ML24221A201

VIP-012 Environmental Qualification Final

ML24221A201
Person / Time
Issue date:	08/26/2024
From:	Odunayo Ayegbusi NRC/NRR/DRO/IQVB
To:
References
VIP-012, Rev. 2
Download: ML24221A201 (1)

Text

Desktop Guide No.

VIP-012 Revision 2 Title Environmental Qualification Desktop Guide Revision Editor Odunayo Ayegbusi - NRR/DRO/IQVB Affected Branches IQVB Branch Chief Kerri Kavanagh Date August 22, 2024 PURPOSE This desktop guide (DTG) provides environmental qualification (EQ) guidance for vendor inspectors. This DTG provides guidance on inspecting to Appendix B to 10 CFR Part 50 for a specific type of vendor inspection performed under IMC 2507. The overall objectives of this DTG are as follows:

To provide examples of overall test control associated with EQ.

To further assist in the identification of references for these test control processes.

To provide a starting point for the vendor inspector when assigned EQ vendor inspections.

Revision 1 of this DTG addresses organizational changes and incorporates Revision 2 of Regulatory Guide (RG) 1.180, Guidelines for Evaluating Electromagnetic and Radio-Frequency Interference in Safety-Related Instrumentation and Control Systems.

Revision 2 of this DTG incorporates information related to RG 1.89, Environmental Qualification of Certain Electric Equipment Important to Safety for Nuclear Power Plants, Revision 2, and Inspection Procedure (IP) 71111.21 Attachment N (IP 71111.21N), Design Bases Assurance inspection (Programs), February 2019 (Agencywide Documents Access and Management System (ADAMS) No. ML19036A556). In addition, significant changes were made to the document file format, formatting and content, such that the red line strike out approach would have made the document unreadable.

APPLICABLE REGULATIONS AND GUIDANCE REGULATIONS 10 CFR Part 50 requires, among other things, that structures, systems, and components (SSCs) that are important to safety in a nuclear power plant must be designed to accommodate the effects of environmental conditions (i.e., remain functional under postulated design-basis events).

o 10 CFR 50.49, Environmental qualification of electric equipment important to safety for nuclear power plants, requires that holders or applicants for an operating license for a nuclear power plant issued under Part 50 shall establish a program for the EQ of electric equipment as defined in 10 CFR 50.49. 10 CFR 50.49 also requires that holders of a combined license or a manufacturing license issued

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VIP-012 Revision 2 Title Environmental Qualification Desktop Guide under Part 52 shall establish a program for the EQ of electric equipment as defined in 10 CFR 50.49.

o 10 CFR 50.55a(h), Protection and safety systems, states that protection systems must meet the requirements of the IEEE Std. 603-1991, Criteria for Safety Systems for Nuclear Power Generating Stations (Ref. 4), or IEEE Std. 279-1971, Criteria for Protection Systems for Nuclear Power Generating Stations (Ref. 5),

contingent on the date of construction permit issuance. The design-basis criteria identified in those standards or, for plants with construction permits issued before January 1, 1971, the criteria identified in the licensing basis for such facilities, include the range of transient and steady state environmental conditions during normal, abnormal, and accident conditions during which the equipment must perform its safety functions.

o General Design Criterion (GDC) 4, Environmental and dynamic effects design bases, of Appendix A, General Design Criteria for Nuclear Power Plants, to 10 CFR Part 50, states, in part, that SSCs important to safety shall be designed to accommodate the effects of and to be compatible with the environmental conditions associated with normal operation, maintenance, testing, and postulated accidents, including loss-of-coolant accidents.

o General requirements associated with equipment qualification appear in GDC 1, Quality Standards and Records, GDC 2, Design Bases for Protection Against Natural Phenomena, and GDC 23, Protection System Failure Modes, of Appendix A to 10 CFR Part 50.

o 10 CFR Part 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, requires, in part, that the pertinent requirements of this appendix apply to all activities affecting the safety-related functions of the structures, systems, and components that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public. These activities include designing, purchasing, fabricating, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, and modifying.

10 CFR Part 52 requires that SSCs important to safety in a nuclear power plant be designed to accommodate the effects of environmental conditions.

o 10 CFR 52.47(a)(13) requires that an applicant for a certified design must provide the list of electrical equipment important to safety as required by 10 CFR 50.49(d).

o 10 CFR 52.79(a)(10) requires that an application for a combined license must provide a description of the program, and its implementation, of an EQ program for electrical equipment per 10 CFR 50.49(a). The applicant must also provide the list of electric equipment that is important to safety as required by 10 CFR 50.49(d).

o 10 CFR 52.97(b) requires that combined licenses must contain ITAAC that are necessary and sufficient to provide reasonable assurance that the facility has been constructed and will be operated in accordance with the license; the Atomic Energy Act of 1954, as amended; and NRC rules and regulations.

