ML20205Q441
| ML20205Q441 | |
| Person / Time | |
|---|---|
| Issue date: | 03/18/1987 |
| From: | Arlotto G NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | Zerbe J Committee To Review Generic Requirements |
| Shared Package | |
| ML20204J261 | List: |
| References | |
| FOIA-87-714, RTR-REGGD-1.158, TASK-EE-006-5, TASK-EE-6-5, TASK-RE NUDOCS 8811090237 | |
| Download: ML20205Q441 (5) | |
Text
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Q ucy'o UNITED STATES
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? g NUCLEAR REGULATORY COMMISSION
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MAR 161987 9g MEMORANDUM FOR: John E. Zerbe Acting Chairman Comittee to Review Generic Requirements FROM: Guy A. Arlotto Director i Division of Engineering Safety. RES
SUBJECT:
CRGR REY!EW - REGULATORY GUIDE EE 006-5 "QUALIFICATION OF SAFETY-RELATED LEAD STORAGE BATTERIES FOR NUCLEAR POWER PLANTS" In our memorandum dated December 9,1986, (Beckjord to Sniezek), CRGR 1 approval to issue Regualtory Guide EE 006-5, for public coment was I' requested. Since then, the RES program manager and the three cognizant branch chiefs from NRR have jointly prepared a "Regulatory Analysis" (Enclosure 1) for this proposed guide. Based on their in-depth review of IEEE Std 535-1986, which is endorsed by this guide without any exceptions, they have concluded that this guide does not impose any significant new requirements. The IEEE Standard represents a national consensus on qualification methods to assure reliability, availability and functionality of batteries used in nuclear power plarts. No backfit is involved; only future plants (or operating plant licensees voluntarily comitting to the Regulatory Guide) are affected. The staff has further concluded that this regulatory guide is consistent with current licensing practice.
This regulatory analysis is similar to the one submitted to CRGR on February 3, 1987 (Memo from Beckjord to Sneizek) for proposed Regulatory Guide EE 404-4 (Connection Assemblies), and, since CRGR approved the publi- t cation of Guide EE 404-4 (subsequent to receipt of its regulatory analysis) without an additional CRGR meeting. I suggest that the CRGR consider approving publication of this guide for public coment ithout a formal CRGR meeting.
, [$
Guy A Arlotto. Director Divis n of Engineering Safety Office of Nuclear Regulatory Research
Contact:
Satish K. Aggarwal 443-7840
Enclosure:
As stated cc: W/ Encl.
E. Beckjord H. Denton J. Taylor S. Treby -
g109 37 001007 WEISS87-714 PDR
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4 Regulatory Analysis for Proposed Guide on Oualification of Safety-Related Lead-Storage Ratteries 4
Background:
The Commission's regulations (10CFR Part 50) require that safety-related systems and components in nuclear power plants be designed to accomodate the effects of env'<ronmental conditions (i.e., remain functional during and after postulated seismic and accident conditions) and that design control measures, such as testing, be used to verify the adequacy of design. Section 50.49 to 10CFR Part 50 and Regulatory Guide 1.89 provide requirements and acceptable methods for the environmental qualification of electric equipment.
The environmental qualification of electric equipment in mild environments is not included within the scope of Section 50.49 However, qualification for the mild environment (and the harsh environment) is included in the scope of IEEE Std. 3?'.1974 which is endorsed by R.G.1.89, but component specific guidance is not brovided. During the development of Section 50.49, the Committion concluded that the quality and surveillance requirements applicable to elect. ac equipment (10 CFR Part 50, Appendix B; R.G.1.33 Revision 2) are generally sufficient to ensure adequate performance of safety related equipeent located in mild environnents.
During this rulemaking, the staff was directed to develop regulatory guides for specific electric equipment located in mild environments where additional guidance is needed.
Discussion:
Safetv-related batteries are located in mild environments. Section 3.11 (Page 5) of the Standard Review Plan states the followinq regarding qualification for electric equipment in mild environment:
"The environmental qualification of all electrical and mechanical equiprent located in the mild environnent is acceptable if the following procedure is followed:
The documertation required to demonstate qualification of equipment in a mild environment are the "Design / Purchase" specifications. The specifications shall contain a description of the functional requirements for its specific environmental zone during normal and abnormal environmental conditions. A well supported reintenance/ surveillance program in conjunction with a good preventive maintenance program will suffice to assure that equipment that meets the design / purchase specifica-tions is qualified for the designed life.
Furthermore the maintenance / surveillance program data and records shall be reviewed periodically (not more than 18 months) to ensure that the design qualified life has not suffered thermal and cyclic degradation resulting from the accumulated stresses triggered by the
r abnormal environmental conditions and the normal wear due to its service condition. Engi m ring judgment thall be used to modify the replacement program and/or replace the equipment as deemed necessary."
Seismic qualification of safety-related batteries is covered by Regulatory Guide 1.100 There is no regulatory guide for regulatory document) that describes methods acceptable to the NRC staff for "pre-aging" prior to seismic qualifica-tion of safety-related batteries. However, Section 3.11 (page 4) of the Standard Review Man, dated July 1981, states: "In addition. IEEE Standards 381, 535...
can be used Mr guidance purposes even though NRC has not formally endorsed these standards thro"@ the issuance of a Regulatory Guide."
The staff has accepted voluntary compliance with IEEE Std 535 (all versions) for meeting the Comission's regulations.
Present licensino Status:
- Seismic qualifi';ation of safety-related equipment, including batteries, has been evaluated by . hor against Regulatory Guide 1.100 for the past several i yea rs. During seismic qualification reviews, the NRR staff has noted that some -
kind of pre-aging was donc prior to seismic testing of batteries.
