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 G 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 Licensing l Enclosure:

As sta Wd d cscr orooor,>0

PART 53

• DOMESTIC LICENSING

OF PRODUCTlION

AND UTILIZATION

FACILITIES (a-0'a,.(3) Those fire protection features.including alternative shutdown capa-bility. involving installation of modifi-cations requiring plant shutdown shall be implemented before the startup after the earliest of the following events commencing

9 months or more after the date of the NRC staff Fire Protection Safety Evaluation Report accepting or requiring such features: (I) The first refueling outage;(i1) Another planned outage that lasts for at least 60 days; or (lii) An unplanned outage that lasts for at least 120 days.(4) Those fire protection features in-volving dedicated shutdown capability requiring new buildings and systems shall be implemented within 30 months of NRC approval.

Other modi-fications requiring NRC approval prior to installation shall be Implemented within 6 months after NRC approval.(e) Nuclear power plants licensed to operate after January 1, 1979. shall complete all fire protection modifica-tions needed to satisfy Criterion

3 of Appendix A to this part in accordance with the provisions of their licenses.AH9 Environmental qualhlcatimf of aLectric equipment Important to safety for nuclear power plants.(a) Each holder of or each applicant for a license to operate a nuclear power plant shall establish a program for qualifying the electric equipment defined in paragraph (b) of this section (b) Electric equipment Important to safety covered by this section I, (1) Safety-related electric equipment" This equipment Is that relied upon to remain functional during and following design basis events to ensure Us) the integrity of the reactor coolant pressure boundary. (ii) the capability to shut down the reactor and maintain It in a safe shutdown condition.

and (ill) the Z capability to prevent or mitigate the r consequences of accidents that could result In potential offslte exposures comparable to the 10 CFR Part 100 guidelines.

Design basis events are defined as conditions of normal operation.

including anticipated operational occurrences.

design basis accidents, external events, and natural phenomena for which the plant must be designed to ensure functions (i) through (iii) of this paragraph.

(2) Nonsafety-relaled electric equipment whose failure under postulated environmental conditions could prevent satisfactory accomplishment of safety functions specified in subparagraphs (I) through (iii) of paragraph (b)(l) of this section by the safety-related equipment (3) Certain post-accident monitoring equipment'(c) Requirements for (1) dynamic and seismic qualification of electric equipment important to safety, (Ul)protection of electric equipment important to safety against other natural phenomena and external events, and (ill) environmental qualification of electric equipment important to safety located in a mild environment are not Included within the scope of this section.A mild environment is an environment that would at no time be significantly more severe than the environment that would occur during normal plant operation.

including anticipated operational occurrences.

I-I II II (d) The applicant or licensee shall prepare a list of electric equipment important to safefj covered by this section. In addition.

the applicant or licensee shall Include the following information for this electric equipment Important to safety in a qualification file: (1) The performance specifications under conditions existing during and following design basis accidents.

(2) The voltage, frequency, load, and other electrical characteristics for which the performance specified in accordance wvith paragraph (d)(1) of this section can be ensured.(3) The environmental conditions.

including temperature, pressure.humidity, radiation.

chemicals, and submergence at the location where the equipment must perform as specified in accordance with paragraphs (d)(1l and (2) of this section.(e) The electric equipment qualification program must include and be based on the following-

(1) Tempemiture and Pressur. The time-dependent temperature and pressure at the location of the electric equipment important to safety must be established for the most severe design basis accident during or following which this equipment Is required to remain functional.

(23 Humidity.

Humidity during design basis accidents must be considered.

(3) Chemical Effects. The composition of chemicals used must be at least as severe as that resulting from the most limiting mode of plant operation (eg.oSpedulc ui dance concernig the type of aniables to be monitored I provided in Revion at Regulatory Guide 1.7. 'letrumentatino for Light-Water Cooled Nuclear Power Plants to Asaes Plant and Environs Conditions During and Followtog an Accident'

Copies of the Regulatory Guide can be obtained froe Nuclear Regulatory Commdisson.

