ML20054K086
| ML20054K086 | |
| Person / Time | |
|---|---|
| Issue date: | 06/01/1982 |
| From: | Norry P, Scott R NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | |
| Shared Package | |
| ML20054K085 | List: |
| References | |
| OMB-3150-0011, OMB-3150-11, NUDOCS 8207010045 | |
| Download: ML20054K086 (32) | |
Text
.
REQUEST FOR OMB REVIEW (Undar the Paperwork R: duction Act and Executive Order 12291)
Importcnt - Read instructions (SF-83A) before comptsting this Of tice of Intormation and Regulatory Affairs form Submit the requirednumber of copoes of SF 83.together offsce of hynagement and Budget with the material for A nsch review is requested to.
Washing'on. D C. 20503
- 1. Department / Agency and Bureau / Office originating request
- 3. Name(s) ano telephone number (s) of person (s) who can best answer questions regarding request U.S. Nuclear Regulatory Commission
' S. Aggarwal (301) 443-5946 2.6-digit Agency / Bureau number (fasstpart of 11-dtgit Treasury
- 4. 3-digit f unctional code (last part of 11-digit Treasury Account Account No.)
No.)
3 1
0 2
_Q. _0_
.?._ _L _f_
5 Tille of informatson Collection or Rufemaking C. Is this a rulemaking submsssoon under Section 3504 th) of P.L.96-511 ? (Check one)
Environmental Qualification of Electrical ijo No <section 35o7 submission)
Equipment, 10 CFR 50.49 amendment 2 0 ves.NPRM. Expected date of publication:
'6. A Is anyInformation collection (reporting or recordkeeping) 3 0 Yes.fsnat rute. Expected date of pubincatnon:
involved ? (Cneck one)
Etfective date.
I R Yes and proposal is attached for review D. At what phase of rulemaking is this submission made?
(Check one) 2 O Yes but proposat is not attached - skip to question D 3 O No - skip to cuestion D.
1 O Not apphcable B Are the respondents pnmanly educatiorsalagencies or 20 Maior rule.at NPRM stage institutions or is the purpose related to Federaleducation 3 D Major Final rule for which no NPRM was pubhshed programs 7 4XX Major Final rule. after pubhcation of NPRM O yes la No 5 O Nonmajor rule, at NPRM stage 6 O Nonmajor rule at Final stage COMPLETE SH ADED PORTION IF INFORM ATION COLLECTION PROPOS AL IS ATTACHED
- 7. Current (or former) OMB Number
- 8. Requested
- 12. Agency report form number (s) 3150-0011 N/A Expiration Date
- 13. Are respondents only Federal agencies?
4/30/85 4/30/85 O Yes R No 9 Is proposed information collection listed in
- 14. Type of request (Check one) the information cot;ection budget?
OtYes O No 10 D'el'minary plan
- 10. Will this proposed inf ormation collection 2 O new (notprmousy aproved ompM mom man 6 monm cause the agency to exceed its information ago) collection budget allowance? (if yes, attach O Yes E No 3 % revision amendment request from agency head.)
4 D extension ladiustmens to burden only)
- 11. Number of repor1 forms submitted for approval 5 C extension (no changel 6 0 resnstatement (emored within 6 months) 15.
16 Classifscation ot Change in Burden (explainin supporting statement)
. 4cn.n...ee w. o<
un. e se 'd $ * * * '
N/A No.cf Responses No.of Reporting Hours Cost to the Pubhc b sa* o's=~p*
5,777:500 S
tUA
- a. in inventory 8,103 e Estimetso number et
- b. As proposed 8,443 5,805,420 lS
,esocoo>nis e,
,eco,o uecerococa' 34
- c. Difference (b-a) 340 27220 lS a Recons annua!', ev cacn Explanation of dif ference (indicate as many as apply) respondent (<re, 25' 10 Adjustments
"[c",[5," '"
d Correction-error i,
i l1 S 340
- e. Correction-reestimate i i
iS f E stimated eve' age i
- f. Change in use i
i iS n umt+ o"*
- pere,wonse
- - - ~ ~ 'gp Program Changes O E slimsted tota! hours bS
{*,""vl',bv'd" '"
- g. Increase 340 27 320 4
+
'"'5""
27,920
- h. Decrea se l-S 820701004S 820601 Standarc Form 83 (Rev 3-81)
PDR ORO EUSOMB For Use Beginn+ng 4/1/81 PDR
- 17. Abstract-Needs and Usss (50 words orisss)
Licensees are required to qualify essential electrical equipment to assure that the equipment will perform its accident mitigation functions.
l
- 18. Related report f ormts) (give OMB number (s). lRCN(s),
- 20. Catalog of Federal Domestic Assistance Program Number l
intsinalagenc y report form number (s) or symbol (s))
N/A Regulatory Guide 1.89 Proposed, Revision 1
- 21. Smali business or organization O Yes Pb No NUREG-0588 l 19 Type of affected public (Check as many as apply)
- 22. Type of activity of affected public-indicate 3-digit Standard 1 O individuals or households
- Y'
~
10, check O Multiple or O All 2 O state orlocalgovernments 3 O farms 4 CC businesses or otherinstitutions (except farms) 4
_k
_3._
~
- 23. Brizf description of affected public (e g.,"retailgrocery stores."" State education agencies."" households in 50 largest SMSAs")
NRC Power Plant Licensees 24 Purpose (Check as many as apply It more than one. indicate
- 26. Collection method (Check as many as apply) predominant by an asterssk) 1 [R mail self-administered 1 O application for benefits 2 O other self-administered 2 O program evaluation 3 O telephone interview -
3 O generalpurpose statistics 4 O persona! interview 4 2 regulatory or compliance 50t recordkeeping requirement:
5 O program planning or management Required retention period: 40 years 6 O research 6 O other-describe:
- 25. Frequency of Use
- 27. Co!!ection agent (Check one) 1 O Nonrecurring 13 requesting Department / Agency Recurring (check as many as apply) 2 O other FederalDepartment/ Agency 2)O on occasion 6O semiannually 3 O privite contractor 3 O weekly 70 annually 4 O recordkeeping requirement 4 O monthly 8 0 biennially 5 O other-describe:
5 C Quarterly 90 other-describe:
28' Authority for agency for information collection or 330 Do you promise confidentiality?
rulemaking-indicate statute regulation, judicial decree.
