NRC Generic Letter 1984-24

NRC Generic Letter 1984-024: Certification of Compliance to 10 CFR 50.49, Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants

ML031180070
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, 05000000, Zimmer, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant, Skagit, Marble Hill
Issue date:	12/27/1984
From:	Eisenhut D Office of Nuclear Reactor Regulation
To:
References
GL-84-024, NUDOCS 8501030120
Download: ML031180070 (3)

v.. E.,_ -.

0 *UNITED STATES

vXNUCLEAR REGULATORY COMMISSION

i 1WASHINGTON. 0. C. 20555 IDEC 2 7 19B4 TO ALL LICENSEES OF OPERATING REACTORS AND APPLICANTS FOR AN OPERATING

LICENSE

Gentlemen:

SUBJECl: CERTIFICATION OF COMPLIANCE TO 10 CFR 50.49, ENVIRONMENTAL

QUALIFICATION OF ELECTRIC EQUIPMENT IMPORTANT TO SAFETY

FOR NUCLEAR POWER PLANTS (Generic Letter 84-24)

The Commission has amended its regulations, effective February 23, 1983, to clarify and strengthen the criteria for environmental qualification of electric equipment important to safety. A copy of the new rule, 10 CFR 50.49,

"Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants," is enclosed for information.

The Commission has directed the staff to collect information on the status of compliance with the rule, evaluate the information and make recommendations on needed action. Accordingly, pursuant to 10 CFR 50.54(f), each licensee of an operating reactor is required to submit, under oath or affirmation, no later than 30 days from the date of this letter, a certification that: (a) the utility has in place and is implementing an Environmental Qualification (EQ)

Program that will satisfy the requirements of 10 CFR Section 50.49 within the currently approved schedule for the plant without further extension; (b) the plant has at least one path to safe shutdown using fully qualified equipment, or has submitted a Justification for continued safe operation (JCO) pending full qualification of any equipment not fully qualified; and (c) all other equipment within the scope of 50.49 is either fully qualified or a JCO has been submitted pending full qualification.

The certifications described in (a), (b), and (c) above should specifically address all IE Bulletins and Information Notices that identify EQ problems, to the extent that such bulletins and notices are relevant to the licensee's facility. The following Bulletins and Information Notices are considered applicable to these certifications: IE Bulletin 82-04, IE Information Notices

82-11, 82-52, 83-45, 83-72, 84-23, 84-44, 84-47, 84-57, 84-68 and 84-78.

This requirement for certification under oath or affirmation does not require approval by the Office of Management and Budget. Comments on burden and duplication may be directed to the Office of Management and Budget, Reports Management Room 3208, New Executive Office Building, Washington, D.C. 20503.

Darrell G. senhut, Director Division of Licensingl Enclosure: As sta Wdd cscr orooor,>0

PART 53

• DOMESTIC LICENSING OF PRODUCTlION AND UTILIZATION FACILITIES

accomplishment of safety functions containment spray, emergency core

(3) Those fire protection features. cooling. or recirculation from including alternative shutdown capa- specified in subparagraphs (I) through (iii) of paragraph (b)(l) of this section by containment sump). If the composition I

bility. involving installation of modifi- of the chemical spray can be affected by'

cations requiring plant shutdown shall the safety-related equipment

(3) Certain post-accident monitoring equipment malfunctions, the most be implemented before the startup severe chemical spray environment that after the earliest of the following equipment' results from a single failure In the spray events commencing 9 months or more (c) Requirements for (1)dynamic and after the date of the NRC staff Fire seismic qualification of electric system must be assumed.

Protection Safety Evaluation Report equipment important to safety, (Ul) (4) Radiation.The radiation accepting or requiring such features: protection of electric equipment environment must be based on the type (I) The first refueling outage; important to safety against other natural of radiation. the total dose expected (i1) Another planned outage that phenomena and external events, and during normal operation over the (a

lasts for at least 60 days; or (ill) environmental qualification of Installed life of the equipment. and the

-0 (lii) An unplanned outage that lasts electric equipment important to safety radiation environment associated with for at least 120 days. are not the most severe design basis accident

(4) Those fire protection features in- located in a mild environment during or following which the equipment volving dedicated shutdown capability Included within the scope of this section.

'a,.

