NRC Generic Letter 1981-05
.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 81-0)Reference (a) -Order for Modification of License concerning the Environmental Qualification of Safety-Related Electrical Equipment, October 24, 1980 Reference (b) -Commission Memorandum and Order of May 23, 1980 (80-CLI-21)
Reference (c) -I&E Bulletin 79-OlB Supplement No. 3, October 24, 1980 On October 24, 1980, the staff issued Orders [Reference (a)] to all power reactor licensees, which modified their Technical Specifications in accor-dance 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 equipment for the following:
(1) equipment necessary to achieve a cold shutdown, (2) replace-ment 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 Bulletin requirement was not intended to invoke a change in the licensing basis of the plant.Plants licensed to a hot "safe shutdown" condition are only required by Reference (a) to qualify the equipment necessary to achieve a hot shutdown (i.e., plant specific safety-related equipment).
However, the Bulletin (Reference c) does require that the licensee submit the presently available information for one path to achieve the cold shutdown conditions.
The Referihce (c)position represents an enveloping staff position to be implemented 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) Replacement Parts -We note that this requirement is set forth in reference (b) it not explicitly in the ordering clauses of reference,, (a). In this regard, the E-Q requirements for replacement parts are,`3 ...-.. .\ ........3........;
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I NRC FORM 318 410/801 NRCM 0240 O FFICIA L RE CO R.D C OP Y-., USGPO: 1980-329-824 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
EQUI)*ENT Reference (a) -Order for Modification of License concp i1ng the Environmental Qualification of Safety-eRelated Electrical Equipment, October 24, 1980 Reference (b) -Commission Memorandum and Order of May 23, 1980 (80-CLI-21)
Reference (c) -I&E Bulletin 79-OlB Supplement, flo. 3, October 24, 1980 On October 24, 1980, the staff-issued Order$'[Reference (a)] to all power reactor licensees, which modified their Teghnical Specifications in accor-dance with the Commission-ordered Environsental Qualification Requirements
[Reference (b)]. The purpose of this letter is to provide information in response to licensee requests, regardin4 these Orders and the associated staff actions. The specific items tote addressed involve the environmental qualification (E-Q) requirements of )he electrical equipment for the following:
(1) equipment necessaryto achieve a cold shutdown, (2) replace-ment parts, and (3) Three Mile Isldnd (TMI) Action Plan (NUREG-0737)
equipment and (4) the June 30, l9jt deadline of Ref. (a).(1) Cold Shutdown -Reference
(4 requires licensees to submit E-Q information for the equipment necessary to achieve and maintain a cold shutdown conditiomf This Bulletin requirement was not intended to invoke a chaAge in the licensing basis of the plant.Plants licensed to a hqt "safe shutdown" condition are only required by Reference
2a) to qualify the equipment necessary to a achieve a hot shutdowi (i.e., plant specific safety-related J equpmn)
- the Bulletin (Reference c) does require that , the licensee submi thezavailable information for one path to achieve the cold shutdown conditions.
The Reference (c) position represents an enviloping staff position to be implemented on a case-by-case bas s. Regulatory Guide 1.139 contains the imple-mentation plans or the cold shutdown requirements, of which E-Q is a part. S fff reviews are in progress on this issue.(2) Replacement P~rts -We note that this requirement is set forth in reference
(4tx but not explicitly in the ordering clauses of reference (a). In thWs regard, the E-Q requirements for replacement parts are OFI~ ... ....................
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...NRC FORM 318 410/801 NRCM 0240 OFFICIAL RECORD COPY* USGPO: 1980-329-824
0 ,4 0 U W _- a-ALL LICENSEES
OF OPERATING
PLANTS AND APPLICANTS
FOR OPE NING LICENSES AND HOLDERS OF CONSTRUCTION
PERMITS /SUBJECT: INFORMATION
REGARDING
THE PROGRAM FOR ENV IONMENTAL QUALIFICATION
OF SAFETY-RELATED
ELECTRIC EQUIPMENT Reference (a) -Order for Modification of Licens concerning the Environmental Qualification of afety-Rtlated Electrical Equipment, October 24, 1980.Reference (b) -Commission Memorandum and Or er of May 23, 1980 (80-CLI-21)
Reference (c) -I&E Bulletin 79-018 Suppl ent No. 3, October 24, 1880 On October 24, 1980, the staff-issued
0 ders [Reference (a)] to all power reactor licensees, which modified theiy Technical Specifications in accordance with the Commission-approVqd Environmental Qualification Require-ments [Reference (b)]. The purpose 9T this letter is to provide informa-tion in response to licensee requests, regarding these Orders and the associ-ated staff actions. The specific iems to be addressed involve the environ-mental qualification (E-Q) require ents of the electrical equipment for the following:
(1) equipment necessary to achieve a cold shutdown, (2) replace-ment parts, and (3) Three Mile I and (TMI) Action Plan (NUREG-0737)
equip-ment. In addition, the method fbr implementation of the E-Q safety evalua-tion results will be presented./
(1) Cold Shutdown -Referenc /(c) requires licensees to submit E-Q informa-tion for the equipment nessary to achieve and maintain a cold shut-down condition.