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10 CFR 52.99(c)(1) requires that each combined license holder notify the NRC that the prescribed inspections, tests, and analyses have been performed and that the prescribed acceptance criteria are met for each ITAAC included in their combined license.

o 10 CFR 52.137(a)(13) requires that an applicant for a standard design approval must provide the list of electric equipment that is important to safety as required by 10 CFR 50.49(d).

o 10 CFR 52.157(f)(6) requires that an applicant for a manufacturing license provide a list of electric equipment important to safety that is required by 10 CFR 50.49(d).

REGULATORY GUIDANCE NUREG-0800, Section 3.11, Environmental Qualification of Mechanical and Electrical Equipment, identifies staff guidance for determining that all items of equipment that are important to safety (mechanical, electrical, and instrumentation and control (I&C) equipment) can perform their design safety functions under all normal environmental conditions, anticipated operational occurrences, and accident and post-accident environmental conditions. It includes all environmental conditions that may result from any normal mode of plant operation, anticipated operational occurrences, design-basis events (as defined in 10 CFR 50.49(b)(1)(ii)), post-design-basis events, and containment tests.

Prior to the 1983 issuance of the 10 CFR 50.49 final rule, the Commission (in Petition for Emergency and Remedial Action, CLI-80-21, 11 NRC 707 (1980)) directed the staff to use NUREG-0588, Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment, Revision 1, and the Division of Operating Reactors (DOR)

Guidelines, Guidelines for Evaluating Qualification of Class 1E Electrical Equipment in Operating Reactors, November 3, 1979, as requirements that licensees and applicants must meet in order to satisfy the equipment qualification requirements of 10 CFR Part 50.

At that time, NUREG-0588 consisted of what is now Part I of NUREG-0588 (i.e., only the for comment version of NUREG-0588).

Upon its issuance, 10 CFR 50.49, which is based on Part I of NUREG-0588 (hereinafter NUREG-0588) and the DOR Guidelines, did not require requalification of electric equipment by applicants for and holders of operating licenses for nuclear power plants previously required by the NRC to qualify equipment in accordance with the DOR Guidelines or NUREG-0588 (Category I or II).

According to NUREG-0588, all nuclear reactors with operating licenses as of May 23, 1980, would be evaluated by the staff against the DOR Guidelines. As the Commission stated in the 10 CFR 50.49 final rule preamble, Category I requirements of NUREG-0588, which supplement the recommendations of and apply to equipment qualified in accordance with IEEE Std. 323-1974, IEEE Standard for Qualifying Class IE Equipment for Nuclear Power Generating Stations, apply to nuclear power plants for which the construction permit safety evaluation report was issued after July 1, 1974. Category II requirements, which supplement the recommendations of and apply to equipment qualified in accordance with IEEE Std. 323-1971, IEEE Trial-Use Standard: General Guide for Qualifying Class I Electric Equipment for Nuclear Power Generating Stations, apply to

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VIP-012 Revision 2 Title Environmental Qualification Desktop Guide nuclear power plants for which the construction permit safety evaluation report was issued prior to July 1, 1974 (Category I is essentially equivalent to the guidance in RG 1.89 Revision 1). For plants whose safety evaluation reports for construction permits were issued since July 1, 1974, the NRC has used RG 1.89.

RG 1.97, Criteria for Accident Monitoring Instrumentation for Nuclear Power Plants, describes a method that is acceptable to the staff of the NRC for use in complying with the regulatory requirements with respect to satisfying criteria for accident monitoring instrumentation in nuclear power plants.

RG 1.183, Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors, provides guidance to licensees of operating power reactors on acceptable applications of alternative source terms (ASTs); the scope, nature, and documentation of associated analyses and evaluations; consideration of impacts on analyzed risk; and content of submittals related to the use of ASTs in radiological consequence analyses at operating power reactors. RG 1.183 can be used in radiological accident analysis and provides acceptable accident source term methodologies that may be used for EQ, as applicable. Therefore, for those applicants and licensees that RG 1.183 is applicable, RG 1.183 is referenced in this guide to describe acceptable source term methodologies to be used for EQ. However, RG 1.183 is not the only approved methodology for accident source terms and additional source term methodologies may be approved in the future. While other accident source term methodologies are not specifically referenced in this guide, approved accident source term methodologies for EQ may continue to be used (if they remain applicable) and new methodologies may be considered by the staff. The source term methodologies used must be applicable to the specific applicant or licensee and adequate to address EQ requirements.

RG 1.215, Guidance for ITAAC Closure Under 10 CFR Part 52, describes a method for documenting the completion of inspections, tests, analyses, and acceptance criteria.

The following documents facilitate qualification under other requirements, include additional information for qualifying specific equipment, or provide an additional level of detail for qualifying equipment.

RG 1.209, Guidelines for Environmental Qualification of Safety-Related Computer-Based Instrumentation and Control Systems in Nuclear Power Plants, describes a method that the NRC staff considers acceptable for determining the EQ procedures for safety-related computer-based I&C systems for service within nuclear power plants. This regulatory guide addresses in part acceptable ways to address environmental qualification requirements covered within 10 CFR 50.49 and in part other environmental stressors (e.g.,

smoke, and electromagnetic phenomena) that are not covered under 10 CFR 50.49.

