ML20150D912
| ML20150D912 | |
| Person / Time | |
|---|---|
| Issue date: | 07/24/1978 |
| From: | Minogue R NRC OFFICE OF STANDARDS DEVELOPMENT |
| To: | Case E Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20150D914 | List: |
| References | |
| RTR-REGGD-01.XXX, RTR-REGGD-1.153, RTR-REGGD-1.XXX, TASK-OS, TASK-RS-609-5 NUDOCS 7812110025 | |
| Download: ML20150D912 (5) | |
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JUL 2 41973 MEMORAtiDUM FOR: E. G. Case, Chairman, RRRC FROM: Robert B. Minogue, Director, SD
SUBJECT:
SUPPLEMENTARY INF0PJ% TION ON DRAFT REGULATORY GUIDE 1.XXX,
" CRITERIA FOR ELECTRIC, IllSTRLHENTATION a CONTROL PORTIONS OF SAFETY SYSTEMS" (50 TASK RS 609-5)
In a memorandum from S. H. Hanauer to R. G. Minogue, dated April 26, 1978, Dr. Hanauer raised two issues relative to the Draft Regulatory Guide 1.XXX, " Criteria for Electric, Instrumentation & Control Portions of Safety Systems" (SD Task RS 609-5), unich should be considered by the Regulatory Requirements Review Cccmittee when it reviews this draft guide. A copy of Dr. Hanauer's memorandum is enclosed.
- 1. The first question related to the relationship among (a) the guide, (b) the standard it endorses (IEEE Std 603-1977, "IEEE Trial-Use Standard Criteria for Safety Systems for Nuclear Power Generating Stations"), and (c) IEEE Std 279-1971 (also designated as ANSI N42.7-1972), " Criteria for Protection Systems for Nuclear Power Generating Stations." IEEE Std 279-1971 is incorporated into the NRC Rules in Section S0. sea (h), " Protection Systems," of 10 CFR 50.
As stated in the proposed guide endorsing IEEE Std 603-1977, "IEEE Std 603-1977 embodies the requirements and reccamendations contained in IEEE Std 279-1971, whose scope is limited only to protection systems. Compliance with the provisions of IEEE Std 603-1977 as supplemented in Section C below (the Regulatory Positions), is considered by the NRC staff to satisfy the provisions of IEEE Std 279-1971. (The converse is not true due to the greater scope of IEEE Std 603-1977.)" The safety system scope, as delineated in IEEE Std 603-1977 includes the protection system (the IEEE Std 279scope),
and, the protective action system and auxiliary supporting features.
There is sufficient basic in the Rules, see 10 CFR 50, Appendix A, Criteria 2, 4, 10, 12, 13, 17, 18, 20, 21, 22, 23, 24, 25, 29, 34, 35, 37, 38, 40, 41, 43, 44, 46, and 54, for endorsing IEEE Std 603-1977 without reference to IEEE Std 279-1971. IEEE Std 603-1977 has been issued by IEEE "for trial use." IEEE plans to issue a " final" version in about two years frcm the initial issue date. The proposed guide will be issued "for ccament." Ultimately, a regulatory guide will be issued endorsing the " final" version of IEEE Std 603.
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E. G. Case 2 JU' 2 4 '27 When IEEE Standard 603-197X is published in its final form (not just for comment) by IEEE, we will determine if any action is needed to amend the NRC Rules in Section 50.55a(h).
- 2. The second question raised by Dr. Hanauer concerns backfitting of older plants to the requirements of IEEE Std 603-1977 and the supple-mentary provisions of the associated regulatory guide. Backfitting of IEEE Std 603-1977 is not recommended as it reflects current Regulatory practice. Following is a sumary of the purpose of each Regulatory Position in the proposed guide and a backfitting recom-mendation on each Position. Numbering is the same as in the guide.
(l.a.) This provision clarifies the intent of IEEE Std 603-1977 Section 1.2 (concerns applicability of IEEE Std 603). No backfitting is recocuended as no change in the current Regulatory practice is involved.
(1.b.) This provision clarifies Figure 1 (describes equipment scope) of IEEE Std 603-1977. No backfitting is recom- '
mended as no change in the current Regulatory practice is involved.
(l.c.) This provision makes the terminology used in IEEE Std 503-1977 consistent with the terminology being used in Standard Technical Specifications. No backfitting is recccmended as no change in the current Regulatory prac-tice is involved.