A mild environment is an environment Is required to remLsa !unctionaL

requiring new buildings and systems Including thc radiation resulting from shall be implemented within 30 that would at no time be significantly months of NRC approval. Other modi- more severe than the environment that recirculating fluids for equipment fications requiring NRC approval prior would occur during normal plant located near the recirculating lines and to installation shall be Implemented operation. including anticipated including dose-rate effects.

within 6 months after NRC approval. operational occurrences. (5) Aging. Equipment qualified by test (e) Nuclear power plants licensed to must be preconditioned by natural or operate after January 1, 1979. shall (d) The applicant or licensee shall artificial (accelerated) aging to its end- complete all fire protection modifica- prepare alist of electric equipment of-Installed life condition. Consideration tions needed to satisfy Criterion 3 of important to safefj covered by this must be given to all significant types of Appendix A to this part in accordance section. In addition. the applicant or degradation which can have an effect on with the provisions of their licenses. licensee shall Include the following the functional capability of the information for this electric equipment equipment If preconditioning to an end- Important to safety in a qualification p.

of-installed life condition is not I- file: Ia practicable. the equpment may be AH9 Environmental qualhlcatimf of (1) The performance specifications 'a preconditioned to a shorter designated aLectric equipment Important to safety for nuclear power plants. under conditions existing during and lifeIThe equipment must be replaced or following design basis accidents. refurbished atthe end of this designated (a) Each holder of or each applicant (2) The voltage, frequency, load, and for a license to operate a nuclear power life unless ongoing qualification plant shall establish a program for other electrical characteristics for which demonstrates that the Item has *C'

qualifying the electric equipment the performance specified in accordance additional life.

wvith paragraph (d)(1) of this section can (6) Submergence (if subject to being defined in paragraph (b) of this section be ensured.

(b) Electric equipment Important to ubmerged).

(3) The environmental conditions. (7) Synergistic Effects. Synergistic safety covered by this section I, including temperature, pressure.

(1) Safety-related electric equipment" effects must be considered when these This equipment Is that relied upon to humidity, radiation. chemicals, and effects are believed to have a significant remain functional during and following submergence at the location where the effect on equipment performance.

design basis events to ensure Us) the equipment must perform as specified in (8) Margins.Margins must be applied accordance with paragraphs (d)(1l and to account for unquantified uncertainty, integrity of the reactor coolant pressure (2) of this section.

boundary. (ii) the capability to shut such as the effects of production (e) The electric equipment variations and inaccuracies in test down the reactor and maintain It in a qualification program must include and instruments- These margins are in.

I safe shutdown condition. and (ill) the be based on the following- addition to any conservatisms applied Z capability to prevent or mitigate the (1) Tempemiture and Pressur. The of accidents that could during the derivation of local IIr consequences time-dependent temperature and environzental conditions of the result In potential offslte exposures pressure at the location of the electric II comparable to the 10 CFR Part 100 equipment unless these conservatisms guidelines. Design basis events are equipment important to safety must be can be quantified and shown to contain defined as conditions of normal established for the most severe design appropriate margini operation. including anticipated basis accident during or following which (f] Each item of electric equipment operational occurrences. design basis this equipment Is required to remain Important to safety must be qualified by accidents, external events, and natural functional. one of the following methods:

phenomena for which the plant must be

(23 Humidity. Humidity during design (1) Testing an Identical item of designed to ensure functions (i) through basis accidents must be considered. equipment under identical conditions or (iii) of this paragraph. (3) ChemicalEffects. The composition under similar conditions with a

(2) Nonsafety-relaled electric of chemicals used must be at least as supporting analysis to show that the equipment whose failure under severe as that resulting from the most equipment to be qualified Is acceptable.

postulated environmental conditions limiting mode of plant operation (eg. (2) Testing a similar item of equipment could prevent satisfactory with a supporting analysis to show that oSpedulc ui dance concernig the type of the equipment to be qualified is aniables to be monitored I provided in Revion acceptable.

at Regulatory Guide 1.7. 'letrumentatino for Light- Water Cooled Nuclear Power Plants to Asaes Plant (3) Experience with Identical or

9SAfe:y rel.ed eldeilt- e*!uhpent ig refered lo and Environs Conditions During and Followtog an similar equipment under similar as Ciu.. s e.;

e.,a;Pa.'r I :.%IME l23...4. Copies Accident' Copies of the Regulatory Guide can be conditions with a supporting analysis to of this standard may be obiained fram the heatitUta obtained froeNuclear Regulatory Commdisson. show that the equipment to be qualified of Electrical and Electronics Ensinee Inc.. SO Document Management Branch. Washington. DC Is acceptable.

I East 4.lth StreeL New York, NY 1007. 206s&

50-24 January 31, 1983 (next page is50-24a)

PN

PART 50 0 DOME~TiC LICENSING OF PRODUCTION Akrd UTILIZATION FACILITIES '

(4) AnalysIs, In combination with partial type test data that supports the analytical assumptions and conclusions

(5) No significant degradation of any safety function or misleading Information to the operator as a result of Ilife is less than the term requested Where construction of a facility is in- volved, the Commission may specify in (C)Each holder of an operating license failure of equipment under the accident the construction permit the period for Issued prior to February 22, 1983. shall, environment resulting from a design which the license will be Issued If ap- proved pursuant to 1 50.5. Licenses L

by May 20,1983, Identify the electric basis event.

equipment Important to safety within may be renewed by the Commission U)A record of the qualification , upon the expiration of the period.

the scope of this section already including documentation In paragraph qualified and submit a schedule for (d) of this section. must be maintained In 50.52 Combining licenses I

either the qualification to the provisions an auditable form for the entire period of this section or for the replacement of during wHch the covered itern is The Commission may combine in a the remaining electric equipment installed in the nuclear power Cant or Is single license the activities of an appli- Important to safety within the scope of cant which would otherwise be 11- stored for future use to permit censed severally.

this .ection. This schedule must verification that each item of electric ests-,lish a goal of findl environmertal equipment important to safety covered qualification of the electric equipment by this section- within th~e scope of this section by the (1) Is qualified for its application and end of the second refueling outage after (2) Meets its specified performance r 150.53 Jurisdictional limitations.