RG 1.40, Qualification of Continuous Duty Safety-Related Motors for Nuclear Power Plants, endorses IEEE 334-2006, Qualifying Continuous Duty Class 1E Motors for Nuclear Power Generating Stations, and describes a method that the staff of the NRC considers acceptable to implement regulatory requirements for the qualification of continuous duty safety-related motors for nuclear power plants.

RG 1.63, Electric Penetration Assemblies in Containment Structures for Nuclear Power Plants, describes a method acceptable to the NRC staff for complying with the regulatory

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VIP-012 Revision 2 Title Environmental Qualification Desktop Guide requirements for the design, construction, testing, qualification, installation, and external circuit protection of electric penetration assemblies in containment structures of nuclear power plants.

RG 1.73, Qualification Tests for Safety-Related Actuators in Nuclear Power Plants, describes methods that the staff considers acceptable for the environmental qualification of safety-related power-operated valve actuators in nuclear power plants.

RG 1.100, Seismic Qualification of Electric and Active Mechanical Equipment and Functional Qualification of Active Mechanical Equipment for Nuclear Power Plants, describes methods that the staff of the NRC considers acceptable for use in the seismic qualification of electrical and active mechanical equipment and the functional qualification of active mechanical equipment for nuclear power plants.

RG 1.152, Criteria for Use of Computers in Safety Systems of Nuclear Power Plants, endorses IEEE Std. 7-4.3.2-2003, Standard Criteria for Digital Computers in Safety Systems of Nuclear Power Generating Stations, with exceptions and clarifications. IEEE Standard 7-4.3.2 contains criteria acceptable to the staff for addressing environmental design and qualification of computer-specific and programmable digital device-specific requirements and should be used in conjunction with NUREG-0588 and Regulatory Guide 1.89, as appropriate, for evaluating computer-specific requirements.

RG 1.153, Criteria for Safety Systems, describes a method acceptable to the NRC staff for complying with the regulatory requirements for the design, reliability, qualification, and testability of the power, instrumentation, and control portions of safety systems of nuclear plants.

RG 1.156, Qualification of Connection Assemblies for Nuclear Power Plants, describes a method that the staff of the NRC considers acceptable for complying with the regulatory requirements for the EQ of connection assemblies and environmental seals in combination with cables or wires as assemblies for service in nuclear power plants. The EQ helps ensure that connection assemblies can perform their safety functions during and after a design-basis event.

RG 1.158, Qualification of Safety-Related Lead Storage Batteries for Nuclear Power Plants, describes methods and procedures the staff of the NRC considers acceptable for use in complying with the regulatory requirements for the qualification method of safety-related lead-acid storage batteries for nuclear power plants.

RG 1.180, Guidelines for Evaluating Electromagnetic and Radio-frequency Interference in Safety-related Instrumentation and Control Systems, describes methods and procedures that the staff of the NRC considers acceptable for demonstrating compliance with the regulatory requirements for design, installation, and testing to address the effects of electromagnetic and radio-frequency interference (EMI/RFI), power surges, and electrostatic discharge on safety-related instrumentation and control (I&C) systems.

RG 1.210, Qualification of Safety-Related Battery Chargers and Inverters for Nuclear Power Plants, describes a method that the staff of the NRC considers acceptable in complying with the regulatory requirements for the qualification of safety-related battery chargers and inverters for nuclear power plants.

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VIP-012 Revision 2 Title Environmental Qualification Desktop Guide RG 1.211, Qualification of Safety-Related Cables and Field Splices for Nuclear Power Plants, describes a method that the staff of the NRC considers acceptable for complying with the regulatory requirements for the qualification of safety-related cables and field splices for nuclear power plants.

RG 1.213, Qualification of Safety-Related Motor Control Centers for Nuclear Power Plants, describes a method that the staff of the NRC deems acceptable for complying with the regulatory requirements for qualification of safety-related motor control centers for nuclear power plants.

GUIDANCE EQ is a subset of equipment qualification that must account for the following design basis parameters: temperature, pressure, humidity, chemical effects, radiation, aging, submergence, activation energy and synergistic effects and must apply appropriate margins to account for un-quantified uncertainty. The design specification should specify to which standard the equipment is being qualified to and address equipment mounting details, interface connections, age conditioning procedure, service conditions, margins, and acceptance criteria.

Review the materials that are sensitive to environmental effects (e.g., seals, gaskets, lubricants, hydraulic fluids, insulators, isolators, and diaphragms). Electrical equipment and their associated mechanical components will experience environmental conditions as defined in 10 CFR 50.49(e).

These conditions will be used in reviewing the EQ of equipment. See NRC Standard Review Plan (SRP) Section 3.11, Environmental Qualification of Mechanical and Electrical Equipment, for additional guidance.

