ML20248E897

Responds to 890824 Request for Clarification Re Spec/ Qualification Requirements for Cable Assessory Equipment. Licensee Responsible for Demonstrating That Equipment Can Perform Required Function

ML20248E897
Person / Time
Issue date:	09/12/1989
From:	Murley T Office of Nuclear Reactor Regulation
To:	Kerstun Norman 3M FAR EAST, LTD.
Shared Package
ML20248E900	List: ML20248E897 ML20248E907
References
NUDOCS 8910060096
Download: ML20248E897 (6)

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UNITED STATES

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SEP 121999 Mr. Kendall Norman, CDT Federal Government Manager 3M Electrical Products Division

.1101. Fifteenth Street, N.W.

Washington, D.C.

20005

Dear Mr. Norman:

In your letter to NRC Chairman Kenneth Carr, dated August 24, 1989, you asked what specification / qualification requirements your cable accessory equipment must meet.

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Environmental equipment qualification requirements are a function of the anticipated accident (harsh) environment in which the equipment must function.

Consequently, the qualification requirements may be different for the same equipment used in different locations within a nuclear power plant or in similar locations at a different plant. Generally, the anticipated accident environment inside a reactor containment building is more severe than the anticipated environment outside the containment building. Thert. fore, the requirements for equipment used inside containment are, in general, more restrictive.

The type of equipment that must be environmentally qualified is discussed in 10 CFR 50.49(b), the qualification requirements are discussed in 10 CFR 50.49(d)..and acceptable quMification methods are discussed in 10 CFR 50.49(f) (see enclosure).

After. equipment has been determined to be acceptable for use in a plant, the-applicant or licensee is responsible for demonstrating by one of the methods in 10 CFR 50.49(f) that the equipment can perform its required function for as long as that function is required. This responsibility includes definition of the anticipated accident environment and qualification of equipment (including installation, testing, and maintenance aspects) to assure equipment operability during anticipated accidents.

The NRC is responsible for ensuring that applicants and licensees comply with the Commission's regulations in Title 10, Chapter I, of the Code of Federal Regulations, specifically, in this case, with 10 CFR 50.49.

When the NRC staff _ inspects and reviews environmental qualification packages for equipment, questions may arise concerning their qualification. Sometimes the test results for a piece of equipment do nct appear to demonstrate that I

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it can function, or function for the required period in certain anticipated environments. Therefore, the staff may conclude from these questions and qualified for the particular application..

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further investigation that a piece of equipment is not environmentally

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l... t Mr. Kenda11' Norman,

I hope that this information. answers your question about qualification of your products for use in nuclear power plants.

Sincerely, Original uigned by.

Thomas E. Marley.

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Thomas E. Murley, Director L

Office of Nuclear Reactor Regulation

Enclosure:

Copy of 10'CFR 50.49 i

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50.48(d)PART 90 e DOMESTIC UCENSING OF PRODUCTION AND UTILIZATION FACILITIES established for the most severe design (3) Certain post-accident monitoring besis accident during or following which (3) Those fire protection features, equipment.

this equipment is required to remain including alternative shutdown caps-(c) Requirements for (i) dynamic and functional.

i bility, involving installation of modi!!-

seismic qualification of electric (2) Humidity. Humidity during design cations requiring plant shutdown shall equipment important to safety (2) basis accidents must be considered.

be implemented before the startup after the earliest of the iollowing protection of electric equipment (3) Chemical Effects. He composition eventa commencing 9 months or more important to safety against other natural of chemicals used must be at lesst as after the date of the NRC staff Fire : phenomena and externalevents,and severe as that resulting from the most i

Prrer? tion Safety Dialuation Report (3)environmentalquahfication of limiting mode of plant operation (e4 acceming or requiring such features:

e electric equipment important to safety cwa nment spray, emugency com (1) The first refueling outage; ld environment are not 8 ' "#I#

i (1D Another planned outage that locatedin a miincluded within the scope of this section.

contain' ment sump). If the composition lasts for at least 60 days; or A mild envir nment is an environment of the chemical spray can be affected by E (111) An unplanned outage that lasta that would at no time be significant y egulpment malfunctions, the most I for at least 120 days.

more severe than the environment that severe chemical sprs environment that (4) Those fire protection features in, would occur during normal plant results from a single ure in the spray n volving dedicated shutdown capabnity operation, including anticipated system must be assumed.