March 31.1982 or by Marchs 31.1983.

whichever Is earer. The D r of the.

Ii requirements when It Is subjected to the  : No license under this part shall be conditions predicted to be present when a deemed to have been Issued for activi- Office of Nuclear Reactor Regulatory It must perform its safety function up to " ties which are not under or within the may grant requests for extensions of this the end of its qualified life. Jurisdiction of the United States.

deadline to a date no later than I.r (k) Applicants for and holders of L

November 30,198I. for specific pieces of equipment if thes. requests are filed an operating licenses are not required to requalify electric equipment important a timely basis and demonstrate good to safety In accordance with the 0 I 50.54 Conditions of lcenses.

cause for the extension, such as provisions of this section If the procurement lead time, test Commission has previously required . Whther stated therein or notWhthnot~, the complications, and Installation following shall be deemed conditions qualification of that equipment in in every license Issued:

problems. In exceptional cases. the accordance with 'Guidelines for Commission Itself may consider and Evaluating Environmental Qualification grant extensions beyond November 30 of Class IE Electrical Equipment in

.4

1985. for completion of environmental Operating Reactors November 1979 qualification. (DOR Guidelines), or NUREG-o8 (For (h) Each licensee shall notify the >(a)(1) Each nuclear power plant or tid Comment version). Interim Staff Commission of any significant Position on Environmental Qualification reprocessing plant licensee subject to equipment' qualification problem that of Safety-Related Electrical Equipment." the quality assurance criteria in may require extension of the completion (i) Replacement equipment must be Appendix B of this part shall implemet.

date provided In accordance with qualified in accordance with the pursuant to I 504b)(8)(Il of this part paragraph (g) of this section within So the quality assurance program described provisions of this section unless there or referenced in the Safety Analysis days of its discovery. are sound reasons to the contrary.

(i) Applicants for operating licenses Report. Including changes to that report that are to be pranted on or after (2)Each licensee dewced in February 22, 193 but prior to November paragraph (aXi) of this section shalL by

30.1985. shall perform an analysis to ISSUANcz, LIMITATIONS, AND CONDI- June 10. 1983 submit to the appropriate ensure that the plant can be safely noNs or LIcENsEs AND CONSTRUcrION NRC Regional Office shown in operated pending completion of PrITS Appendix D of Part 20 of this chapter th equipment qualification required by this current description of the quality section. This analysis must be submitted 050.50 Issuance of licenses and construe. assurance program It Is implementing to the Director of the Office of Nuclear tion permits. for Inclusion In the Safety Analysis Reactor Regulation for consideration Upon determination that an applica- Report, unless there are no changes to prior to the granting of an operating tion for a license meets the standards the description previously accepted by license and must include. where and requirements of the act and regu- . NRC. This submittal must identify appropriate, consideration oh lations, and that notifications, if any, changes made to the quality assurance

(1) Accomplishing the safety function to other agencies or bodies have been g program description since th duly made, the Commission will issue description was submitted to NRC.

by some designated alternative a license, or if appropriate a construc- : (Should a licensee need additional equipment if the principal equipment "I

tion permit, In such form and contain- time has not been demonstrated to be fully beyond June 101983 to submit its Ing such conditions and limitations in- current quality assurance program qualified. U.

cluding technical specifications, as it

(2) The validity of partial test data in Z

deems appropriate and necessary. description to NRC, It shall notify the appropriate MRC Regional Office In support of the original qualification.

(3) Limited use of administrative I 50.51 Duration of lIcense. renewal. writ explain why additional time is controls over equipment that has not Each license will be Issued for a neededL and provide a schedule for NRC

been demonstrated to be fully qualified. fixed period of time to be specified in approval showing when Its current

(4) Completion of the safety function the license but in no case to exceed 40 quality assurance proam desipton prior to exposure to the accident years from the date of Issuance. will be submitted.)

environment resulting from a design Where the operation of a facility is in- (3) After March 11. 1963. each license.

basis event and ensuring that the volved the Commission will issue the described In paragraph (a)X) of this subsequent failure of the equipment license for the term requested by the section may make a change to a does not degrade any safety function or applicant or for the estimated useful previously accepted quality assurance mislead the operator. life of the facility if the Commission program description included or determines that the estimated useful referenced In the Safety Analysis50-24a January 31, 1983 (next 0age IS0-24 b