Specific Guidance This section of the EQ desktop guide discusses the following:

Primary references/IP to be used for EQ Document examples Physical parameters Types of EQ testing with recommended evaluation techniques Primary

References:

The primary reference documents for EQ are described in Attachment 1 of this document. The steps to perform for design certification testing are delineated in IP 35034, Design Certification Testing Inspection. A vendor inspector may reference IP 51080, Part 52, Environmental Qualification (EQ) Program for Electrical and Mechanical Equipment, as referenced in Table 1 for guidelines; however, IP 51080 is written with respect to Licensee EQ and therefore the Vendor Inspector must use judgment to determine the applicable components, perspectives, and parts of the IP to apply. A vendor inspector may also reference IP71111.21N as referenced in Table 1 for guidelines; however, IP 71111.21N is written with respect to Licensee EQ and therefore the Vendor Inspector must use judgment to determine the applicable components, perspectives, and parts of the IP to apply.

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VIP-012 Revision 2 Title Environmental Qualification Desktop Guide Table 1: Primary Inspection Procedures Inspection Procedure Description IP 35034: Design Certification Testing Inspection This IP should be consulted for an overview of the general requirements for EQ Testing. The procedure lays out specific steps that should be reviewed within the scope of test plan and procedures, configuration management, test results and data reduction, control of measuring and test equipment (M&TE), QA records, and personnel qualification.

IP 51080: Part 52, Environmental Qualification (EQ) Program for Electrical and Mechanical Equipment This IP provides further guidance with respect to licensee EQ. It directs verification that the qualification of systems, structures, and components (SSCs) is done in accordance with appropriate design specifications and that it meets the acceptance criteria. Information within the IP can be scoped for use in vendor inspections.

IP 71111.21N, Design Bases Assurance Inspection (Programs)

This IP provides further guidance with respect to selected topics regarding the environmental qualification process. It provides guidance on the use of the Arrhenius methodology for estimating accelerated aging, validation of information in EQ reports (e.g., activation energy), and replacement EQ equipment and upgrade Requirements.

Information within the IP can be scoped for use in vendor inspections.

Document Examples:

To evaluate the EQ program, the following list of documents is an example of documents to review when determining a vendors EQ effectiveness:

Safety analysis reports

EQ test reports

EQ requirements

Equipment specifications/datasheets

Detailed equipment parts lists

Procurement documents

Installation documents

Shipping Documents/Receipts

Maintenance requirements and history records

Peer review and audit reports

Calculations and measurements of environmental conditions (for design basis events (DBEs) as well as for normal operation)

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List of limited life items and replacement intervals

Maintenance requirements and intervals

Qualification test plan and test data

Operational performance requirements

Initial event and normal operation service conditions

Calculations and analyses (seismic stress evaluation, qualified life, etc.)

Storage requirements

Walkdown verification checklists Types of EQ Testing:

10 CFR Part 50.49(e) states, in part, that the electric equipment qualification program must include and be based on the following temperature and pressurehumiditychemical effectsradiationaging submergence (if subject to being submerged), synergistic effectsmargins. 10 CFR 50.49(f) states that [e]ach item of electric equipment important to safety 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.

(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.

(4)

Analysis in combination with partial type test data that supports the analytical assumptions and conclusions.

The following list discusses suggested documents to review, processes to observe and references to use. This information is a starting point for a vendor inspector and is not all encompassing. This should be used as a point of departure to aid the vendor inspector in developing a personal inspection plan.

1.

Harsh Environment: EQ is required for all electrical equipment that is important to safety that could be exposed to harsh accident conditions (i.e., conditions that are substantially different from those occurring during normal operation and anticipated operational occurrences) and needed to mitigate the accident producing the harsh conditions.

Generally, these accidents are limited to LOCA and HELB type accidents. Equipment is generally protected from, rather than qualified to, the flooding effects of moderate energy line breaks, jet impingement and whipping effects of HELBs and the damaging effects of fires.

References:

RG 1.89 a.

Areas to consider when evaluating EQ Harsh Environment:

i.

Within these systems, the actuated devices (motors) and sensors with required functions are tabulated along with their functions and the required duration of equipment operation.

ii.

Mechanical and electrical drawings are reviewed to identify support features (e.g., electric power distribution equipment, diesel generators, component cooling water) and equipment required by these systems and equipment.

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VIP-012 Revision 2 Title Environmental Qualification Desktop Guide iii.

Electrical circuit diagrams are reviewed to identify other electrical devices, located in the harsh environment, with necessary active or passive functions. Such devices may include cables, connectors, relays, and containment electrical penetrations.

iv.

Equipment specifications and procurement documents are reviewed to identify the manufacturer, model, and other identification information for the selected equipment.

2.

Type testing: Qualification by type testing is the preferred method of qualification and refers to a series of tests subjecting equipment test samples to limiting environmental and operational conditions, with appropriate margin, while required performance is verified.

a.

Documents: A formal test plan is required that addresses the description of the equipment being tested, the mounting and connection requirements, the service conditions to be simulated, the procedure for simulating the aging of the component, the performance, and environmental variables to be measured, requirements of the test equipment, test specimen failure descriptions and documentation requirements.

b.