S requiring new buildings and systems shall be implemented within 30 operst>onal occurrences.

pdiction.%e radiation environment must be based on the type months of NRC approval. Other modl-fications requiring NRC approval prior (d)Tne oppbcant or hcer.see shall of radiation, the total dose expected to installation shall be implemented prepare a hst of electric ecuspment during normal operation over the within 6 months after NRC approval.

Important to sefety covered by this installed life of the equipment, and the (e) Nuclear power planta licensed to section. In addition. tne appbcan' or radiation environment associated with 8

bcensee shallinclude the inf ormation m the most severe design basis accident which the equipment paragraphs (d)t11. (21. and 13) of th18 during or followmg%nctional, com lete al i pr ectio tions needed to satisiy Criterion a of section for this electric equmment is requitto to remt Appendix A to this part in accordance

• o, important to saierv tr. a quahfication induding thr adiation rtsulting from with the provisions of their licensea.

file.The apphcant or heensee shall keep recirculating "he recircu*ating lines and luids for equipmeat e the het and information in the file

located near t A current and retain the file in auditable including dose-rate effects.

l 60.at Environmental cuencetion of

• form for the entire period dunns which g (5) Asir g. Equipment ualified by test tiectric equipment important to safety for the covered item is installed in tne

= must be preconditioned y natural or potear pow P4mnsa, nuclear power plant or is stored for artificial (accelerated) aging to its end-(e)Each holder of or each applicant future use to permit venfication that of. installed life condition. Consideration for a license to operate a nuclear power each item of electric equipment is must be given to all significant types of plant shall establish a program for important to safetv sneets the degradation which can have an effect on ualifying the electric eq ment requirements of pitragraph (j) of this the functional capability of the dsdoning to an end-efined in paragraph (b) o this section.

section.

equipment.lf btion is not (b) Electric e uipment important to of-installed (1)The performance specifications practicable. the equipment may be safety covered y this sectionis:

[ reconditioned to a shorter designated (2) Safety-related electric equipment:'

under conditions existing dunns and This equipment is that relied upon to following design basis accidents.

remain functional during and following (2) The voltage. frequency. load, and refurbished at the end of this designated design basis events to ensure (1) the other electrical characteristics for which life unless ongoing qualification integrity of the reactor coolant pressure the performance specified in accordance demonstrates that the item has i

boundary, (11) the capability to shut with parsgraph (d)(1) of this section can additionallife.

down the reactor and maintainitin a be ensured.

(6) Submergence (if subject to being safe shutdown condition, and (111) the 4 (3) The environmental condition' submerged).

O capability to prevent or Initigste the

including temperature. pressure.

(7) Synergistic Effects. Synergistic a humidity, ra diation, chemicals, and effects must be considered when these g consequences of accidents that could g submergence at the location where the effects are beheved to have a significant

. result in olential offsite exposures

• compara le to the 10 CFR Part 100

= equipment must perform as specified in effect on equipment performance.

guidehnen. Design basis events are accordance with paragraphs (d)(1) and (8) Aforgins. Margins must be applied defined as conditions of normal (2)of this rection.

to account for unquantified uncertainty, operation, including anticipated (e) The electric equipment such as the effects of production operational occurrences. design basis qualification am must include and variations and inaccuracies in test accidents, external eventa. and natural be based on e flowir@

instruments.These margins are in phenomena for which the plant must be (1) Temperature oncf Pressure.The addition to any conservatism applied designed to ensure functions (1) through time-dependent temperature and during the derivation oflocal (111)of this paragr h,

pressure at the locatkr. v the electric environmental conditions of the (2) Nonsafety-ted electric equipment important - sfety mustbe equi ment unless these conservatism quantified and shown to contain equipment whose failure under

• Specific guidance uncermeg the types of appropriate margina.

can postulated environmental conditions vanables to be monitored is provided in could prevent satisfacto accomplishment of safety functions evjsgn2 fkes at tfcooled importan fety in be q ah by u

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specified in sub aragraphs (i) through nucles, power plants to Assess piant and one of the following methods:

(iii)of paragrep )(1) of this section by Environs conditions Dunna and Followmg an (1) Testing anidentical item of Accident.

equipment under identical conditions or

" Copies of the Regulatory Guideh'yh 'h' h a under similar conditions with a the safety-related equipment.