This Byletin requirement was not intended to invoke a change in the licensi*g basis of the plant. Plants licensed to a hot'safe shutdown'
condit on are only required by Reference (a) to qualify the equipment necessa'y to achieve a hot shutdown (i.e., plant specific safety -related equ Went). However, the Bulletin does require that the licensee submit ghe available information.
The Reference (c) posi-tion represents an envelop1ng staff position to be implemented on a case-bf-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 pr ess on this issue.(2) Replacement Parts -The E-Q requirements for Replacement parts are clearly presented in Supplement No. 2 to IEB 79-OlB (September
30, 1980).It is the licen~ee's responsibility to justify deviation from the Cateogry I column of NUREG-0588 in an auditible manner. "Sound reasons*for such deviation are plant/equipment specific.
Examples such as availability or system incompatibility, are a matter of degree and will be Judged accordingly.
The subjective aspect of this requirement is necessary and will be addressed on a case-by-case basis.OFFICE~SU N M O ...................
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..I. I NRC FORM 318 410/80) NRCM 0240 O FFICIA L R EC O RD C OPY*t USGPO: 1980329-824 A' 9 9 9 I 0 -a (3) NUREG-0737 Enuipment
-The qualification requirements f9/ this equipment are specifically addressed In Appendix E to ,te NUREG. The schedule for submitting the information to the NRC i;/contained in Reference (c). Contingencies for equipment unavailpbility are addressed in the NUREG. If the licensee's position on any of this equipment is that it is not safety-related that p sition should be justified in the submittal.
Staff judgements ip this regard will be made in a Supplement to the original Safety Ev luation.Safety Evaluation Implementation
-Reference (b) /equires the staff to issue Safety Evaluations by February 1, 1981. T ese Safety Evaluations will be issued with a request for licensee res p6nse under the provisions of 10 CFR 50.54(f).
Subsequent to the staff view of that response, the staff will issue Confirmatory and/or Show Ca~ e Orders which provide the opportunity for a hearing to implement the 7pecific requirements applicable to that facility.
This procedure may make 'existing hearing/extension requests based on Reference (a), unnecess/ry.
Licensees with such requests should review this matter and afvise the NRC of their intents as soon as possible.
Formal notification s necessary to change existing requests.SI Darrell G. Elsenhut, Director Division of Licensing (4I (K.i D*SEE PREVIOUS WHITE FOR CONCURRENCE
OFFICEO ORB #2 ORB #2 AD:OR E J OELD DD:DL D:DL.................
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SURNAMEo *MWllijams:!
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DEisenhut DATEO 12/24/80 12/24/80 / / /II / 1A/ /..................
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NRC FORM 318 110/801 NRCM 0240 O FFICIA L R EC O RD C OPY* SGPO: 1980-329-824 ALL LICENSEES
OF OPERATING
PLANTS AND APPLICANTS
FOR OPERATJ G LICENSES AND HOLDERS OF CONSTRUCTION
PERMITS /SUBJECT: INFORMATION
REGARDING
THE PROGRAM FOR ENVIRO 4 ENTAL QUALIFICATION
OF SAFETY-RELATED
ELECTRICAL
EQUIPMENT Reference (a) -Order for Modification of License c ncerning the Environmental Qualification of Safety-Related El ctrical Equipment, October 24, 1980.Reference (b) -Commission Memorandum and Order/of May 23, 1980 (80-CLI-21)
Reference (c) -I&E Bulletin 79-OlB Supplemeny No. 3, October 24, 1980 On October 24, 1980, the staff-issued Orders,/(Reference (a)I to all power reactor licensees, which modified their Technical Specifications In accordance with the Commission-approved Enyironmental Qualification Require-ments [Reference (b)]. The purpose of this letter is to provide Information, in response to licensee requests, regard 7ng these Orders and the associated staff actions. The specific items to b 'addressed involve the environmental qualification (E-Q) requirements of th electrical equipment for the following:
1) equipment necessary to achieve a cold shutdown, (2) replace-ment parts, 3) equipment in mild env ronments, and (4) Three Mile Island (TMI)Action Plan NUREG-0737)
equipment.
n addition, the method for implementation of the E-Q safety evaluation results will be presented.