(if yes, explain basis for pledge Atomic Energy Act of 1954 in supporung statement)
O Yes Ot No Energy Reorganization Act of 1974
- 31. Will the proposed information collection create a new or become part of an existing Privacy Act system of records?
29 Respondent s obligat>on to reply (Check as many as apply)
(If yes. attach Federal Register notice or proposed draft of i
t O voluntary notice.)
O Yes O( No 2 O reau. red to obtain or retain benefit 32 Cost to Federa1 Government of a lt mancatory-cite statute.not CFR (attach copy of information collection or rutemaking 5411 90 statutory authority)
COMPLETE ITEMS 33 THRU 35 ONLY IF RULEM AKING SUBMISSION
- 33. Compliance costs to the public
- 34 is there a regulatory impact
- 35. ls there a statutory or judicial analysis attached?
deadline af fecting issuance?
5 0 Yes O No O Yes. Enter date.
O No CERTIFIC ATION BY AUTHORIZED OFFICI ALS SUBMITTING REQUEST-We certif y that theinformation collection or ruiemalung submitted for review is necessary ter the proper performance of the agency's f unctions. that the proposal represents the minimum oublic Durden and Federal cost Consistent w.th need. and is consistent with aDolicable OMB and agency pohey directives Signature and title of.
cr,,c.aco.m om s.
mci..
o.1c
.</LL G/+
fpn Pa r1 cia G. Norry,61/E D
. Stephen cot
/
'y e
SUPPORTING STATEMENT FOR 10 CFR 50'Section 50.49 Environmental Qualification of Electrical Equipment for Nuclear Power Plants Justification Nuclear power plant equipment must be able to perform the safety functions throughout its installed life. The final rule is designed to assure the NRC that the electrical equipment will be able to perform its accident mitigation functions under the postulated environmental conditions. To accomplish this objective, the proposed rule requires licensees to qualify the essential. electrical equipment. Although testing is to be the primary method of qualification, analysis in lieu of testing will be permitted if the testing of equipment is impractical because of limitation due to the state of the art.
By its Memorandum and Order CLI-80-21, dated May 23, 1980, the Connission directed that the D0R Guidelines for Evaluating Environmental Qualification of Class IE Electrical' Equipment in Operating Reactors and NUREG-0588, " Interim Staff Position of Environmental Qualification of Safety-Related Electrical Equipment," form the basis for the requirements licensees and applicants must meet for environmental qualification of electrical equipment. This Memorandum and Order also included certain reporting and recordkeeping requirements which licensees of the operating nuclear power plants are required to comply with.
The recordkeeping requirements in general terms are contained in Sections XI and XVII of 10 CFR 50, Appendix B.
The rule will codify the Commission's current requirements for the qualification of electrical equipment and explicitly state the reporting and recordkeeping requirements.
In addition to the proposed rule, a revised Regulatory Guide 1.89 is being issued to describe acceptable methods of implementing the rule.
The information collection requirements and acceptable methods of compliance contained in the rule and Regulatory Guide 1.89, respectively, consist of the following:
A.
50.49(d):
establishment of records listing all electrical equipment covered by the rule, its performance characteristics, its electrical characteristics, and the environmental conditions in which it must operate.
B.
50.49(g):
submission of a report which identifies the electrical equipment already qualified prior to the effective date of the rule and a schedule for testing or replacing the remaining electrical equipment.
C.
50.49(h):
notification of any significant equipment' qualification problem that may require extension of the completion date within 60 days of its discovery.
~~
D.
50.49(i):
submission of an analysis by an applicant for an operating license to ensure that the plant can be safely operated pending completion i
of the environmental qualification of electrical equipment.
l
s i
E.
50.49(j): maintenance of records of electrical equipment qualified under the proposed regulations, retained for the life of the plant.
Regulatory Guide 1.89 does not impose additional reporting and/or recordkeeping requirements beyond what is covered by the rule.
These records and reporting requirements are all necessary to ensure that electrical equipment covered by the rule are qualified to provide adequate assurance of public safety.
Description The rule applies to all operating nuclear power plants and the plants which will l
be licensed after the effective date of this rule.
Qualification testing is performed on prototype equipment. Analysis in lieu of testing is allowed if type testing is precluded by the state of the art.
Time Schedule The electrical equipment covered by the rule for the operating nuclear power plants must be qualified by the second refueling outage beyond March 1982.
Information under provisions of Section 50.49(d) is not required to be submitted to NRC.
Submission of schedule under Section 50.49(i) is required on a one-l time-only basis within 90 days after the effective date of the final rule.
Information under Section 50.49(h) shall be submitted only when a problem occurs.
The reports will be reviewed by the NRC staff within 15 days after receipt.
