ML20199L773

Requests Comments,Questions & Concerns Re Listed Proposed Comment Re Fr Notification of NRC Plan to Amend Paragraph (H) of 10CFR50.55(a) to Replace IEEE 279 W/Ieee 603

ML20199L773
Person / Time
Issue date:	11/25/1997
From:	NRC
To:	NRC
References
FRN-62FR53932, FRN-62FR53975, RULE-PR-50 62FR53932-00008, 62FR53932-8, NUDOCS 9712020106
Download: ML20199L773 (1)

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00CXETED From: Admin cjlkanre. gov > (la2fA 539JM USNRC To: WND2 , WNF6 (JLK)

Date 11/25/97 9:56am .DE f. /

Subject Note: Request f or feedback f or making electripogstAP.58 synonymous with protection systems by Tegulatory Rule HyperNews notification. Reply via: OFFC - "c; y http://irm25.nre. gov 86/HyperNews/get/EELB/ Distribution hhtml . ' -u JUX WF Comments / questions / concerns are requested relating to the following proposed comment being developed by EELB. The proposed comment relates to the Federal Register notification of HRC's plan to amend paragraph (h) of 10 CFR 50.55a to replace IEEE 279 with IEEE 603.

The letter from the EDO to the Commission dated September F,, 1997 states the following:

"The Commission considers that the systems covered by IEEE Std. 603-1991 and IEEE Std. 279-1971 are the same. Therefore, for purposes of paragraph (h) of 10 CFR 50.55a, " protection systems," and " safety systems" are synonymous. The Commission notes that these two terms are also synonymous with the term

" safety-related systems," used elsewhere in Commission's regulations. Therefore, licensees.ar6 expected to apply IEEE Std. 279-1971 and IEEE Std. 603-1991, as appropriate, to

" safety-related syr ems. "

It is agreed that systems covered by 603 and 279 are the same; but, what is not clear is how the Commission, for purposes of paragraph (h) of 10 CFR 50.55a, therefore concludes that " protection systems" and " safety systems" are synonymous. Protection systems, as defined by 603, are consider to be one of many safety systems. One of many safety systems, by definition, cannot be synonymous with all (the manyl safety systems; thus, protection systems are not synonymous with safety systems.

The onsite electric power system, the component cooling water system, the residual heat removal system, and many other mechanical and electrical systems, in addition to the protecticn system, are defined as safety systema, by IEEE 603. These mechanical and electrical systems, as specified by 603, are not required to meet the guidelines of IEEE 603,

, However, by inference, if it is stated as part of NRC regulations that protection systems are synonymous with safety systems, then these many otner mee.hanical and electrical safety systems can also be considered synonymous with protection systems and be required to meet 603 requirements; but, since these other mechanical and electrical systems I

are outside the scope of 603 and hava no stated requirements in the g standard, the commistion (by defining the existence of a synonymous =

relationehip between safety systems and protection systems) has added an j unnecessary level of confusion to our regulations and perpetuates a dichotomy between the NRC staff and IEEE. It is recommended that the j proposed rule be revised to remove the synonymous relationship between l- protection systems and safety systems so that NRC's definitions of l safety systems will be the same as IEEE's.

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9712020106 971125 T t I

PDR PR 50 42FRS3932 PDR .

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