Other: Further information can be found in RG 1.89 for mounting, connections, monitoring, and margin relative to testing.

3.

Qualification Margin: The difference between the specified service conditions at installed equipment locations and the more severe conditions assumed when qualification is established. RG 1.89 provides further guidance on how and when to apply margin.

4.

Test Sequence:

Inspection of the equipment for defects Operation of the equipment under normal environmental conditions to baseline performance variables.

Operation of the equipment under normal environmental conditions at the extreme limits of the electrical characteristics.

The aging of the equipment including radiation dose if required.

Subjection of the aged equipment to whatever vibration tests required.

Operation of the aged equipment while the component is subjected to the simulated accident environment.

Operation of the equipment in a simulated post-accident environment.

Other: RG 1.89 provides further guidance on test sequence.

5.

Aging: Significant ageing mechanisms will vary according to device design and normal service conditions. The following service conditions are related to potentially significant aging mechanisms: temperature, thermal cycling, radiation, humidity, voltage, vibration, corrosion, erosion, operation (cyclical or continuous).

a.

Techniques to address significant aging mechanism when qualification is being established:

i.

Analyze aging significance as part of qualification evaluation, ii.

Simulate the aging degradation during qualification testing, iii.

Identify significant mechanisms not amenable to simulation, iv.

Identify periodic inspections and maintenance actions for mechanisms not amenable to simulation.

6.

Analysis: Qualification by analysis alone is not accepted. Qualification by analysis in

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VIP-012 Revision 2 Title Environmental Qualification Desktop Guide combination with partial type test data that supports the analytical assumptions and conclusions generally requires the construction of valid analytical models of the item to be qualified. The models must address the relevant characteristics, including materials and configuration, of the items being modeled and their known responses to service conditions and other influences. The validity of the model and its applicability to the equipment items must be justified by auditable data based on physical laws, tests or operating experience and documented. Vendors/Licensees can use the Arrhenius methodology to analyze new activation energy numbers without performing additional EQ testing when revising initial EQ results. Vendor inspectors should review documentation that justify:

a.

Where the activation energy number came from and a justification with verifiable test documentation for using that number e.g. because of initial qualification.

b.

How the new activation energy number compares to the initial testing numbers.

c.

The vendor has evaluated the failure modes that could impact the new activation energy number.

d.

Review other changes made to determine the EQ life of a component.

7.

Configuration Management:

a.

Installation details b.

Detailed layout and wiring diagrams c.

Parts list d.

Vendor drawings 8.

EMI/RFI:

a.

Documents: Review purchase orders (PO) to see what the licensee/customer requires. Examine test procedures and test reports to see if the guidelines in the guidance documents are met.

b.

Processes: Vendors and/or test facilities should be following the guidelines for test setup, antennae requirements, test parameters, distances, frequency sweeps, etc. all per the guidance required by the PO.

c.

References:

RG 1.180 and Electric Power Research Institute (EPRI) TR-102323 (different technical revisions are required/endorsed dependent on the revision of the guidance), MIL-STD-461E, IEC 61000 series. Example:

d.

Other: Test vendors may typically use more recent technical revisions if they are not certified to the older revisions. There are numerous parameters that have a less conservative range/testing requirement in the newer revisions than the ones referenced/endorsed in RG 1.180 and the EPRI guidance documents. If the vendor uses a newer technical revision, ensure that the actual test setup and parameters are bounded by the assumptions made in RG 1.180 and the EPRI guidance documents. If not, then the vendor or test facility needs to provide an evaluation that shows that differences are equal to or more conservative than the guidance documents.

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VIP-012 Revision 2 Title Environmental Qualification Desktop Guide Table 2. RG and EPRI revisions showing date of endorsed documents.

RG 1.180, Rev. 1 RG 1.180, Rev. 2 EPRI TR 102323 Rev. 2 EPRI TR 102323 Rev. 3 MIL-STD-461E MIL-STD-461G MIL-STD-461E MIL-STD-461E IEC 61000 2, 2001 IEC 61000 3, 2010 IEC 61000-3-2, 1995 IEC 61000-3-2, 1995 IEC 61000-3-4, 1998 IEC 61000-4-1, 1992 IEC 61000-4-2, 1995 IEC 61000-4-2, 2008 IEC 61000-4-2, 1999 IEC 61000-4-2, 1999 IEC 61000-4-3, 1995 IEC 61000-4-3, 2010 IEC 61000-4-3, 1998 IEC 61000-4-3, 1995 IEC 61000-4-4, 1995 IEC 61000-4-4, 2010 IEC 61000-4-4, 1995 IEC 61000-4-4, 1995 IEC 61000-4-5, 1995 IEC 61000-4-5, 2014 IEC 61000-4-5, 1995 IEC 61000-4-5, 1995 IEC 61000-4-6, 1996 IEC 61000-4-6, 2013 IEC 61000-4-6, 1996 IEC 61000-4-6, 1996 IEC 61000-4-7, 1991 IEC 61000-4-8, 1993 IEC 61000-4-8, 2009 IEC 61000-4-8, 1993 IEC 61000-4-9, 1993 IEC 61000-4-9, 2001 IEC 61000-4-9, 1993 IEC 61000-4-10, 1993 IEC 61000-4-10, 1993 IEC 61000-4-11, 1994 IEC 61000-4-12, 1996 IEC 61000-4-12, 2006 IEC 61000-4-12, 1993 IEC 61000-4-13, 1998 IEC 61000-4-13, 2015 IEC 61000-4-13, 2002 IEC 61000-4-16, 1998 IEC 61000-4-16, 2011 IEC 61000-4-16, 2002