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by supporting analysis to show that the

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se cm. e e.,,p, n i w22 w.ea cooise WMO m h Wmg to Se M equipment to be quahlied is scCeptable.

of this standadi misy tuo etnained frse t!.e lastitute Government Printma Office. P.O. Box 37o82.

(2)Testm' g s similar item of equipment of Cectrical and D.ctrorucs Enstneers, lac. ses Weshmston, DC 200u-7082.

s sicm stro.i.No. yort wv sunr.

50 29 November 30,1988

5034(a) 50.49(fp PART 50 o DOMESTIC UCENSING OF PRODUCTION AND UTILIZATION FACILITIES (2) The validity of partial test data in "i 50.51 Duration at scenu, renewet with a supporting analysis to show that support of the original qualification.

Each license will be issued for a fixed f

the equipment to be quahfied is (3) Limited use cf c"strative period of time to be specified in the acceptable.

controls over equipment that has not license but in no case to exceed 40 years (3) Experience with identical or been demonstrated to be fully qualified.

from the # ate of inuance. Where the similar equipment under similar (4) Completion of the safety function operation of a facil ty is involved the

conditions with a supporting analysis to prior to exposure to the accident.

Commission will tesue the license for a show that the equipment to be qualified environment resulting from a design the term requested by the apphcant or 6

0 is acceptable.

basis event and ensuring that the

= for the estimated usefullife of the E acility if the Commission determines (4) Analysis in combination with subsequent failure of the equipment f

A that the estimated useful hfe is less than partial type test data that supports the does not degrade any safety function or analytical assumptions and conclusions.

mislead the operator.

E the term requested.Where construction 1 fg) Each holder of an operating license (5) No sigmficant degradation of any q of a facihty is involved. the Commission issued prior to February 22.1983, shall, safety function or misleading may specify in the construction permit by May 20.1983 identify the electric information to the operator as a result of the period for which the license will be (quipment important to safety within failure of equipment under the accident issued if approved pursuant to I 50.58.

the scope of this section already environment resulting from a design Licenses may be renewed by the quahfied and submit a schedule for basis event.

Commission upon the expiration of the either the qualification to the provisions (J) A record of the qualification, period. Application for termination of cf this section or for the replacement of

, includ ng documentationin paragraph heense is to be made pursuant to the remaining electric equipment 0 (d) of this section. must be maintained in

-1 50.82.

important to safety within the scope of E an nuore.bie ferm for the entire ptriod during Mich the covered iterr is f 8 50.52 Combining licenses.

6 this section.This schedule must The Commission may combine in a Establish a goal of final environmental installed m the nuclear power %t or is a

quahfication of the electric equipment stared for future use to permit f single license the activities of an appli-within the scope of this section by the verification that each item of electric 5 cant which would otherwise be 11-

-. cnd of the second refuehng outage after equipment important to safety covered b, censed severally.

3 March 31.1982 or by March 31.1985, by this section-E whicheveris earlier.ne Director of the (1)Is quahfied for its application: and : I 50.53 Jurisdictional timttations.

4 No license under this part shall be

" Office of Nuclear Reactor Regulation (2) Meets its specified performance may grant requests for extensions of this requirements when it is subjected to the g deemed to have been issued for activi-p' deadline to a date no later than conditions predicted to be present when., ties which are not under or within the November 30.1985. for specific pieces of it must perform its safety function up to jurisdiction of the United States.

squipment if these requests are filed on the end of its quahfied hfe.

yf 50.54 Conditions of licenm.

e timely basis and demonstrate good (k) Appheants for and holders of Wh her at ted t er or not,the A

cause for the extension, such as operating licenses are not required to g g

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procurement lead time. test requalify electric equipment irrportant

g. n nery heme isswd complications. and installation to safety in accordance with the

'" (a)(1) Each nuclear power plant or fuel problems In exceptional cases, the provisions of this section if the Commission itself may consider and Commission has previously required reprocessing plant licensee subject to grant extensions beyond November 30.

qualification of that equipment in the quality assurance criteria in 1985. for completion of environmental accordance with "Guidehnes for" Appendix B of this shallimplement, qualification.

Evaluating Environmental Qualification pursuant to i 50.

)(6)(11) of this part, The schedule in this paragraph of Class 1E Electrical Equipment in the quality assurance program described supersedes the lune 30.1982, deadhne.