Submission of analysis under Section 50.49(i) is required on a one-time ' oasis only upon publication of the final rule.
These analyses will be reviewed by the NRC staff within 90 days after receipt.
Recordkeeping requirements under Section 50.49(j) must be completed no later than November 1985 for all operating nuclear power plants.
Consultations Outside the Agency NRC staff participates in the development of national IEEE standards. Since 1975, these IEEE standards require maintenance of qualification records of l
essential electrical equipment.
6 e
e i
e Estimate of Burden Compliance Burden
- For 72 Operating For 30 Nuc. Pwr. Plts.,
Nuclear Power Plants 10 to be licensed each Requirement (mh/ plant) year (mh/ plant)
To To To "To Licensees Govt.-
Applicants Govt.
50.49(d)
Development of list of essential electrical Previously Accomplished equipment and its characteristics (one time only) 50.49(g)
Submission of a schedule for testing and 160 8
160 8
replacement (one time only)
Sub Total 3,840 192 1,600 80 50.49(h)
Reporting of significant qualification problem 40 8
40 8
(Average 4 responses, 8 annually per plant)
Sub Total 2,880(A) 576(A) 800(A) 160(A) 50.49(i) Submission o^f a safety analysis report N/A N/A 40 8
Sub Total 400 80 50.49(j ) Maintenance of Qualification file (Average 200 100 200 100 4 responses annually per plant)
Sub Total 14,400(A) 7.200(A) 4,000 2,000 Sub Total Licensee / Applicant Burden 21,120 6,800 Total Licensee / Applicant Burden 27,920 Sub Total Cost to Government 7,968 2,320 Total Cost to Government 10,288
?l[/O77 Annual.
All' other burdens are one-time and are annualized over the three year period of the 3150-0011 cl eara nce.
Estimates of Cost to Federal Government
.' Estimated cost per plant is included in paragraph entitled " Estimate of Compliance Burden." The total cost to the Government is estimated to be $411,520 (10,288 hours0.00333 days <br />0.08 hours <br />4.761905e-4 weeks <br />1.09584e-4 months <br /> x $40/hr.).
f g
f, MAY (4 194l
[7590-01]
NUCLEAR REGULATORY COMMISSION 10 CFR Part 50 Environmental Qualification of Safety-Related Electric Equipment for Nuclear Power Plants AGENCY:
Nuclear Regulatory Commission.
ACTION:
[Preposed] Final rule.
SUMMARY
The [Heciear-Regeistory] Commission is [ proposing-te] amending its regulations applicable to nuclear power plants to clarify and strengthen the criteria for environmental qualification of safety-related electric equipment.
Specific qualification methods currently contained in national 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 ruie-weeld] codifyies the[se] environmental qualification methods and criteria that meet the [and-ciarify-the] Commission's requirements in this area.
EFFECTIVE DATE:
[UPON publication in the Federal Register]
[ BATES: Eemment period expires (68 days after publication in the FedersiRegister): Eemments received after ----------- wiii be censidered if it is practiesi to de re-bet asse.rance of consideration cannet be given except as to comments received,en er before this date-ABBRESSES: Written cemments and seggestions may be maiied to the 1
'[7590-01]
t Secretary of the Eemmission-Attention: Becketing and Service Branch-8:S: Naciear Regulatory Eemmissien-Washington-8:E: 20555 or hand-delivered to the Eemmission's Public Becement Room at 1717 H Street NW:-- Washington-- 8:E:- between the hears of 8:30 a-m and 4:45 p:m: on normal 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 proposed rulemaking on environmental qualification of electric equip-ment for nuclear power plants (47 FR 2876).
The comment period expired March 22,1982. ' A total of 69 comment letters raising 10 major issues were received by April 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 Scope of 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 an,d 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
4
+
[7590-01]
Reprocessing Plants," to 10 CFR Part 50; and in paragraph 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 l
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 1,1974, the Commission has used Regulatory Guide 1.89,
" Qualification of Class 1E Equipment for Light-Water-Cooled Nuclear Power Plants," which endorses IEEE 323-1974,2 "IEEE Standard for Qualifying Class IE Equipment for Nuclear Power Generating Stations," subject to supplementary provisions.
Currently, the Commission has 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 criteria for environmental qualification of safety related electric equipment [important-to safety) have been developed by the NRC.
A document entitled " Guide' lines for Evaluating Environmental Qualification of Class 1E Electrical Equipment in Operating Reactors" (DOR Guidelines) was issued in November 1979.
In addition, the NRC has issued NUREG-0588, " Interim Staff Position on 11ncorporation by reference approved by the Director of the Office of Federal Register on January 1,1981.
2Copies may be obtained from the Institute of Electrical and Electronics Engineers, Inc., 345 East 47th Street, New York, N.Y. 10017.
3
[7590-01]
Environmental Qualification of Safety-Related Electrical Equipment," which contains two sets of criteria:
the first for plants originally reviewed in accordance with IEEE 323-1971 and the second for plants reviewed in accordance with IEEE 323-1974.
By its Memorandum and Order CLI-80-21 dated May 23, 1980, the Commission directed the staff to proceed with a rulemaking on environ-mental qualification of safety grade equipment and to address the ques-tion of backfit.
The Commission also directed that the DOR Guidelines and NUREG-0588 form the basis for the requirements licensees and appli-cants must meet until the rulemaking has been completed.
This preposed rule is generally based on the requirements of the Division of Operating Reactors (00R) Guidelines and NUREG-0588.