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VIP-012 Revision 2 Title Environmental Qualification Desktop Guide IEC 61000-6-4, 1997 IEC 61000-6-4, 2006 ATTACHMENTS : References : Sample Questions : Issues to Review

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VIP-012 Revision 2 Title Environmental Qualification Desktop Guide ATTACHMENT 1 REFERENCE

SUMMARY

As defined by the 10 CFR 50.49 EQ rule, equipment important to safety includes one or more of the following three categories:

o Safety-related equipment required to remain functional during and following design basis events (DBEs) to ensure the performance of required safety functions.

o Non-safety-related equipment whose failure during postulated DBEs could prevent the accomplishment of safety functions.

o Post-accident monitoring instruments providing information on certain key variables.1 DOR Guidelines As part of the process for resolving environmental qualification concerns raised by the Union of Concerned Scientists (UCS) petition, the NRC issued IE Bulletin 79-01B on June 8, 1979. of this bulletin was the Guidelines for Evaluating Environmental Qualification of Class 1 E Electrical Equipment in Operating Reactors, commonly referred to as the DOR Guidelines.

The DOR Guidelines were originally intended for use by the NRC to evaluate the qualification of existing equipment in reactors operating prior to May 23, 1980. However, the DOR Guidelines soon became the qualification criteria document applicable to these facilities. The guidelines were based in part on IEEE Std. 323-1971 and 323-1974 and the For Comment version of NUREG-0588, which was previously issued to address qualification in plants licensed after May 1980. The contents of the guidelines were clarified in three supplements to Bulletin 79-01B issues as follows: supplement #1 -

February 29, 1980; supplement #2 - September 29, 1980; and supplement #3 - October 24, 1980.

The criteria of the DOR Guidelines, which generally distinguish it from the other NRC qualification criteria documents, are:

LOCA in-containment temperature conditions of 340°F for 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> (BWR drywells) and 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> (PWR ice condenser lower compartments) were suggested.

Qualification for in-containment main steam line break (MSLB) conditions could be based on LOCA conditions if the plant used single, failure-proof, automatically actuated containment spray systems.

In-containment gamma radiation conditions of 2 x 107 rads were accepted for PWRs with dry containment designs.

For sensitive equipment internals, if an in-containment beta dose of 2 x 108 rads could be attenuated via shielding to less than 10% of the required gamma dose, then qualification to the gamma dose level alone was considered acceptable.

Qualification test duration should be at least as long as the period from accident initiation until the temperature and pressure return to essentially pre-accident levels.

1 These instruments are classified as Category 1 or 2 instruments based on plant specific submittals addressing RG 1.97, Post-Accident Monitoring Instrumentation.

Shorter tests were acceptable if analysis indicated no significant accelerated thermal aging during the untested period.

Thermal or radiation aging of the test specimen s was not necessary if the materials were not susceptible to significant aging mechanisms during normal operation.

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VIP-012 Revision 2 Title Environmental Qualification Desktop Guide If a component failed during a test, the test should be considered inconclusive.

Qualification for accident radiation and chemical sprays could be performed by analysis.

Margin need not be applied to the required environmental conditions. Equipment should be qualified for a one-hour minimum operating time, as per supplement #2 of IE Bulletin 79-01B.

A qualified life of equipment was not required to be established. Ongoing programs should exist at the plant to review surveillance and maintenance records to assure that equipment which is exhibiting ige related degradation will be identified and-replaced as necessary.

NUREG0588 This document was issued by the NRC for comment in late 1979. A revised version containing public comments and NRC staff responses was issued in July 1981. Its important to note that only the for comment version was codified in 10 CFR 50.49 (i.e., the revised version containing public comments and staff responses cannot be cited as a regulatory basis when challenging a licensee or vendor).

NUREG-0588 was developed to resolve NRC Generic Technical Activity A-24 and established NRC staff technical positions for qualification of Class 1E equipment for new plants and plants under construction. Like the DOR Guidelines, NUREG-0588 addresses only EQ; seismic qualification is not discussed as requirements for dynamic and seismic qualification of electric equipment important to safety, protection of electric equipment important to safety against other natural phenomena and external events, and environmental qualification of electric equipment important to safety located in a mild environment are not included within the scope 10 CFR 50.49.

NUREG-0588 established two EQ categories based on the 1974 and 1971 versions of IEEE Std. 323.