Operating Reactors." November 1979 or teferenced in the Safety Analysis er any other pr4 vlously imposed date.

fDOR Guidelines). or NUREG-ossa (For Report. including changes to that repoet.

for environmental quahfication of Comment versio.n). " Interim StaN (2) Each licensee described is slectric equipment containe<l in certain Position on Environmental Quali!! cation paragraph (a)(1) of this section sha!!, by nuclear power operating licenses.

of Safety.Related Electrical Equipment" June 10.1983, submit to the appropriate (1) Replacement equipment must be NRC Regional Osce shownin

[ Corrmn.sion as specified in i 50 4 of any qualified in accordance with the Appendix D of Part 20 of this chapter the (b) Each license shall notify the g

provisions of this section unless there current description of the quahty g sp.faant equipment quahfication are sound reasons to the contrary.

assurance program it la implementing CoNDI. 2 for inclusion in the Safety Analysis a prcblem that r.ay reqmre extensien of IssvANet.

a Report, urdess there are no changes to

', the completion date provided in Lu TAT!oNs. AND the description previcuoly accepted by e accordance with parapreph (gl of this T1oNs oF LICENSES AND CONSTRUCTION 6 Pcautts

NRC.This submittalinualidentify

{section within 00 days of its dncosery.

changes made to the quality assurance S f 50.50 lesuance of licenses and construe.

i program description since the

[i) Appl: cants for operating licenses E

tion permits.

description was submitted to NRC.

granted after February 22.1083. but prior a

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" th ti[nbra"ee ar d (Should a licensee need additional time to Noymber 30.1985. shall perform an e eets t e t beyond lune 10.1983 to submitits f

o analys:s to ensure that the phnt can be and requirements of the act and regu.

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safely operated pending cornpletion of lations, and that notifications, if any, current quality assurance program description to NRC it shall notify the a equipment qual

fication required by this to other agencies or bodies have been

'section.This analysis must be duly made, the Commission will issue approptiste NRC Regianal OfBee in i

E sub'nttted, e4 specified in i 50 4. for a license. or if appropriate a construc-writing, explain why additional tim is consideration p-ior to the granting of an tion permit in such form and contain-needed, and provide e schedule for hRC operating lic ense and must include.

Ing such conditions and limitations in.

approval showing when its cunnt

-v.here appro; iate, consideration of.

cluding technical specifications. as it quality assurance program descrtPtic n deems appropriate and necessary.

will be submitsed.)

(1) Accomplishing the safety function

[ [3] Af cr March 11.1983 eachli:ensee

{by some designated attemative 2 described in paragraph (a)(1) of this h

p, equipment if the principal equipment 0 section mey rneke e charge to a a

ha bcen demonstrated to be fully p iody accepted quahty assurance e

November 30,1988 50 30

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DUE: 09/12/89 EDO CONTROL: 0004714 j

T-DOC DT: 08/24/89

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-FINAL REPLY:

p lKanda11fNorman

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3M Electrical Products < Division l

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Chairman

.FOR.SIONATURE OF

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CRC ND: '89-07.77

,Murley.

i ROUTING:-

DESC:

-lj SPECIFICATION AND-QUALIFICATION OF CABLE

ACCESSORY PRODUCTS USED ON NUCLEAR POWER PLANT.

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SITES ~

-DATE: 68/29/89 e.

ASSIGNEDiTO.:

CONTACT:

NRR Murley SPECIAL INSTRUCTIONS OR REMARKS:

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'NRR RECEIVED: AUGUST 29, 1989 ACTION:

DSTY:THADANI?S g

lNRR' ROUTINGS MURLEY/SNIEZEK.

MIRAGLIA' PARTLOW CRUTCHFIELD L

GILCESPIE l~

MOSSBURG i

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, 9 OFFICE OF THE SECRETARY

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. CORRESPONDENCE CONTROL TICKET i

PAPER NUMBER:

CRC-89-0777 LOGGING DATE: 'Aug 28 89

. ACTION OFFICE:

EDO AUTHOR:

Kendall Norman AFFILIATION:

DC (DISTRICT OF COLUMBIA)

LETTER DATE:

Aug 24 89 FILE CODE:

SUBJECT:

Specification and qualification of cable accessory products used on nuclear power plant sites ACTION:

Direct Reply DISTRIBUTION:

SPECIAL HANDLING: None NOTES:

DATE DUE:

Sep 12 89 SIGNATURE:

DATE SIGNED:

AFFILIATIOli:

Rec' doll.EDO Dete-.

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