Requalification of electric equipment in accordance with this rule will not be required for equipment qualified or being qualified in accordance with DDR Guidelines or NUREG-0588 provided the qualification of electric eouipment has commenced prior to
[ Insert a date 90 days after the effective date of this amendment].
The dates specified in this rule for ' completion of environmental qualification of safety-related electric equipment apply to all licensees l
and applicants and supersede any date previously imoosed.
No changes to licenses or technical specifications are necessary to reflect these l
new completion dates.
[The Eemmission's Memerandem and Order Eti-88-21 directed that the environmental qesiification of electric equipment in operating neciear pewer plants be tempieted by dene 1982- - Hewever en September-ES-i 1981-the Eemmission censidered the petition (SE6Y-81-486fie extend this l
l l
4
[7590-01]
deadline: The preposed rule covers the same electrie equipment as EEf-80-El and implements SE6Y-81-486 by incorporating the extension dates recommended by the 6hairmen in his memorandem-dated September-36-- 1981.
Incieded in the proposed rule is a requirement that each holder of er each applicant for a license to operate a naciear power piant identify and qualify the electric equipment needed to complete ene path of achieving and maintaining a ceid shutdown condition: The Eemmissien specifically requests comment en this preposed additionsi requirement:]
The scope of the [ proposed] final rule does not include all electric equipment important to safety in its various gradations of importance.
It
[inciedes] covers that portion of equipment important to safety commonly referred to as " safety-related." [er u61 ass-1Eu equipment-in-fEEE national standards and seme additionai nen-64 ass-iE-equipment and systems-whose failure under-extreme-environmental cenditions-could prevent-the satis-factory accempiishment of safety-fenetiens-by-accident mitigating equipment:] Safety related electric equipment is essentially " Class lE" equipment as defined in IEEE 323-1974.
Included in the [ proposed] final rule are specific technical require ments pertaining to (a) qualification parameters, (b) qualification methods, and (c) documentation.
Qualification parameters include temperature, pressure, humidity, radiation, chemicals, and submergence.
Qualification methods include (a) testing as the principal means of qualification and (b) analysis and operating experience in lieu of testing.
The [ proposed]
l final rule wecid requires _ that the qualification program include synergistic effects, aging, margins, radiation, and environmental conditions.
- Also, j
a record of qualification must be maintained.
Proposed Revision 1 to Regulatory Guide 1.89, [is being revised te] which has been issued for 5
[7590-01]
i public comment, will describe methods acceptable to the NRC for meeting the provisions of this [ proposed] rule and [to] will include a list of typical equipment covered by it [a-draft of-the proposed]. Revision 1_
Eis-being pebiished-for peblic cemment-concurrently with-the proposed reier to Regulatory Guide 1.89 will be issued after resolution of public comments.
Specific guidance on replacement parts will be included in Regulatory Guide 1.89.
The Commission expects that licensees and appli-cants will utilize the replacement process to uograde the quality of electric equipment to the provisions of this rule.
[Also-incieded-in-the proposed-reie-is a requirement--which-is-consis tent with-Eemmission-Memorandem and-erder--Eti-80-El--for sebmission---
of an-analysis-by-iicensees-to ensure-that-the piant can-be safeiy operated pending-cempietien-of-the-environmentai qualification of electric equip-ment:--The-Eemmission expects-thst--for each-of-the-currently eperating power pients--this analysis-and-its evalestion-by-the-NRE-staff-wiii-be completed-weii-in-advance of-the effective-date-of-this rule---if-the licensees of-eperating power piants-faii-to provide-these analyses-in a l
timely-manner--the-Eemmissien expects-the-NRE staff-to-take-the appro-l priate steps-to-require-that-the-informatien-be provided and-to enforce compliance with-this requirement---This requirement-has-been-incieded-in this proposed-reie-to provide-a-regeistory-basis-for enforcement-]
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 event conditions.
To ensure integri'ty of a testing prograTn; the same j
piece of equipment must be used throughout the complete test secuence.
1 6
[7590-01]
[ Analysis may-be acceptable-if-testing-of-the-equipment-is-impractical because-of size--er-iimitation-due-to-the-state-of-the artr--The pro-posed-rule-tahes-inte-considerstion-the prior qualification-history of the-operating power piants:--For example--the proposed reie-recognizes that-for-these plants-which are-not-committed-to either-fEEE-SES-1971-or
.~
IEEE-SE3-1974-for equipment qualification--and-have-been-tested-eniy-for high-temperature pressure--and steam-seme equipment may-not-need-to-be tested again-to-inciade ether service cenditiens sech as radiation and chemical-sprays':--The qualification of equipment-for-these service condi-tiens-may-be established-by-analysis-]
The [preposed] final rule weaid 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 would-have-to must be submitted written b,y [ Insert a date 90 days after the effective date of this amendment]. rele: EHewever--this-time period-wiiSe adjested-dering-the-finai raie-making process-to-aliew reasonabie-time-for-licensees-to evaluate-NREls safety-reviews-that are currentiy anderway.
The preposed-rule wiii-codify-the-Gemmission s current requirements i
j fer-the environmentai qualification-of electric equipment---Upon peblica-tion of a-tinal-reie--the-96R geidelines and-N8RE6-0588-wi41-be withdrawn:]
l The general requirements for seismic and dynamic qualification for electric equipment are contained in the General Design criteria.
Pending development of specific requirements in this area, the 'g'e'neral require-
~
ments will continue to apply.
NRC is considering expansion of the scope 7
[7590-01]
i of this rule to include additional electric equipment important to safety.
This matter will be the subject of a future rulemaking.