Category I technical positions apply to equipment whose qualification is based on IEEE Std. 323-1974.

The Category II positions apply to equipment qualified to the earlier version, IEEE Std. 323-1971.

NUREG-0588 amplifies and clarifies the criteria presented in the two versions of IEEE Std. 323.

NUREG-0588 describes acceptable qualification methods and provides guidance for establishing service environments, performance requirements, selection of qualification methods, the contents of licensing submittals, and qualification documentation. It also notes that IEEE daughter standards, which address qualification of specific equipment types (e.g., cables, electrical penetrations, motors, etc.) and are endorsed by a RG, represent acceptable methods of establishing qualification.

NUREG-0588 is divided into five sections and several appendices. Each section contains separate guidance for Category I and II equipment. Section 1 discusses design basis environmental conditions, including LOCA, MSLB, and chemical spray conditions inside containment. It also discusses outside containment environmental conditions and radiation conditions both inside and outside containment.

Most of the appendices are associated with defining environmental conditions. Appendix A identifies acceptable methods of determining pipe-break mass and energy releases. Appendix B presents a model for calculating a device's thermal response to MSLB superheat conditions and determining if the surface temperature is bounded by the LOCA test temperature. Appendix C is a suggested in-containment qualification profile for BWRs and ice condenser PWRs, while Appendix D presents a sample calculation for in-containment radiation conditions.

Section 2 of NUREG-0588 discusses qualification methods with special emphasis on qualification type testing. The section generally subscribes to the guidance in IEEE Std. 323-1974. It indicates the NRC will not generally accept analysis alone as a qualification method for equipment in harsh environments unless testing is impractical due to equipment size, or partial test data support the analytical assumptions and conclusions.

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VIP-012 Revision 2 Title Environmental Qualification Desktop Guide Section 3 of NUREG-0588 accepts the margins proposed by IEEE Std. 323-1974 on accident test conditions. Although these margins must be provided to address test equipment inaccuracies, additional margin to account for other qualification uncertainties need not be added if the accident conditions were developed using conservative NUREG-0588 guidance. NUREG-0588 requires a one-hour minimum operating time margin for equipment performing its function within a short time into the event.

Section 4 of NUREG-0588 addresses aging, supports the use of the Arrhenius methodology, and indicates an equipment qualified life should be developed.

Section 5 of NUREG-0588 addresses documentation, supports related guidance in IEEE Std. 323-1974 and references Appendix E of NUREG-0588 for the type of information that should be documented. Finally, it notes that a manufacturer's Certificate of Conformance alone, without supporting data, is not sufficient basis for establishing qualification.

Standard Review Plan NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition, also known as (SRP), offers guidance for NRC staff on a variety of topics. The SRP is revised periodically and is intended to represent the latest information regarding specific regulatory topics. The organization of the SRP is analogous to the contents of a licensee's safety analysis report. EQ of mechanical and electrical equipment is discussed in SRP Chapter 3.11, Environmental Qualification of Mechanical and Electrical Equipment, while seismic qualification is contained in SRP Chapter 3.10, Seismic and Dynamic Qualification of Mechanical and Electrical Equipment. Other SRP subchapters address related material. For example, SRP Chapters 3.6.1, Plant Design for Protection Against Postulated Piping Failures in Fluid Systems Outside Containment, 3.6.2, Determination of Rupture Locations and Dynamic Effects Associated with the Postulated Rupture of Piping, and 3.6.3, Leak-Before-Break Evaluation Procedure, contain information on pipe-break location and criteria, both inside and outside containment.

SRP Chapter 3.11 addresses qualification for both harsh and mild environments. It embraces the information and methodologies presented in IEEE Std. 323-1974 (which the NRC endorsed with clarifications and exceptions taken in RG 1.89, Revision 1) and NUREG-0588. The mechanical equipment that is referenced in SRP 3.11 relates to subcomponents of environmentally qualified electrical equipment that are non-metallic such as seals, gaskets, lubricants, fluids for hydraulic systems, diaphragms, O-rings, etc.

Regulatory Guides The NRC issues RGs to provide methods for complying with the NRCs regulations (e.g., 10 CFR 50).

Where industry standards exist, RGs typically endorse these standards with selective clarification and/or exceptions taken. For equipment qualification, several RGs have been issued by the NRC. The Regulatory Guidance section of this DTG provides a comprehensive list of RGs that are commonly utilized to establish EQ of electrical equipment.

