, 1980, 2.
TECHNICAL APPROACH The technical approach will be to codify the programs of the DOR Guidelines and NUREG-0588.
3.
PROCEDURAL APPROACH Rulemaking has been mandated by the Commission in its Memorandum and Order cited above.
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4.
STATUTORY CONSIDERATIONS 4.1 NRC Authority Authority for this rulemaking is derived from the Atomic Energy Act of 1954, as amerIded, and the Energy Reorganization Act of 1974, as amended.
4.2 Need for NEPA Assessment The proposed action dots not require an environmental impact statement in accordance with 51.5(d)(3) of 10 CFR Part 51.
5.
RELATIONSHIP TO OTHER EXISTING OR PROPOSED REGULATIONS OR POLICIES No conflicts or overlaps with requirements promulgated byiother agencies are foreseen.
6.
SUMMARY
/.4D CONCLUSIONS This rule.nandated by the Commission will be effective upon publication, which is expected prior to June 30, 1982.
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