[Additiensi-views-of-Eemmissioner-Bradford:--Eemmissioner-Bradford believes-that-the propesed-desdiine-(second refeeling-outage after '
March-31--I 823-for qualification-is-mech-teo reiaxed-given-the-fact that-iicensees and-the-NRE-have-been-aware-of-the problems-in-this area since-1978---The proposed-deadline extends-as mech-as-two and one-half years-beyond-the-dene-38--1983-date-by which-the-Atemie-industriai-Forum concluded-that-nearly-ali electrical equipment cocid-be qualified.
Given-the-more genereas-deadline--he aise-believes-that-the rule should have contained requirements-for seismic and-dynamic qualification---While the generai-design criteria-centain requirements-in-this ares--tiarifica-tion-new-weeld-ensere-that equipment-to-be-replaced-in-the near-term-wiii not-have-to-be-ripped oct-in-a-few years-because-it-was not properiy seismically qualified-Eemmissioner-Giiinsky-has-agreed with-these views-]
Comments On The Proposed Rule l
The Commission received and considered the comments on the proposed l
l rule contained in the 69 letters received from the public by April 6, 1982.
Copies of those letters and a staff resoonse to each comment are available for public inspection and copying for a fee at the Commission's Public Document Room at 1717 H Street NW., Washington, D.C.
Single copies of the analysis of the comments may be obtained through written request to the Office of Administration, Document Managemen~t Branch, U.S. Nuclear Regulatcry Commission, Washington, D.C.'20555.
~
1 The major issues raised by the comments and NRC staff responses l
are as follows:
8 l
l
[7590-01]
(1) Seismic and Dynamic Qualification - Paragraph 50.49(a)
Issue:
Seismic and dynamic qualifications are an integral part of environmental qualification.
It is therefore inappropriate to codify these requirements separately.
Response
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.
The Commission has decided, after considerable de' liberation, to pursue this issue at a future date through the issuance of an advance notice of proposed rulemaking.
Any seismic qualification testing of equipment in operating plants that may be required by future rulemaking will not require retesting for environmental stresses solely because a single prototype was not used during the original qualification.
(2) Scope - Cold Shutdown Reauirement - Paragraph 50.49(c)
Issue:
The rule introduces a new requirement to qualify " equipment needed to complete one path of achieving and maintaining a cold shutdown condition." A change of this magnitude, at this advanced stage of the 1
industry's qualification effort, most certainly introduces significant new costs and obligations with no demonstrated improvement in safety.
Response
The Commission 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 j
systems necessary to bring the reactor from norma'l operating co'nditions l
to cold shutdown be designed to Class lE standards.
Therefore, to l
l require that all plants environmentally cualify the electric equipment and systems needed to complete one path of achieving and maintaining 9
(7590-01]
i a cold shutdown condition may reauire the upgrading of a significant amount of equipment and systems that do not currently meet C? ass lE standards for operating reactors.
However, electric equipment and systems necessary to mitigate the consequences of design basis accidents should be required to meet Class IE standards for all reactors and there-fore, would be covered by the rule.
The Commission 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 require-ments to ensure that failure to remove shutdown decay heat does not pose an unacceptable risk.
Under A-45 a comprehensive and consistent r,et of shutdown cooling requirements for existing and future plants are being i
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 equipment 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) Scope - Equipment in a Mild Environment - Paragraph 50.49(c)
Issue:
The rule makes no distinction between equipment located in a harsh or mild environment.
The stresses for equipment in a mild environment are less severe than for those in a harsh environment.
Response
The final rule does not cover the electric eauipment located in a mild environment.
The Commission has concluded that the general cuality and surveillance requirements applicable to safety-related electric equipment as a result of other Commission regulations, 10 i
= _ _ - -. _ _ - -. _ -
__ - _ = _ _. _ _ _
[7590-01) including 10 CFR Part 50, Appendix B (see for example, Regulatory Guide 1.33) are sufficient to ensure adequate performance of safety-related electric equipment located in mild anvironments.
Since it has been concluded that no further environmental qualification requirements are needed for such equipment provided they fully satisfy all other i
applicable regulations, the Commission has determined that no additional requirerr.ents are necessary with respect to safety-related equipment located in mild environments in order for licensees to satisfy,. with
{
respect to such equipment, existing license conditions or technical soecifications calling for qualification of safety-related electric e_auipment in accordance with DOR Guidelines or NUREG-0588.
i (4)' Scope - Previous Qualification Efforts - Paragraph 50.49(c)
Issue:
The rule does not recognize that operating plants have just completed qualification of equipment to the D0R Guidelines or NUREG'0588.
Withcut such recognition, industry efforts, manpower, and billions of dollars will go down the drain.
Response
The final rule has been expanded to alleviate this concern.
(5) Humidity - Paragraph 50.49(e)(2)
Issue:
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
The Commission agrees.
The words " Time-dependent variation of relative" have been deleted from Paragraph 50.49(e)(2).
(6) Aging - Paragraph 50.49(e)(5)
Issue:
The requirement that onooinq qualifications'b'e'done using
" prototype equipment naturally aged" is overly restrictive.
Use of 11
[7590-01]
dCCelerated aging to define a Qualified life is not technically feasible.
Response
Paragraph 50.49(e)(5) has been modified to alleviate this concern.
(7) Margins - Paragraph 50.49(e)(8)
Issue:
The margins applied in addition to known conservatisms lead to excessive stress that could lead to failures of equipment in unrealis-tic qualification tests.
This paragraph is in conflict with Regulatory Guide 1.89.
Response
The Commission agrees.
The paracraoh has been modified accordingly.
