NRC Generic Letter 81-05, Information Regarding the Program for Environmental Qualification Of Safety-Related Electrical Equipment

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January 19, 1981

ALL LICENSEES OF OPERATING PLANTS AND APPLICANTS FOR OPERATING LICENSES AND HOLDERS OF CONSTRUCTION PERMITS

SUBJECT: INFORMATION REGARDING THE PROGRAM FOR ENVIRONMENTAL QUALIFICATION OF SAFETY-RELATED ELECTRICAL EQUIPMENT (GENERIC LETTER 81-05)

Reference (a) - Order for Modification of License concerning the Environmental Qualification of Safety-Related Electrical Equipement, October 24, 1980

Reference (b) - Commision Memorandum and Order of May 23, 1980 (80-CLI-21)

Reference (c) - I&E Bullentin 79-01B Supplement No. 3, October 24, 1980

On October 24, 1980, the staff issued Orders [Refernce (a)] to all power reactor licensees, which modified their Technical Specifications in accordance with the Commission-ordered Environmental Qualification Requirements [Reference (b)]. The purpose of this letter is to provide information in response to licensee requests, regarding these Orders and the associated staff actions. The specific items to be addressed involve the environmental qualification (E-Q) requirements of the electrical equipement for the following:

(1) equipment necessary to achieve a cold shutdaown,

(2) replacement parts,

(3) Three Mile Island (TMI) Action Plan (NUREG-0737)

equipment and

(4) the June 30, 1982 deadline of Ref. (a).

(1) Cold Shutdown - Reference

(c) requires licensees to submit E-Q information for the equipment necessary to achieve and maintain a cold shutdown condition. This Bullentin requirement was not intended to invoke a change in the licensing basis of the plant. Plants licenses to a hot "safe shutdown" condition are only required by Reference

(a) to qualifiy the equipment necessary to achieve a hot shutdown (i.e., plant specific safety-related equipment). However, the Bullentin (Reference c) does require that the licensee submit the presently available information for one path to achieve the cold shutdown conditions. The Refernce

(c) position represents an enveloping staff position to be implementd on a case-by-case basis. Regulatory Guide 1.139 contains the implementation plans for the cold shutdown requirements, of which E-Q is a part. Staff reviews are in progress on this issue.

(2) Replacements Parts - We note that this requirement is set forth in reference

(b) but not explicitly in the ordering clauses of reference (a). In this regard, the E-Q requirements for replacemenmt parts are

.clearly presented in Supplement No. 2 to IEB 70-01B (September 30, 1980). It is the licensee's responsibility to justify deviation from the Category I column of NUREG-0588 in an auditiable manner. "Sound reasons" for such deviation are plant/equipment specific. Examples such as availability or system incompatability, are a matter of degree and will be judged accordingly.

(3) NUREG-0737 Equipment - The qualification requirements for this equipment are described in Appendix B to the NUREG. The schedule for submitting the information to the NRC is contained in Reference (c).

Contingencies for equipment unavailability are addressed in the NUREG. If the licensee's position on any of this quipment is that it is not safety-related within the meaning of reference (a), that position should be justified in the submittal. Staff judgements in this regard will be made in a Supplement to the original Safety Evaluation.

(4) June 30, 1982 Deadline - Some licensees have indicated that the new E-Q requirements have resulted in saturation of the test/production capabilities of the industry, and violations of the deadline may occur. Licensees should note that Ref.

(a) orders implemented a Commission imposed deadline [Ref. (b)] and the staff is not authorized to grant relief from this deadline.

Some licensee have submitted either a hearing request or a request for an extension of the time to request a hearing in regard to Ref. (a). Others have submitted letters of concern regarding specific requirements. The former will be addressed on an individual basis. This letter responds to the generic concerns of both groups.

Sincerely,

Darrell G. Eisenhut, Director Director of Licensing