Document Management Branch. Washington.

DC 206s&p.Ia'a containment spray, emergency core cooling. or recirculation from containment sump). If the composition I of the chemical spray can be affected by'equipment malfunctions, the most severe chemical spray environment that results from a single failure In the spray system must be assumed.(4) Radiation.

The radiation environment must be based on the type of radiation.

the total dose expected during normal operation over the Installed life of the equipment.

and the radiation environment associated with the most severe design basis accident during or following which the equipment Is required to remLsa !unctionaL

Including thc radiation resulting from recirculating fluids for equipment located near the recirculating lines and including dose-rate effects.(5) Aging. Equipment qualified by test must be preconditioned by natural or artificial (accelerated)

aging to its end-of-Installed life condition.

Consideration must be given to all significant types of degradation which can have an effect on the functional capability of the equipment If preconditioning to an end-of-installed life condition is not practicable.

the equpment may be preconditioned to a shorter designated lifeIThe equipment must be replaced or refurbished at the end of this designated life unless ongoing qualification demonstrates that the Item has additional life.(6) Submergence (if subject to being ubmerged).

(7) Synergistic Effects. Synergistic effects must be considered when these effects are believed to have a significant effect on equipment performance.

(8) Margins. Margins must be applied to account for unquantified uncertainty, such as the effects of production variations and inaccuracies in test instruments- These margins are in.addition to any conservatisms applied during the derivation of local environzental conditions of the equipment unless these conservatisms can be quantified and shown to contain appropriate margini (f] Each item of electric equipment Important to safety must be qualified by one of the following methods: (1) Testing an Identical item of equipment under identical conditions or under similar conditions with a supporting analysis to show that the equipment to be qualified Is acceptable.

(2) Testing a similar item of equipment with a supporting analysis to show that the equipment to be qualified is acceptable.

(3) Experience with Identical or similar equipment under similar conditions with a supporting analysis to show that the equipment to be qualified Is acceptable.

• C'I 9SAfe:y re l.ed eldeilt- e*!uhpent ig refered lo as Ciu.. s e. ; e.,a;Pa.'r I :.% IME l23...4. Copies of this standard may be obiained fram the heatitUta of Electrical and Electronics Ensinee Inc.. SO East 4.lth StreeL New York, NY 1007.50-24 January 31, 1983 (next page is50-24a)

PN PART 50 0 DOME~TiC LICENSING

OF PRODUCTION

Akrd UTILIZATION

FACILITIES

'.4 (4) AnalysIs, In combination with partial type test data that supports the analytical assumptions and conclusions (C) Each holder of an operating license Issued prior to February 22, 1983. shall, by May 20,1983, Identify the electric equipment Important to safety within the scope of this section already qualified and submit a schedule for either the qualification to the provisions of this section or for the replacement of the remaining electric equipment Important to safety within the scope of this .ection. This schedule must ests-,lish a goal of findl environmertal qualification of the electric equipment within th~e scope of this section by the end of the second refueling outage after March 31.1982 or by Marchs 31.1983.whichever Is earer. The D r of the.Office of Nuclear Reactor Regulatory may grant requests for extensions of this deadline to a date no later than November 30,198I. for specific pieces of equipment if thes. requests are filed an a timely basis and demonstrate good cause for the extension, such as procurement lead time, test complications, and Installation problems.

In exceptional cases. the Commission Itself may consider and grant extensions beyond November 30 1985. for completion of environmental qualification.(h) Each licensee shall notify the Commission of any significant equipment'

qualification problem that may require extension of the completion date provided In accordance with paragraph (g) of this section within So days of its discovery.(i) Applicants for operating licenses that are to be pranted on or after February 22, 193 but prior to November 30.1985. shall perform an analysis to ensure that the plant can be safely operated pending completion of equipment qualification required by this section. This analysis must be submitted to the Director of the Office of Nuclear Reactor Regulation for consideration prior to the granting of an operating license and must include. where appropriate, consideration oh (1) Accomplishing the safety function by some designated alternative equipment if the principal equipment has not been demonstrated to be fully qualified.