(8) Analysis and partial test data - Paragraph 50.49(f)(4)
Issue:
If. partial type test data that adequately support the analytical assumptions and conclusions are available, their analysis should be allowed to extrapolate or interpolate these results for equipment, reoardless of purchase date.
Response
The Commission agrees.
Reference to " purchase date" has been deleted.
(9) Reauirement for a central file - Paragraph 50.49(j)_
Issue:
The requirement for a central file should be deleted since it is not cost effective and has no safety benefit.
Response
The Commission agrees.
The requirement for a central file has been deleted.
(10) Justification of continued operation fo' r operating plants.
Issue:
The requirement to submit justification for the continued operation of operating plants should be deleted since this information has been previously submitted to NRC.
12 l
I
(7590-01]
Response
This requirement has been satisfactorily met and Paragraph 50.49(j) of the proposed rule has been deleted in its entirety from the final rule.
In addition, Paragraph 50.49(g) of the proposed rule has been deleted from the final rule since it is too crescriptive.
It will be included in Regulatory Guide 1.89.
Effective Date:
This rule is effective upon publication in the Federal Register.
The Commission'has determined 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 Procedure Act.
This j
is so because all operating reactor licensees are currently under a June 30, 1982, deadline to complete environmental qualification of safety-related 3
electric equipment.
The final rule's implementation schedule, as explained above. supplants this date and thus gives licensees additional time to complete environmental qualification of safety-related electric equipment.
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-i tive 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 statutory 30 days and allow 60 additional 1
days to make the submittal required 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.
13 l
l
[7590-01]
Paperwork Reduction Act The [preposed] final rule contains recordkeeping requirements that are subject to review by the Office of Management and Budget (OMB).
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 prannigated-]
will not have a significant economic impact on a substantial number of small entities.
This [preposed] final rule affects the method of qualifica-tion of electric equipment by utilities.
Utilities do not fall 7within 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 D0R " Guidelines for Evaluating Environmental Quclification of Class 1E Electrical Equipment in Operating Reactors," (November 1979) and NUREG-0588, " Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment," which form the basis of this [preposed]
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 plants and reacters, Penalty, Radiation protection, Reactor siting criteria, Reporting requirements.
14
[7590-01]
Pursuant to the Atomic Energy Act of 1954, as amended, the Energy Reorganization Act of 1974, as amended, and section 553 of title 5 of the United States Code, notice-is-hereby given-that-adeptien-of-thethe following amendment to Title 10, Chapter I, Code of Federal Regula-tions, Part 50, 18-EFR-Part-58-is-centemplated is published as a docu-ment subject to codification.
The authority citation for Part 50 continues to read as follows:
AUTHORITY:
Secs. 103, 104, 161, 182, 183, 189, 68 Stat. 936, 937, 948, 953, 954, 955, 956, as amended (42 U.S.C. 2133, 2134, 2201, 2232, 2233, 2239); secs. 201, 202, 206, 88 Stat. 1243, 1244, 1246 (42 U.S.C.
5841, 5842, 5846), unless otherwise noted.
Section 50.78 also issued under sec. 122, 68 Stat. 939 (42 U.S.C.
2152).
Sections' 50.80-50.81 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 S$50.55(e), 50.59(b), 50.70, 50.71, 50.72, and 50.78 are issued under sec. 1610,- 68 Stat. 950, as amended (42 U.S.C 2201(o)).
t
?
15
g
[7590-01]
2.
A new 5 50.49 is added to read as follows:
6 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 equipment located in a mild environment.
A mild environment is an environment that would at no time be sianificantly more severe than the environment that would occur during normal plant operation or during anticipated operational occurrences.
(b)
Each holder of or each applicant for a license to operate a nuclear power plant shall establish a prngram for qualifying the electric equipment as defined in paragraph (c) of this section.
(c) Safety-related electric equipment and systems covered by this section include electric equipment and systems that are [essentiai-te emergency reactor shutdewn--eentainment-isolation-reacter core-cooling-and containment and-reacter-heat removal-or-that-are etherwise essentini l
in preventing significant-release of radioactive-material-to-the environ-ment:--Incieded-is equipment-fi)-that performs-the above-functions auto-l matically--(23-that-is-esed-by-the eperator-to perform-these-functions l
manually--and-(3) whose-faiiere-can prevent-the satisfactory-aceemplish-ment of-ene-or-more of-the above-safety-functions:---Aise-incieded-is equipment-needed-to-complete ene path-of achieving and-maintaining a ceid shetdown condition:] designed to remain-functional for postulated accidents and are necessary to assure (1) the integrit9'6f't.he reactor
~
coolant pressure boundary. (2) the capability to shut down the reactor and naintain.it in a safe condition, and (3) the capability to prevent 1
16
[7590-01]
or mitigate the consequences of accidents which could result in poten-tial offsite exposures comparable 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-auditable-forms:--This-iist of-equipment mast-as-a minimum--incinde-]
In addition, the applicant or licensee shall include the following information for safety-related electric equipment in a qualification file:
(1) The performance specifications [and structural-integrity require-ments] under co.nditions existing during normal and abnormal operation and during design basis events and afterwards. [and-the-lengths-of-the periods daring-which-the-integrity mast-be-maintained:]
(2)
[The range-ef] 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 conditions, including temperature, pressure, humidity, radiation, chemicals, and submergence [and-the predicted varia-tiens-of-these envirenraental conditions with-time] at the location where the equipment must perform as specified in accordance with paragraphs (d)(1) and (2) of this section.