(1) Cold Shutdown -Reference (c) requires licensees to submit E-Q information for the equipment necessary tq achieve and maintain a cold shutdown condition.
This Bulletin requ irement was not intended to invoke a change In the licensing basis of thA plant. Plants licensed to a hot "safe shut-down' condition are only required by Reference (a) to qualify the equip-ment necessary to achieve a/hot shutdown (i.e., plant specific safety-related equipment).
Howevfr, the bulletin does require that the licensee submit the available info mation. The Reference (t) position represents an enveloping staff posi on to be implemented on a case-by-case basis.Regulatory Guide 1.139 cpntains the implementation plans for the cold ct shutdown requirements, ,f which E-Q is a part. Staff reviews are in progress on this Issue/(2) Replacemtnt Parts -Toe E-Q requirements for replacement parts are clearly presented in Suppleme/t No. 2 to IEB 79-OlB (September
30, 1980). It is the licensee's responsibility to justify deviation from the Category I column of NUREG-0588/in an auditible manner. "Sound reasons" for such deviation are plant/equipment specific.
Examples such as availability or system incompat1bility, are a matter of degree and will be Judged OFFICEO ..,....................
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NRC FORM 318 (10/80) NRCM 0240 O FFICIA L R EC O RD C OP Y* USGPO: 1980-329-824 u b ~* 4-2-accordingly.
The subjective aspect of this requ Iement is necessary and will be addressed on a case-by-case basis.(3) Mild Environments
-It is apparent that, in soe cases, the staff's view of the scope of this task differs signif cantly from the licensee~s view. The requirements are contained in thD.O.. Guidelines and NUREG-0588.
Programs are required to addre s aging. Equipment should be qualified for the environmental extremeF associated with loss of its non-redundant HVAC for the time it is requ red to operate plus margin.Throughout the Guidelines, the licensee n y, as an alternative, provide contingencies to maintain environmental parameters within the equipment specifications or provide the necessary/standard of reliability.
In the case of mild environments, such altern'tives are much more feasible due '., to the accessibility of the components!.
Licensees should proceed with their mild environment program based fn the existing requirements.
More detailed information regarding the mild environment NRC review will be provided next March. /(4) NUREG-0737 Equipment
-The qualification requirements for this equipment are specifically addressed in AppF ndix B to the HUREG. The schedule for submitting the information to th NRC is contained in Reference Wc).Contingencies for equipment unav ilability are addressed in the NUREG.If the licensee's position on a of this equipment is that it is not safety-related that position s uld be justified in the submittal.
Staff judgements in this regar will be made in a Supplement to the original Safety Evaluation.
(5) Safety Evaluation Implementation
-Reference (b) requires the staff to issue Safety Evaluations by/February
1, 1981. These Safety Evaluations will be issued with a requ t for licensee response under the provisions of 10 CFR 50.54(f).
Subsejuent to the staff review of that response, the staff will issue Confirma bry and/or Show Cause Orders which provide the opportunity for a hearing/to implement the specific requirements appli-cable to that facility.
this procedure may make existing:hearing/extension request based on Referqhce (a), unnecessary.
Licensees with such requests should review this matter and advise the NRC of their intents as soon as possible.
F rmal notification Is necessary to change existing requests.Darrell G. Elsenhut, Director Division of Licensing DE Rosz t ocjY i~ryoJ OFFICEI0 ORB #2# AD:DL DE OELD.... .. DDP;&....
