ML20238E413
| ML20238E413 | |
| Person / Time | |
|---|---|
| Issue date: | 08/31/1987 |
| From: | Aggarwal S, Calvo J, Rosa F Office of Nuclear Reactor Regulation, NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | |
| References | |
| RTR-REGGD-1.158, TASK-EE-006-5, TASK-EE-6-5, TASK-RE REGGD-01.XXX, REGGD-1.XXX, NUDOCS 8709140332 | |
| Download: ML20238E413 (10) | |
Text
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- % U.S. NUCLEAR REGULATORY COMMISSION August 1987
./ 3, OFFICE OF NUCLEAR REGULATORY RESEARCH Division 1 a
Task EE 006-5 i* i
- DRAFT REGULATORY GUIDE e
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Contact:
S. K. Aggarwal (301) 443-7840 QUALIFICATION OF SAFETY-RELATED LEAD STORAGE 9ATTERIES FOR NUCLEAR POWER PLANTS A. INTRODUCTION The Commission's regulations in 10 CFR Part 50, " Domestic Licensing of Production and Utilization Facilities," require that structures, systems, and components important to safety in a nuclear power plant be desjgned to accom-modatetheeffectsofenvironmentalconditionsandthatdesigNcontrolmeasures s'uch as testing be used to check the adequacy of design. These general require-mentsarecontainedinGeneralDesignCriteria1,2,4,/ilnd:kofAppendixA.
" General Design Criteria for Nuclear Power Plants," y pto'Part 50, in Criterion III, i
" Design Control," and in Criterion XVII, " Quality Assurance mu Records," of Appen-dix B, " Quality Assurance Criteria for Nuclear Poher3P1' ants and Fuel Reprocess-ing Plants," to Part 50. e $u 4 s %
This regulatory guide describes a method icce^p , table to the NRC staff for
% e complying with Commissun regulations withygard'to qualification of safety-related lead storage batteries for nuclearjoweE % y plants.
Any information collection activitiislmentioned
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in this draft regulatory guidearecontainedasrequirement$.i.in10,;CFRPart50,whichprovidestheregu-latory basis' for this guide. The,iNformationcollectionrequirementsin10CFR Part50havebeenclearedundefbMB(ClearanceNo. 3150-0011.
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B. DISCUSSION fu TheStationDesigg$ubcommitteeoftheInstituteofElectricaland Electronics Engineers,(IEEE) has prepared IEEE Std 535-1986, "IEEE Standard for c ,.
QualificationoffClas'si1ELeadStorageBatteriesforNuclearPowerGenerating A f gi A :b" lhes regulatory gekide is being i s sued i n d ra f t form to envolve the public en the pa rty stages of the develop-ment of a regulatory position in this cres. It has not received complete staff review and does not re p re se n t ,
an official NRC statt position.
Public comments are being solicited on the draf t guide (including any implementation schedule) and its esso-cisted regulatory analysis or volpe/ impact statement. Comments should be accompanied by appropriate supporting data. Written comments may be submitted to the Rules and Procedures Branch, DRR. ARM, U.S. Nuclea r Regula tory Commission, washengton, DC 20$ M. Comments may a lso be delivered to Room 16000. Ma ryland Na tiona l Bank Building,
$P Ic u nt oo 1 5 et , a g$ok 0 Nm nI b mo ehu hai!Nr if receivedItTe by Nove$er20, 1987.
Reauests for single copies of draf t ev6 des (which may be reproduced) or for placement on an autt,mptic distribu-tion test for single copies or future draf t gu60es in speceric divisions shouse be made in writing to the U.S. Nut asa r megulatory commission, washington, DC 205%. Attent6cn: Director, Division or information support Services.
8709140332 870831 PDR HECCD 01.XXX R PDR __ ________-_ -
I Stations."* The IEEE Standards Board approved the standard on September 19, 1985. This standard describes qualification methods for Class IE lead storage batteries and racks to be used in nuclear power plants outside of primary con-tainment.