(2) The validity of partial test data in support of the original qualification.

(3) Limited use of administrative controls over equipment that has not been demonstrated to be fully qualified.

(4) Completion of the safety function prior to exposure to the accident environment resulting from a design basis event and ensuring that the subsequent failure of the equipment does not degrade any safety function or mislead the operator.Ii I.r (5) No significant degradation of any safety function or misleading Information to the operator as a result of failure of equipment under the accident environment resulting from a design basis event.U) A record of the qualification including documentation In paragraph (d) of this section. must be maintained In an auditable form for the entire period during wHch the covered itern is installed in the nuclear power Cant or Is stored for future use to permit verification that each item of electric equipment important to safety covered by this section-(1) Is qualified for its application and (2) Meets its specified performance requirements when It Is subjected to the conditions predicted to be present when It must perform its safety function up to the end of its qualified life.(k) Applicants for and holders of operating licenses are not required to requalify electric equipment important to safety In accordance with the provisions of this section If the Commission has previously required qualification of that equipment in accordance with 'Guidelines for Evaluating Environmental Qualification of Class IE Electrical Equipment in Operating Reactors November 1979 (DOR Guidelines), or NUREG-o8 (For Comment version).

Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment." (i) Replacement equipment must be qualified in accordance with the provisions of this section unless there are sound reasons to the contrary.Ilife is less than the term requested Where construction of a facility is in-volved, the Commission may specify in the construction permit the period for which the license will be Issued If ap-proved pursuant to 1 50.5. Licenses may be renewed by the Commission , upon the expiration of the period.L 50.52 Combining licenses The Commission may combine in a single license the activities of an appli-cant which would otherwise be 11-censed severally.

r 1 50.53 Jurisdictional limitations.

No license under this part shall be a deemed to have been Issued for activi-" ties which are not under or within the Jurisdiction of the United States.L 0 I 50.54 Conditions of lcenses.notWhth.Whther stated therein or not~, the following shall be deemed conditions in every license Issued:>(a)(1) Each nuclear power plant or tid reprocessing plant licensee subject to the quality assurance criteria in Appendix B of this part shall implemet.pursuant to I 504b)(8)(Il of this part the quality assurance program described or referenced in the Safety Analysis Report. Including changes to that report (2) Each licensee dewced in paragraph (aXi) of this section shalL by June 10. 1983 submit to the appropriate NRC Regional Office shown in Appendix D of Part 20 of this chapter th current description of the quality assurance program It Is implementing for Inclusion In the Safety Analysis Report, unless there are no changes to the description previously accepted by.NRC. This submittal must identify changes made to the quality assurance g program description since th description was submitted to NRC.: (Should a licensee need additional time beyond June 101983 to submit its current quality assurance program description to NRC, It shall notify the appropriate MRC Regional Office In writ explain why additional time is neededL and provide a schedule for NRC approval showing when Its current quality assurance proam desipton will be submitted.)

(3) After March 11. 1963. each license.described In paragraph (a)X) of this section may make a change to a previously accepted quality assurance program description included or referenced In the Safety Analysis I"I U.Z I ISSUANcz, LIMITATIONS, AND CONDI-noNs or LIcENsEs AND CONSTRUcrION

PrITS 050.50 Issuance of licenses and construe.tion permits.Upon determination that an applica-tion for a license meets the standards and requirements of the act and regu-lations, and that notifications, if any, to other agencies or bodies have been duly made, the Commission will issue a license, or if appropriate a construc-tion permit, In such form and contain-Ing such conditions and limitations in-cluding technical specifications, as it deems appropriate and necessary.

50.51 Duration of lIcense. renewal.Each license will be Issued for a fixed period of time to be specified in the license but in no case to exceed 40 years from the date of Issuance.Where the operation of a facility is in-volved the Commission will issue the license for the term requested by the applicant or for the estimated useful life of the facility if the Commission determines that the estimated useful 50-24a January 31, 1983 (next 0age IS0-24 b