RG 1.89, Environmental Qualification of Certain Electric Equipment Important to Safety for Nuclear Power Plants, Revision 1, and RG 1.89, Environmental Qualification of Certain Electric Equipment Important to Safety for Nuclear Power Plants, Revision 2, describe methods acceptable to the NRC staff for complying with 10 CFR Part 50.49. RG 1.89, Revision 1 endorses, with clarifications and exceptions taken, IEEE Std. 323-1974. RG 1.89, Revision 2 endorses, with clarifications and exceptions taken, International Technical Committee (IEC)/IEEE 60780-323, Nuclear Facilities

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VIP-012 Revision 2 Title Environmental Qualification Desktop Guide Electrical Equipment Important to SafetyQualification, Edition 1, 2016-02. It is recognized that RG 1.89, Revision 2 will most likely be used for future nuclear power plants and that the existing nuclear fleet would continue using guidance in their design or licensing basis (i.e., DOR Guidelines, NUREG-0588 Category I or II, or RG 1.89, Revision 1). Either of these RGs should be considered the NRC's formal guidance regarding compliance with the EQ Rule. Like NUREG-0588, the RGs address methods for addressing environmental conditions, qualification methods, margin, aging, etc.

EQ of Class 1E Equipment (IEEE Std. 323)

IEEE Std. 323 is commonly viewed as the definitive qualification standard for electrical equipment, including instrumentation. The standard was originally issued as a trial use guide in 1971 and was intended to be the first of a series of qualification documents for electrical equipment. It was subsequently revised in 1974; a supplement was added in 1975; the standard was rewritten and reissued in 1983 and 2003. The latest version is a joint standard titled IEC/IEEE 60780-323.

The 1971 trial use guide called for qualification of safety-related electrical equipment through a systematic and disciplined program of analysis, testing, and quality assurance. It specified that qualification may be achieved through analysis, type testing, operating experience (suitably extrapolated and justified), or a combination of these methods. The 1974 standard contains expanded technical requirements, including the concept of aging. A 1975 addendum to IEEE Std. 323 was added to clarify that aging should be determined based on the specific design and application. It also indicated any accelerated aging techniques applied should yield valid results and be correlated to real time. It acknowledged that the state of the art for aging simulation was more advanced for some equipment and that "known technology" should be used. Finally, it suggested that where the state of the art was limiting, aging could be addressed by operating experience, analysis, ongoing qualification, or a combination of techniques. The 2016 standard contains expanded discussion on aging including considerations of activation energy and acceleration rates.

For information on aging acceleration rate and activation energy values, see RG 1.89, Revisions 1 and 2 and IP 71111.21N.

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VIP-012 Revision 2 Title Environmental Qualification Desktop Guide ATTACHMENT 2 SAMPLE QUESTIONS Sample Questions:

1.

To what standard (i.e., IEEE Std. 323-1974) or guidance (DOR Guidelines, NUREG-0588 Category I or II, RG 1.89 Rev. 1 or 2, etc.) is the component qualified to?

2.

What are the key parts of the environmental and aging tests?

3.

Identify and evaluate the parts of test susceptible to going/being done wrong 3. Why is this specific item being tested?

a.

Is it representative/bounding of plant design or site specific?

b.

Is the DCD properly translated into test specifications? Look at procurement documentation.

4.

Evaluate data fidelity.

5.

What will the specific item be used for? Does the test demonstrate that the specific item can perform safety function?

6.

What is the safety function of the specific item - is it required to operate in a harsh environment? (or other conditions described in 10 CFR Part 50.49)? Is this addressed in the test?

7.

What does the test report say what environment it is qualified for?

8.

Will the test apparatus/test design produce a test with representative results of accident scenario?

9.

What does the test simulate? Is it appropriate (e.g., does it bound the expected environmental conditions over the entire duration of the assumed DBE)?

10.

What are the key parameters of the test?

11.

Is the instrumentation appropriate and calibrated?

12.

Check Corrective Actions and look for problems then go back to program.

13.

Is the orientation of the specific item representative of installed orientation? (May not be known) 14.

Is qualification a combination of test and analysis?

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VIP-012 Revision 2 Title Environmental Qualification Desktop Guide ATTACHMENT 3 SAMPLE ISSUES TO REVIEW EQ Issue Yes No Comments

1. Stated conclusion that the equipment is qualified for the intended applications

2. Full description of the equipment

3. Adequate similarity between installed and qualified devices

4. Allowed mounting methods and orientations

5. Interfaces conduit, housing seals, etc.

6. Per EQ requirements, a qualified life has been established (except for qualification in accordance with DOR guidelines) with appropriate technical justification and testing

7. Per EQ requirements, type tests were performed sequentially on the same test specimens

8. Type test sequence conforms to requirements or is otherwise adequately justified

9. Performance/

acceptance criteria (operating time, accuracy, etc.)

appropriately defined and achieved

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10. Radiation qualification covers both normal and accident conditions

11. Operating environment simulation meets plant requirements:

Steam exposure,

Humidity, Temperature, Pressure

12. Chemical or water spray simulation performed and documented if required

13. Submergence simulation performed and documented if required

14. Qualification margins are established per EQ requirements (except for qualification in accordance with DOR guidelines)

15. Relevant type test anomalies evaluated and resolved

16. Periodic maintenance, surveillance and replacement activities defined

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17. Relevant regulatory or industry notifications evaluated and resolved

18. Referenced data and documents identified and either attached or readily retrievable http://www-pub.iaea.org/MTCD/publications/PDF/P052_scr.pdf