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..NRC FORM 318 (i1080) NRCM 0240 O FFICIA L R EC O RD C OPY-.- US;PO: 1980-329-824 ALL LICENSEES
OF OPERATING
PLANTS AND APPLICANTS
F OPERATING
LICENSES AND HOLDERS OF CONSTRUCTION
PERMITS 7 SUBJECT: INFORMATION
REGARDING
THE PROGRAM FOR. tNVIRONMENTAL
QUALIFICATION
OF SAFETY-RELATED
ELE9TRICAL
EQUIPMENT Reference (a) -Order for Modification of License concerning the Environmental Qual1ficati owof Safety-Related Electrical Equipment, October 24, 1980 Reference (b) -Commission Memorandum aqd Order of May 23, 1980 (80-CLI-21)
Reference (c) -I&E Bulletin 79-018 Supplement No. 3, October 24, 1980.On October 24, 1980, the staff-issued Orders [Reference (a)] to all power reactor licensees, which modified their Technical Specifications in accor-dance with the Commission-approved tnvironmental Qualification Requirements
[Reference (b)]. The purpose of tfis letter is to provide information in response to licensee requests, refarding these Orders and the associated staff actions. The specific iteus to be addressed involve the environmental qualification (E-Q) requirements of the electrical equipment for the following:
(1) equipment necessary to achieve a cold shutdown (2) replacement parts, and (3) Three Mile Islnd (TMI) Action Plan (NUREG-07371 equipment and (4) the June 30, 1982 deadline of Ref. (a).(1) Cold Shutdown -Refereffce (c) requires licensees to submit E-Q information for the e4uipment necessary to achieve and maintain a cold shutdown conditfon.
This Bulletin requirement was not intended to invoke a change lb the licensing basis of the plant. Plants licensed to a hot '¶iafe shutdown" condition are only required by Reference (a) to q9alify the equipment necessary to achieve a hot shutdown (i.e., plant specific safety-related equipment).
However, the Bulletin doei require that the licensee submit the available information.
Thb Reference (c) position represents an enveloping staff positionkto be implemented on a case-by-case basis. Regulatory Guide 1.139 cofitains the implementation plans for the cold shutdown requirements, of which E-Q is a part. Staff reviews are in progress on this issug.(2) RQPiacementj'Parts
-We note that this requirement is set forth in reference
1b) Eti not explicitly in the ordering clauses of reference (a). In Ohis regard, the E-Q requirements for replacement parts are clearly presented in Supplement No. 2 to IEB 79-OlB (September
30, 1980). / is the licensee's responsibility to justify deviation from./I.1 OFFIC~t O FC O ...................
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NRC FORM 318 (lO/80) NRCM 0240 O FFICIA L R EC O RD C OPY., USGPO: 1980-329-824
-2 -the Category I column of NUREG-0588 In an auditible 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 re4 irements for this equipment are specifically addressed in Apendix 8 to the HUREG.The kciedule for submitting the inforMattn 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 equipment is that it is not safety-reited within the meaning of reference
(2), that position should justified In the submittal.
Staff judgments in this regard will Je made In a Supplement to the original Safety Evaluation.
t (4) June 30, 1982 Deadline -Some licensees have indicated that the new E-Q requirements have resulted ii saturation of the test/production capabilities of the industry, aqk violations of the deadline may occur. Licensees should note that the Ref. (a) orders implemented a Commission imposed deadline ZTRef. (b)] and the staff is unable to grant relief from this deadli1 9.Some licensees have submitted eitier a hearing request or a request for an extension of the time to requert a hearing In regard to Ref. (a).Others have submitted letters of concern regarding specific requirements.
The former will be addressed on n individual basis. This letter responds to the generic concerns of both/groups.
/ Sincerely,-? Darrell G. Elsenhut, Director/ Division of Licensing i I*See attached file co~/ for previous concurrences
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SURNAMEO T I.ovak EJordan SSohinki RPurple DGEisenhut I...................
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DATE_ _ 1 /8 1 1/ /81 l/ 81 1/ /81 1/ /81.3 ...........
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NRC FORM 318 410/80) NRCM 0240 OFFICIAL RECORD COPY* US;PO: 1980-329-824
-2-clearly presented in Supplement No. 2 to IEB 79-OIB (September
30, 1980). It is the licensee's responsibility to Justify deviation from the Category I column of NUREG-0588 in an auditible 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 tc). Contingencies for equipment unavailability are addressed in the NUREG. If the licensee's position on any of this equipment is that it is not safety-related within the meaning of reference (a), that position should be justified in the submittal.
Staff Judgments 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 the Ref. (a) orders implemented a Commission imposed deadline [Ref. Ib)J and the staff is not authorized to grant relief from this deadline.Some licensees 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 Division of Licensing*See previous file copi S ncur ces OFFICEO Dl OELDj DL:DD SURNAMEO s :m va EJor SSohinki 4 k RPurple D nhut DATEF 1 1/- /8 1\/8i j 1/ / 8T 1 1 j.........
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NRC FORM 318 110/801 NRCM 0240 OFFICI1AL
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