(e) The electrical equipment qualification program must include the following:
(1) Temperature and Pressure.
The time-dependent temperature and pressure at the location of the equipment must be established for the most [3imiting] severe of the applicable [ postulated-accidents] design basis events and must be used as the basis for the envi.ronmental qualification of safety-related electric equipment.
17
[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 es severe as that resulting from the most limiting mode of plant operation (e.g., containment spray, emergency core cooling, or recircula-tion frcm containment sump).
If the composition of the chemical spray can be af fected by equipment malfunctions, the most severe chemical spray environtrent 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-radiation environment]
2 expected during normal 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.
[Eiectremechanical equipment mest-be I
eperated-to-the-mechsnical-wear and eiectrical-degradstion expected-dering its-installed-life-]
I_f Where preconditioning to an installed end-of-life l
condition [a qualified-life equai-to-the-instalied-life] is not [possibie]
practicable and technically meaningful, the equipment may be preconditioned to a shorter [ qualified] designated' life.
The equipment niust be replaced or refurbished at the end of [its qualified] this designated life unless ongoing qual.ification [of] demonstrates [pretetype equipment natursily aged l
18 l
[7590-01]
in plant.ervice shew--by artificiai aging-and-type-testing] that the item has additional [ qualified] life.
(6)
Submercence (if subject to being submerged).
(7) Synergistic Effects.
[The preeenditioning and-testing of equip-ment must-consider-known] 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 environmentai conditions-] any conservatisms applied during the derivation of environ-mental conditions unless these conservatisms can be quantified and shown to contain appropriate margins.
(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 supporting analysis to show that the equipment to be qualified is acceptable.
1 (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-Analysis-in-iieu of-testing-in-the-feiiewing-eases-:-
(i)--if-type-testing-is preieded-by-the physiesi sire'-of-the equip.
~
ment or-by-the state-of-the-art-]
19
^
[7590-01]
(4)
(ii3 [By] Analysis in combination with partial type test data (which] that supports the analytical assumptions and conclusions.
[--if-the equipment purchase-order-was executed prier-to-May-23--1980.
(g3--if-an-item-ef-electric equipment-is-to-be qusiified-by-test--
(13--The acceptance criteria-mest-be established prier-to-testing-(23--The-tests-mast-be-designed-and conducted-to-demonstrate-that the equipment-can perform-its-required-fanetion as specified-in accord-ance-with paragraph-fd)(13-of-this section-for alf conditions as speci-fied-in-accordance with paragraphs-(d)(23 and-(S) of-this section---The test prefiic-(e g:- pressere--temperature--radiation vs--time 3-mast inciede-margins as set-forth-in paragraph-(e3(83 of-this section-(33--The-test profile-mast-be either-fi) a single profile-that envelops-the-environmentai cenditiens-resciting-frem any-design-basis event-dering-any-mode of piant operatien-fe g-- a profile-that enveieps the-conditions produced-by-the-ecstulated spectrem of-main steamiine break-(M5tB3-and-less of ceeient seeidents-(t06A33-er-fii3 separate pro-files-for cach-type of event-f e g:--separate prefiles-for-the-MSEB acci-dents and-for-t06As3-(43--The-same picee-of equipment-mest-be escd-threeghout-the eempiete test-sequence ender any given profile-]
[(h3] h), Each holder of an operating license issued prior to (insert the ef fective date of this amendment) mest, 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 i
submit a schedule for the cualificat' ion [ 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
[7590-01]
refueling outage after March 31, 1982.
The Director of Nuclear Reactor Regulation may grant requests for extensions of this deadline to a date no later than November 30, 1985, for specific pieces of equipment if [sech]
thesa 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] 6_0 days of its discovery.
[(j)--For-the contineed-eperation-of-a neciear piant-esch-heider ef an eperating-4icense-isseed prier-to-the effective-date of-this reie-shali perform-an-analysis-to ensere-that-the piant-esn-be-safely eperated pending completion-of-the environmentai qualification---The-detailed analysis-for each equipment-type-with-sppropriate-justification mest-be sebmitted-to Birector of-Neciear-Reseter-Regeistory-by-(insert-the effective-date-ef the rele3-snd mest-inciede--where-appropriate--eensideration-ef:
(33--Accemplishing-the safety-fenetien-by seme-designated aiternative equipment-thst-has-been-adeqeately qualified and-satisfies-the singie failere criterien-if-the principal equipment-has-not-been-demonstrated-te be-feliy qcsiified-
)
(23--The-vsiidity-ef partial-test-data-in seppert of-the original t
l qualifiestien-i (3)--timited ese of administrative centrois over equipm'ent-that-has l
net-been-demonstrated-to-be-feily qualified-l 21 I
l
[7590-01]
(43--Eempietion-ef-the-safety-fenetien prier-te exposure-to-the ense-ing-accident environment and-the subsequent-faiiere of-the equipment-dees net-degrade any safety-fenetion or misiesd-the operator-(53--No-significant-degradatien-of-any-safety-fenetion-et-misleading ef-the operater-as a-rescit of-failure-of equipment ender-the accident environment-]
[(k3] (i) The applicant for an operating license that is granted on or af ter [ 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-(j) of-this sectien-except-that-this-analysis]
This analysis must be submitted to the Director of Nuclear Reactor t
Regulation for consideration prior to the granting of an operating license and must include, where appropriate, consideration of:
(1) Accomolishing the safety function by some desionated alternative equioment if the principal equipment has not been demonstrated to be fully qualified.
(2) The validity of' partial test data in support of the oricinal qualification.