Staff now plans to endorse IEEE Std 535-1986 by a regulatory guide. No backfit is involved; only futcre plants (cr operating plant licensees voluntarily committing to the 4G) are affected. The IEEE Standard represents a national consensus on qualification methods to assure the reliability, availability and functionality of batteries used in nuclear power plants.
1 Although, strictly speaking, the RG does impose a new staff position on new plants, the position imposed essentially codifies existing good practices by the industry and is consistent with the more general guidance provided by the Standard Review Plan.
Analysis of Technical Sections of IEEE Std 535-1986
- 1. Section 5.0 of IEEE Std 535-1986 specified three methods of qualification:
5.1 Type testing t i
5.2 Operating experience 5.3 Analysis supported by test data, operating experience or physical laws of nature.
i These methods, except for (5.3) which permits operating experience or laws of nature as supporting bases, are essentially identical to Section 50.49(f) for equipment located in harsh environments. They are currently acceptable methods of qualification and, as such, do not impose c'>f new requirements.
- 2. Section 5.4 of IEEE Std 535-1986 describes several methods of extending "qualified life." These methods are consistent with IEEE Std 323-1974, which is endorsed by RG 1.89.
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- 3. Section 6 of IEEE Std 535-1986 specifies the infomation which should be included in the test plan for qualification of the battery, e.g.,
installation details, preventive maintenance schedule, electrical data, and qualified life. This information is readily available frca the licensee (s).
4 Section 7 of IEEE Std 535-1986 specifies requirements for the prototype testing of batteries. These are: (1) Test Plan, (2) Test Sequence and (3)
Acceptance Criteria. These are the basic requiremnts for any successful test program for any equipment.
- 5. Section 8 of IEEE Std 535-1986 specifies prescriptive requirements for type tests and analysis procedures. These include accelerated aging procedure, capacity test and discharge test. These tests are described in IEEE Std 450, endorsed by R.G.1.129, and are routinely done in the field (although not for qualification purposes).
- 6. Section 8.3 of IEEE Std 535-1986 deals with seismic testi,ng which is covered by R.G. 1.100. These are prescriptive requirements but do not go beyond the general requirements imposed by R.G.1.100
- 7. Section 9 of IEEE Std 535-1986 deals with documentation. These requirements are consistent with R.G.1.89 and Appendix B of 10 CFR Part 50, and, although somewhat more prescriptive, impose no requirements beyond those implicit in the Comission's regulations.
Impact:
Since IEEE Std 535 was first pubitshed in 1979, the pre-aging prior to seismic testing was not done systematically and strictly in accordance with IEEE Std 535-1979. All three U.S., manufacturers, Exide, C&D and Gould, have since qualified their batterier, in accordance with IEEE Std 535-1979 for use in nuclear powar plants. The cost to each company of testing and pre-aging has ranged from 330,000 t, $180,000 - depending upon the nud>er of prototypes tested, when they are tested, and whether the hatteries were aged naturally or artificiallv. There is no significant difference between the 1979 and 1986 versions of itiEE Std 535 in respect to the "pre-aging" part of the qualification testing.
Conclusion:
Based upon our in-depth review of IEEE Std 535-1986, we conclude that the qualification requirements described in the IEEE standard are based on current industry practices. Further, issuance of this Guide will not result in any imediate additional cost, since all U.S. manufacturers have already cualified their current battery designs.
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We further conclude the requirements of IEEE 535-1986 will satisfy the Comission's regulations with respect to the qualification of safety-related batteries located in mild environments.
x w Satish K. AC.ganval
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Program Manager Engineering Branch, RES J//G/6'?
F. Rosa ,
Branch Chief PAEI, NRR fp' & , fetY b hl
/J. Calvo l Branch Chief PBPE NRR k
E. Mirinos
] f Acting Branch Chief 8WEI, NRR f
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,. I HARMON & WEISS 8001 S ST REET, N.W.
SulTE 430 WAsnIxoTow, D.C. noooo uss SAIL Mc0REEVY HARMON TELEPHONE ELLYN R. WEISS (8039338 3500 OIANE CURRAN OCANA.TOUSLEY AasDREA C. FERSTER Oc tobe r 20, 1987 NcI'OM (F m,cogg4tg ACI REQU681 D of Rules and Records Of fice of Administration U. S . Nuclear Regulatory Commission
/d -M .h Washington, D.C. 20555 RE: Freedom of Information Act Request
Dear Sir / Madam,
Pursuant to the federal Freedom of Information Act, I hereby .
request the following on behalf of the Union of Concerned Scientists:
- 1. All cost-benefit or value-impact analyses done since September,1985 in connection with the consideracion by NRC '
9taff of generic or site-specific backfits.
- 2. Any and all lists, compilations or other identifications of potential generic or site-specific backfits under consid-eration by the NRC staff at any time since September,1985.
- 3. Any and all memoranda or other documents since September i 1985, from the constittee to Review Generic Requirements
('CRGR') containing requests or direction to the NRC staff to perform, modify or reconsider value-impact or cost-benefit analyses regarding any potential generic or site- i specific backfit.
- 4. Any and all documents containing guidance, criteria or examples used by the NRC in deciding which generic or site-specific backfits are appro,Triate for cost-benefit analyses under the backfit rule and which are not so appropriate.
$4l?-ff$5 f I l
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. HAoxoM & WEISS :
Please call me if you have any questtons regarding this request.
Very truly yours, ,
j ddb Ellynh. Weiss BARMON & WBISS 2001 8 Street, N.W.
Suite 430 Washington, D.C. 20009 General Counsel Union of Concerned Scientists I
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