Since safety-related lead storage batteries must meet or exceed design specifications throughout their installed life, the batteries undergo a program of qualification as part of an overall quality assurance program that also includes requirements for design, production, quality control, installation, maintenance, and periodic testing. This regulatory guide addresses only the qualification portion of the overall quality assurance program.
Batteries qualified by test should be preconditioned by natural or arti- .
ficial (accelerated) aging to their end-of-installed-life condition, and con-sideration must be given to all significant types of degradation that can have an effect on the functional capability of the batteries. There are consider-able uncertainties regarding the processes and environmental factors that could result in such degradation. 'Because of these uncertainties, state of-the-art preconditioning techniques as outlined in IEEE Std 535-1986 are not capable of simulating all significant types of degradation. As the state of the art advances and uncertainties are resolved, artificial preconditioning techniques may become more effective. Until such time, the NRC staff prefers natural preaging of safety-related batteries.
The proposed applicability of this regulatory guide is specified in Sec-tion D, " Implementation." The NRC staff is considering changing the Implemen-tation section in the final guide so that the provisions of this regulatory guide would also apply to replacement batteries in all operating nuclear power plants. This provision would not impose any additional cost on licensees, since all U.S. battery manufacturers have already qualified their batteries to the provisions of IEEE Std 535-1986. The staff has concluded that there is no significant difference between the 1979 and 1986 versions of IEEE Std 535 with respect to the pre-aging part of the qualification testing.
Public comments are specifically invited on the applicability of this regulatory guide to all operating nuclear power plants for replacement batteries.
- Copies may be obtained from the Institute of Electrical and Electronics Engi-neers, IEEE Service Center, 445 Hoes Lane, P.O. Box 1331, Piscataway, NJ 08855.
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IEEE Std 535-1986 references other standards that contain valuable infor-mation. Those referenced standards not endorsed by a regulatory guide or incorporated into the regulations, if used, are to be used in a manner con-sistent with current regulations.
C. REGULATORY POSITION Conformance with the requirements of IEEE Std 535-1986, "IEEE Standard for Qualification of Class 1E Lead Storage Batteries for Nuclear Power Generating Stations," provides an acceptable method for satisfying the Commission's regu-lations with respect to qualification of safety related lead storage batteries for nuclear power plants.
D. IMPLEMENTATION
- The purpose of this section is to provide information to applicants and licensees regarding the NRC staff's plans for using this regulatory guide.
Except in those cases in which the applicant or licensee proposes an acceptable alternative method for complying with specified portions of the Commission's regulations, the methods described herein will be used in the evaluation of the qualification of safety related lead storage batteries for nuclear power plants as follows:
- 1. Plants for which the construction permit is issued after the issue date of the final guide.
- 2. Plants for which the operating license application is docketed 6 months or more after the issue date of the final guide.
- 3. Plants for which the applicant or licensee voluntarily commits to the provisions of this guide.
- Section B, " Discussion," of this regulatory gu' Je discusses the NRC staff's proposed modification to this section, namely, whether this regulatory guide should apply to all operating nuclear power plants.
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DRAFT VALUE/ IMPACT STATEMENT BAC% GROUND Large lead storage batteries are used in nuclear power plants as a source of emergency power for vital instrumentation and control systems such as elec-trical distribution breaker controls for engineered safety features, inverters for the reactor protection instrument channels, and certain other safety-related equipment. Since safety-related lead storage batteries must meet design specifications throughout the batteries' installed life, the batteries undergo a program of qualification as part of an overall quality assurance program that also includes requirements for design, production, quality control, installation, maintenance, and period testing. This guide provides regulatory guidance for the qualification of safety-related lead storage batteries used in nuclear power plants.
VALUE There is no published NRC document that describes methods acceptable to the NRC staff for qualifying safety-related lead storage batteries. As a con-sequence, license reviews of safety related lead storage batteries are being done on a case-by-case basis.