(1.d.) This provision, concerning consideration of spurious operation of fire suppression systems in the evaluation of the effects of abnormal circumstances on safety systems performance, is not explicitly covered in either IEEE Std 279-1971 or IEEE Std 603-1977. It is implicitly covered in IEEE Std 279-1971, Design Basis, Section 3(8),
and Section 4.5 (Integrity) and in IEEE Std 603-1977, Design Basis, Section 3.5.4, and Section 4.7 (Integrity);
wherein (1) abnormal conditions are identified and docu-mented (Design Basis) and (2) the equipment is required to perform under these conditions (Integrity). Because of its safety significance, backfitting should be considered.
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l JLt isC (i.e.) Section 3, Design Basis of IEEE Std 279-1971 and 603-1977 requires documentation of the basis for design of all portions of the protection and safety systems respectively.
This Regulatory provision (l.e.) is an explicit reccmenda-tion on this topic where diverse (i.e., backup or alternate) channels are provided. It explicitly recomends design basis documentation of the performance capability of these diverse channels. Because of its safety significance, backfitting should be considered.
(l.f.) The recocmended wording concerning application of the single failure criterion to manual, automatic or comon portions of the system was taken from IEEE Std 279-1971.
Ho backfitting is recomended as no change in the current Regulatory practice is involved.
(l.g.) With regard to reccamending that seal-in of individual channel trips not be construed to be required, it should be noced that this position is consistent with the staff position on Issue # 16 in NUREG 0153. Backfitting is not recommended as no requirement is being added. This position is a clarification.
(l.h.) With regard to termination of protective action by auto-matic means, in the past protection system designs have been required to utilize manual temination of protective action. Automatic termination was not permitted. This position (l.h.) allows automatic temination if certain conditions are met. No backfitting is reccmcended as this position simply allows an alternate, acceptable, design.
l (1.1) This position is intended to make IEEE Std 603-1977 con-sistent with IEEE Std 279-1971. It concerns required redundancy in instrument systems used for both protection and control when one channel is removed for maintenance.
No backfitting is recomended as no enange in current Regulatory practice is involved.
(1.J.) This position proposes a rewording of the text of IEEE Std 603-1977 concerning recorrendations for testing during power operation. If simply endorsed outright the result-ing provision could not be met. The revised wording in the 1.j. position can be met. No backfitting is recem-mended as no change in current Regulatory practice is involved.
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E. G. Case 4 JUL 41978 l
(l.k.) Section 4.1.10 of IEEE Std 603-1977 is incorrect. In Item (1), prevention of an operating bypass must always be accomplished when permissive conditions are not met.
No backfitting is recomended as no change in current Regulatory practice is involved.
(1.1.) Indication of bypasses in the control room was not dis-cussed in IEEE Std 279-1971. It is covered in IEEE Std 603-1977. This Reg. Position is consistent with Reg.
Guide 1.47. fio backfitting is recommended as no change in current Regulatory practice is involved.
(1.m.) This position concerns automatic removal of bypasses in pro-tective action systems when an accident signal is received.
This is consistent with the provisions of Regulatory Position C.1.b(3) of Reg. Guide 1.108 concerning diesel '
l generator testing. No backfitting is recommended as the administrative controls used to limit the time that bypasses are in effect, on existing plants, 9/ considered adequate.
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(1.n.) This position covers reference to other standards. Back-fitting is not recommended as this is an editorial matter.
(2.a.) This position on requiring identification of safety system equipment is consistent with IEEE Std 279-1971 and is necessitated only by the non-mandatory language in IEEE Std 603-1977. Backfitting is not recommended.
(2.b.) The wording of Section 5.1.l(1) of IEEE Std 603-1977 con-cerning types of alternate channels to be considered is not enforceable as it currently reads. No backfitting is recommended as this is an editorial matter.
(3) This position is a correction of a printing error in the text of IEEE Std 603-1977 in printings prior to October 25, 1977. No backfitcing is recomended since this is an
' editorial matter.
Original ris::e 1 by:
ROBERT 3. :iIIGi;E R. B. Minogue, Director Office of Standards Cevelopment
Enclosure:
Memo from S. H. Hanauer to R. B. Minogue, dated 4/26/78 SD Mail Control No. SD-957-78 Task No. RS 609-5 DIR: DES:SD l .DJR:SD CRESS $mes. .-RSSB:ES:SDlRSSB:ES:SD---..1.......,.,...........l...................j 3 -..p 3--.3. 3. .;;--- g g. 3.z.g z. 3 7.
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E. G. Case 5 JUL21155 bec:
S. Hanauer R. Boyd H. Denton R. Mattson T. Murley V. Stello H. Thornburg T. Ippolito D. Tondi F. Rosa R. Minogue R. Smith G. Arlotto W. Morrison D. Sullivan E. Marinos A. Hintze V. Benoroya R. Scholl S. Varga (45 copies)
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