NRC Generic Letter 80-89, IEB 79-01b Supplement 3 Environmental Qualification of Class 1E Equipment
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GL80089
October 24, 1980
MEMORANDUM FOR: B. H. Grier, Director, Region I J. P. O'Reilly, Director, Region II J. G. Keppler, Director, Region III K. V. Seyfrit, Director, Region IV R. H. Engelken, Director, Region V
FROM: Norman C. Mosely, Director, Division of Reactor Operations Inspection, IE
SUBJECT: IE SUPPLEMENT NO. 3 TO BULLETIN 79-01B: ENVIRONMENTAL QUALIFICATION OF CLASS 1E EQUIPMENT
The subject supplement should be dispatched for action on October 24, 1980 to all power reactor facilities with an Operating License. The supplement should be dispatched for information to the SEP plants (including Indian Point 2 and 3 and Zion 1 and 2) the NTOL plants and plants with a construction permit. The supplement will also be transmitted from Headquarters to participants in the July Region meeetings.
The purpose of this supplement is to clarify issues raised by Supplement No. 2. No inspection requirements were added as a result of this Supplement.
Norman C. Mosely, Director Division of Reactor Operations Inspection Office of Inspection and Enforcement
Enclosures:
- 1. Draft Transmittal Letters
CONTACT
- V. D. Thomas, IE 49-28180
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(Draft letter to all power reactor facilities with an operating license less SEP, Indian Point, and Zion)
IE Supplement No. 3 to Bulletin No. 79-01B: ENVIRONMENTAL QUALIFICATION OF CLASS 1E EQUIPMENT
Gentlemen:
Enclosed is IE Supplement No. 3 to Bulletin No.79-01B. This supplement clarifies two issues raised by Supplement No. 2. These are
- (1) the submittal of qualification information for equipment resulting from TMI Action Plan requirements and
- (2) the qualification of equipment which is required to achieve a cold shutdown condition. This action is the result of industry feedback to NRC regarding interpretation of Supplement No. 2. The information presented is applicable to your submittal regarding environmental qualification of Class 1E equipment which is required by November 1, 1980.
Should you have questions regarding this Supplement please contact this office.
Sincerely
Signature (Regional Director)
Enclosures:
- 2. Recently Issued IE Bulletins
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SSINS No.: 6820 Accession No.:
8008220248 IEB Sup #3 to 79-01B UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT WASHINGTON, D.C. 20555
October 24, 1980
IE Bulletin No.79-01B Supplement No. 3: ENVIRONMENTAL QUALIFICATION OF CLASS IE EQUIPMENT
Description of Circumstances
Two issues were raised by Supplement No. 2 which require clarification. These are:
- (1) the dates required for submittal of qualification information for TMI related equipment, and
- (2) whether the equipment required to achieve a Cold Shutdown condition must be environmentally qualified if the licensing basis for the plant was a Hot Safe Shutdown condition.
- (1) Supplement No. 2 (Q.1, Q.5) addressed the minimum cold shutdown requirements. The staff position on this issue is that the licensee must identify and environmentally qualify the equipment needed to complete one method (path) of achieving and maintaining a cold shutdown condition. The equipment of other paths must be reviewed to assure that its failure will not aggravate or contribute to the accident (ref. Q.5 Supp. No. 2).
Due to an inconsistency between Supplement No. 1 and Supplement No. 2, the staff position on this issue was unclear. Therefore, the following will apply:
a. The qualification information for equipment needed to achieve and maintain a Hot Safe Shutdown condition must be submitted no later than November 1, 1980.
b. The qualification information for equipment required to achieve and maintain a Cold Shutdown condition (ref. Q.1 and Q.5 of Supplement No.2) must be submitted not later than February 1, 1981.
- (2) IEB 79-01B required a 90 day response which was due in mid-April 1980. Supplement 1 (Feb. 1980) informed licensees that equipment which was "planned" to be installed as a result of lessons learned need not be addressed in that response. Some of this equipment has since been installed. Supplement No. 2 (Q.5, Q.21) identified that the staff position was that equipment which is installed should be treated in a manner similar to all other safety-related electrical equipment and be addressed in the November 1, 1980 submittal. This position represents no change in staff position regarding the scope of the review. However, since the staff position on this issue was unclear the following will apply:
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IEB 79-01B Sup #3 October 24, 1980 Page 2 of 2
a. Qualification information for installed TMI Action Plan equipment must be submitted by February 1, 1981.
b. Qualification information for future TMI Action Plan equipment (ref. NUREG-0737, when issued), which requires NRC pre-implementation review, must be submitted with the pre-implementation review data.
c. Qualification information for TMI Action Plan equipment currently under the NRC review should be submitted as soon as possible.
d. Qualification information for TMI Action Plan equipment not yet installed which does not require pre-implementation review should be submitted to NRC for review by the implementation date.
The above items 1 and 2 represent no change in staff position regarding the scope of the 79-01B Supplement 2 review.
IE Bulletin No.79-01B was issued under a blanket GAO clearance (B180225 (R0072), clearance expired July 31, 1980) specifically for identified generic problems. Supplement No. 3 to Bulletin 79-01B is for information, hence no GAO clearance is required.