IEEE Std 535-1979, "IEEE Standard for Qualification of Class 1E Lead Stonge Batteries for Nuclear Power Generating Stations," was published in September 1979. This standard needed several improvements. Since then the staff has worked with IEEE in developing IEEE 535-1986, which is satisfactory and meets the Commission's regulations for qualification of safety-related lead storage batteries. Issuance of the regulatory guide is consistent with the NRC policy of evaluating the latest versions of national standards in terms of their suitability for endorsement by regulatory guides.
Thus, this guide would endorse IEEE 535-1986 without any exceptions, and conformance with the requirements of IEE 535-1986 would constitute an acceptable method of complying with the Commission's regulations. This guide should enhance the licensing process.
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l IMPACT This regulatory guide is consistent with current NRC practice. It applies to future nuclear power plants and has no backfit provisions. Thus, this regu-latory guide does not impose any new requirements or costs on current licensees
! or applicants. Use of the guide by current licensees or applicants is voluntary.
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(This posi, tion paper was developed by the NRC staff at the request of the Committee To Review Generic Requirements. It is reproduced with the draft guide for the information of the public and to request public comments.)
Regulatory Analysis for Proposed Guide on Qualification of Safety Related Lead-Storage Batteries
Background:
The Commission's regulations (10CFR Part 50) require that safety-related systems and components in nuclear power plants be designed to accommodate the effects of environmental conditions (i.e., remain functional durina and after postulated seismic and accident conditionsi and that design control measures, such as testing, be used to verify the adequacy of design. Section 50.44 to 10CFP Part 50 and Regulatory Guide 1.89 provide requirements and acceptable methods for the environmental qualification of electric equipment.
The environmental qualification of electric equipment in mild environments is not included within the scope of Section 50.44 However, qualification for the mild environment (and the harsh environment) is included in the scope of IEEE Std. 323-1974 which is endorsed by R.G. 1.80, but component specific guidance is not provided. During the development of Section 50.49, the Commission concluded that the quality and surveillance requirements applicable to electric equipment (10 CFR Part 50, Appendix B; R.G. 1.32 Revision 2) are generally sufficient to ensure adequate performance of safety related equipment located in mild environments.
During this rulemaking, the staff was directed to develop regulatory guides for specific electric equipment located in mild environments where additional guidance is needed.
Discussion:
Safety-related batteries are located in mild environments. Section 3.11 (Page 5) of the Standard Review Plan states the following regarding qualification for electric equipment in mild environment:
"The environmental qualification of all electrical and mechanical equipment located in the mild environment is acceptable if the following procedure is followed:
The documentation required to demonstate qualification of equipment in a mild environment are the " Design / Purchase" specifications. The specifications shall contain a description of the functional requirements for its specific environmental zone during nomal and abnonnal environmental conditions. A well supported maintenance / surveillance pronram in conjunction with a good preventive maintenance program will suffice to assure that equipment that meets the design / purchase specifica-tions is qualified for the designed life.
Furthermore the maintcaance/ surveillance program data and records shall be reviewed periodically (not more than 18 months) to ensure that the design qualified life has not suffered thennal and cyclic degradation resulting from the accumulated stresses triggered by the
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O abnormal environmental conditions and the normal wear due to its service condition. Engineering judgment shall be used to modify the replacement program and/or replace the equipment as deemed necessary."
Seismic qualification of safety-related batteries is covered by Regulatory Guide l
1.100 There is no regulatory guide (or regulatory document) that describes methods acceptable to the NRC staff for " pre-aging" prior to seismic qualifica-tion of safety-related batteries. However, Section 3.11 (page di of the Standard Review Plan, dated July 1981, states: "In addition, IEEE Standards 381, 535...
can be used for guidance purposes even though NRC has not formally endorsed these standards through the issuance of a Regulatory Guide."