(3)
Limited use of administrative controls over eouipment that has not been demonstrated to be fully qualified.
(4) Completion of the safety function prior to expcsure to the ensu-ing accident environment and the subsequent failure of the equipment does not degrade any safety function or mislead the operator.
(5) No significant degradation'of any safety function or misleading of the operator as a result of failure of equioment under the accident environment.
22 1
[7590-01]
[(4)] {11 A record of the qualification including documentation in paragraph (d) of this section must be maintained in [a-centrai-file]
an auditable form for the entire period during which the covered item is installed in the nuclear power plant or is stored for future use to permit verification that each item of safety-related electric equipment covered by this section (1) is qualified for its application and (2) meets its specified performance requirements when it is subjected to the conditions predicted to be present when it must perform its safety function up to the end of its qualified life.
~
(k)
Licensees are not required to qualify electric equipment in accordance with the requirements of this rule provided the following conditions are met:
(1) Qualification of safety-related electric equipment commenced prior to [ insert date 90 days after effective date of this rule), and (2) Qualification of electric equipment was done in accordance with the existing license conditions or technical specifications requiring such equipment to be cualified according to " Guidelines for Evaluating Environmental Qualification of Class 1E Electrical Equipment in Operat-ing Reactors," November 1979, or NUREG-0588 (For Comment version),
" Interim Staff Position on Environmental Qualification of Safety-Related Electrical Eouipment."
Dated at this day of
, 1982.
For the Nuclear Regulatory Commission.
Samuel J. Chilk Secretary of the Commission 23 L
's t
k 5
VALUE/ IMPACT STATEMENT h
1.
PROPOSED ACTION i
i i
1.1 Description The applicant (licensee) of a nuclear power plant is required by the Commission's regulations to verify that structures, systems, and components j
important to safety will perform their intended functions in spite of the j
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 Commission't requirements for the environmental j
j qualification of safety-related electric equipment by test and analysis.
J
.3 3
j' 1.2 Need for Procosed 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 k
Appendix A to Part 50; Sections III and XI of Appendix B to Part 50; and j
Paragraph 50.55a(h) of Part 50, which incorporates by reference IEEE 279-1971,*
I lj
" Criteria for Protection Systems for Nuclear Power Generating Stations." The ij NRC has used several methods to ensure that these general requirements are met
- }
for safety-related electric equipment.
Prior to 1971, qualification was based on the fact that the electric components were of high industrial quality.
For
?
.i 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 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 1
{.
reports were issued after July 1,1974, the Commission has issued Regulatory Guide 1.89, which endorses IEEE 323-1974* subject to supplementiry provisions.
- Copies may be cbtained from the Institute of Electrical and Electronics j
Engineers, Inc., 345 East 47th Street, New York, N.Y. 10017.
l Ti 1
]
Currently, the Commission has under way a program to reevaluate the quali-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 (DOR) issued
" Guidelines for Evaluating Environmental Qualification of Class IE Electrical l
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-sion endorsed the staff's actions to use the 00R 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 equipment. The Commission also ordered that licensees of operating reactors must comply with these requirements so that the applicable equipment
~
in all operating plants will meet the 00R Guidelines or NUREG-0588.
~
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 l
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 00R Guidelines and NUREG-0588, (3) in IEEE standards committee work, and (4) in the development, funding, and monitoring of related research programs..
There should be little impact on the. staff at the time the rule is approved.
Approximately two man years of effort have be'en spenf. in prepaiation of the rule.
1.3.2. Other Government Agencies Not applicable, unless a government agency is the applicant.
2
s.
I 1.3.3 Industry The licensees and applicants currently must meet the requirements for qualification of safety-related 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 significant impact on industry because of backfit.
The value of this rule is that the industry will have clearly specified j
requirements to follow with respect to the qualification of safety-related j
electric equipment for new and existing plants. This, in turn, should ease j
the licensing process for industry by eliminating delays resulting from i
misinterpretation of NRC's requirements.
1 3
\\
}
1.3.4 Public 3
The proposed action will improve public safety by further ensuring that electric equipment will perform its safety functions in spite of environments j
that may result from design basis events. These is no perceived impact on the public.
3 1.4 Decision on Proposed Action
.i
.t The proposed action has been mandated by the Commission in its Memorandum A
and Order CLI-80-21 dated May 23, 1980.
~
2.
TECHNICAL APPROACH
.]
.)
The technical approach will be to codify the programs of the DDR Guidelines and NUREG-0588.
t
'j 3.
PROCEDURAL APPROACH k
i Rulemaking has been mandated by the Commission in its Memorandum and Order
'i' cited above.
3, r
1 l3
-I i
J i
.i s
3
4.
STATUTORY CONSIDERATIONS i
I 4.1 NRC Authority
?
h j
Authority for this rulemaking is derived from the Atomic Energy Act of 1954, as amended, and the Energy Reorganization Act of 1974, as amended.
7 3
4.2 Need for NEPA Assessment i
1 1
}
The proposed action does not require an environmental impact statement in
'.i accordance with 51.5(d)(3) of 10 CFR Part 51.
t I
5.
RELATIONSHIP TO OTHER EXISTING OR PROPOSED REGULATIONS OR POLICIES 3
.1 No conflicts or overlaps with requirements promulgated by other agencies 1
}
are foreseen.
i 6.
SUMMARY
AND CONCLUSIONS
\\j This rule mandated by the Commission will be effecti.ve upon publication,
!)
which is expected prior to June 30, 1982.
1
,s
?
>?
3 1
3 l-
-y 3
1 l
2 t
t 4
,