The staff has accepted voluntary compliance with IEEE Std 535 (all versions) for meeting the Commission's regulations.
Present Licensing Status:
Seismic qualification of safety-related equipment, includino batteries, has been evaluated by NRR against Regulatory Guide 1.100 for the past several years. During seismic qualification reviews, the NRR staff has noted that some kind of pre-aging was done prior to seismic testing of batteries.
Staff now plans to endorse IEEE Std 535-1986 by a regulatory guide. No backfit is involved; only future plants (or operating plant licensees voluntarily committing to the RG) are affected. The IEEE Standard represents a national consensus on qualification methods to assure the reliability, availability and functionality of batteries used in nuclear power plants.
Although, strictly speaking, the RG does impose a new staff position on new plants, the position imposed essentially codifies existing good practices by the industry and is consistent with the more general guidance provided by the Standard Review Plan.
Analysis of Technical Sections of IEEE Std 535-1986
- 1. Section 5.0 of IEEE Std 535-1986 specified three methods of qualification:
5.1 Type testing 5.2 Operating experience 5.3 Analysis supported by test data, operating experience or physical laws of nature.
These methods, except for (5.3) which permits operating experience or laws of nature as supporting bases, are essentially identical to Section 50.49(f) for equipment located in harsh environments. They are currently acceptable methods of qualification and, as such, do not impose any new requirements.
2 Section 5.4 of IEEE Std 535-1986 describes several methods of extending
" qualified life." These methods are consistent with IEEE Std 323-1974, which is endorsed by RG 1.89.
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- 3. Section 6 of IEEE Std 535-1986 specifies the information which should be included in the test plan for qualification of the battery, e.g.,
installation details, preventive maintenance schedule, electrical data, and qualified life. This information is readily available from the licensee (s).
4 Section 7 of IEEE Std 535-1986 specifies requirements for the prototype testing of batteries. These are: (1) Test plan, (2) Test Sequence and (3)
Acceptance Criteria. These are the basic requirements for any successful test program for any equipment,
- 5. Section 8 of IEEE Std 535-1986 specifies prescriptive requirements for type tests and analysis procedures. These include accelerated aging procedure, capacity test and (ischarge test. These tests are described in IEEE Std 450, endorsed by R.G.1.129, and are routinely done in the field (although not for qualification purposes).
- 6. Section 8.3 of IEEE Std 535-1986 deals with seismic testing which is covered by R.G. 1.100. These are prescriptive requirements but do not go beyond the general requirements imposed by R.G.1.100
- 7. Section 9 of IEEE Std 535-1986 deals with documentation. These requirements are consistent with R.G.1.89 and Appendix B of 10 CFR Part
- 50, and, although somewhat more prescriptive, impose no requirements beyond those implicit in the Commission's regulations.
Impact:
Since IEEE Std 535 was first published in 1979, the pre-aoing prior to seismic testing was not done systematically and strictly in accordance with IEEE Std 535-1979 All three U.S. manufacturers, Exide, C&D and Gould, have since qualified their batteries in accordance with IEEE Std 535-1979 for use in nuclear power plants. The cost to each company of testing and pre-aging has ranged from $30,000 to $180,000 - depending upon the number of prototypes tested, when they were tested, and whether the batteries were aged naturally or artificially. There is no significant difference between the 1970 and 1986 versions of IEEE Std 535 in respect to the " pre-aging" part of the qualification testing.
Conclusion:
Based upon our in-depth review of IEEE Std 535-1986, we conclude that the qualification requirements described in the IEEE standard are based on current industry practices. Further, issuance of this Guide will not result in any immediate additional cost, since all U.S. manufacturers have already cualified their current battery designs.
O We further conclude the requirements of IEEE 535-1986 will satisfy the Commission's regulations with respect to the qualif.ication of safety-related batteries located in mild environments.
wwas Satish K. Aggarwal 3AN Program Manager Engineering Rranch, RES
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