ML20004E378

NRC Staff Responses to Commission 790808 Questions Re Ucs Petition for Reconsideration Re Qualification of Class IE safety-related Equipment

ML20004E378
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Issue date:	05/05/1981
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FOIA-81-97 NUDOCS 8106120113
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Text

'

ENCLOSURE-

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(gov.46 t 's

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RESP 0NSE TO COMMISSION QUESTIONS DATED AUGUST 8, 1979 CONCERNING THE UCS PETITION FOR RECONSIDERA'1I0N I!) order to facilitate a response to the Commissionf questions,"a table comparing IEEE Std. 323-1971 and IEEE Std. 323-1974 has been prepared

~

BVe __

(see -Enci;3u + 1).

This table illustrates the fact that with a few notable exceptions (i.e., aging, margins, and detailed requirements for maintaining documentation) both of these standards address all of the major aspects of equipment qualification.

The principle difference in the two is the level of detail provided in the 1974 version as opposed to the interpretations and judgements required in the implementation of the 1971 version. However, even with its greater detail, IEEE Std. 323-1974 still requires a significant amount of engineering judgement in its implementation especially in the area of aging and margins.

The significant point in these introductory remarks is that neither the 4

1971 version nor the 1974 version of IEEE Std. 323 can be applied effective-ly without guidelines for the necessary interpretations and judgements. It is important to note that in the most recent and current reviews of license applications referencing IEEE Std. 323-1971 the staff is requiring interpretations and making judgements that bri se level of assurance of equipment qualification in these plants to essentially the same level as that which will be achieved in future plants from a literal application of IEEE Std. 323-1974.

These interpretations and judgements are part of L

the continuing process of evolution of equipment qualification requirements l

discussed in NUREG 0413, Appendix A, " Report on the Historical Evolution of Environmental Qualification Requirements for Safety-Related Electrical i

j Equipment."

l 8106120lI3

2 Question !

IEEE Standard No. 323 - 1971 Version a{ How many operating nuclear power plants are not now formally

, comitted to comply with the provisions of this Standard?

b.

What are the advantages to be gained by requiring those facilities to formally comply with the provisions of this Standard? the disadvantages?

c.

Based on the response to I.b. above, if such compliance were required by the Commission, what would be a reasonable schedule for demonstration of such compliance?

Respon_se

,'I )

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$ int

a. h ' 's;< power reactors we. currently licensed to operate with no n

fomal reference to IEEE Std. 323-1971 on their dockets as the basis for equipment qualification.

The specific plants in this category are listed in Table 'I. (attached), a-icag with-an-ident46

,p cat 4orH>f-the-equipe,ent-qualification-regtfirement-upon wh4ch-the I-icense-WaS haorf b.

In order to provide a meaningfull response to this question it must be answered within the context of a consideration of the current j

ongoing staff program to upgrade the qualification of electrical ennya equipment 1n -a4+ operating reactors. This program was outlined 3

for the comission at a briefing on July 11, 1979 to discuss l

the licensee responses to IE Bulletin 79-01. The end result of this program will be a higher levei of confidence in equipment qualification at operating reactors. This higher level of confidence l

l

~

will be achieved by a rigorous component by component reevaluation of existing qualification information and documentation for

,* compliance with a set of guidelines established specifically

- to pmvide a level of confidence essentially equivalent to that which would be achieved from the application of IEEE Std. 323-1974.

Therefore, there is little advantage to be gained from formally requiring compliance with the letter of IEEE Std. 323-1971 since the current ongoing staff program is designed to provide a higher level of confidence in equipment qualification than one would get from a mere backfit of the standard without also specifying guidelines for implementation.

In fact there could even be a

~

certain disadvantage in such an approach in that a backfit restricted to the letter of IEEE 323-1971 would not require consideration of aging or margins, nor would it include any specific requirement to maintain qualification documentation.

c.

The current staff program for upgrading equipment qualification is expected to be completed by Since a simple literal backfitting of IEEE Std. 323-1971 would be less comprehensive than the current pmgram, such a backfitting could be accomplished within the same time frame.

i i

i l

i

Enclowre-4 T A d L E.

l COMPARISON OF IEEE STO 323-1974 AND 323-1971

~

1974 1975

~

1. ! Equipment Specification Detailed requirements General requirements

~

including:

~

a) perfonnance characteristics b) voltage, frequency ranges c) installation d) maintenance e) design life f) control, indication g) environrr.ent h) operating cycle

1) qualified life 2.

Principles of Qualification Detailed requirements General requirements for regarding:

type tests, partial type a) type tests tests and analyses,and b) partial type tests operating experience and analyses c) operating experience d) equipment interface 3.

Documentation Specific and detailed Less specific and requirerrents for diff-detailed with no erent qualification specific requirement methods.

Requirement to maintain documenta-to maintain documenta-tion files tion files.

4.

Type test Qualification Very specific test Brief outline of general Procedure plan, including:

test plan in the form a) mounting of data requirements for:

b) connections a) mounting c) monitoring b) connections d) margin c) monitoring e) test sequence d) test sequence f) aging e vibration g vibration f radiation h radiation g operation i operation h) acceptance criteria j) inspection NOT INCLUDED ARE:

k) acceptance criteria a) aging b) margin c) inspection y

w e y e

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1974 1971 5.

Operating Experience Qualifi-Explained in detail Brief outline of cation Method general procedure in the form of data

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requ,i rements.

6. ; Qualification by Analyses Explained in detail Brief outline of Procedure general procedure in the form of data requirements 7.

On-Going Qualification Explained in detail Hot included Procedure 8.

Simulated Service Condition Description and Not included Typical Test Profile figures showing:

a) margin (additional peak temp., press, and time) b) operation c) pressure and temperature d) time period Appendix A and B (not of the IEEE 323-1974 but included in the Standard as a representative of DBE environmental simulation for PWR, BWR, and HTGR's),

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_uestion II Q

IEEE Standard No. 323 - 1974 Version A

a.[Whataretheadvantagestobegainedbyrequiringoperatingnuglear

power plants to comply with this Standard? the disadvantages?

b.

Based on the response to II.a. above, which specific provisions of this Standard strike a favorable value-impact balance with respect to backfitting considerations?

c.

Based on the response to II.b. above, what would be a reasonable schedule for demonstration of compliance with these provisions?

Response

a.

As stated above, the ongoing s:aff program for reassessing the adequacy of equipment qualification at operating reactors will be based on guidelines which are specifically written to raise the level of confidence that equipment is qualified to essentially the same level that would be achieved by requiring full compliance with the letter cf IEEE Std. 323-1974. Therefore, equipment that is found to be qs tlified in accordanc.e with these guidelines would comply with the intent of all the safety significant aspects of the standard. Nevertheless, requiring full compliance with all provisions of the standard would provide some measure of additional assurance. For example, the application of IEEE 323-1974 would require i. hat a qualified life be established for all safety related equipment, where as the guidelines as now I

written in draft fonn would only require that a specific qu.alified life be established for components using materials know to exhibit degradation with age (e.g., nylon in solenoid valves). Another l

l

.. ~.

2 example would be margins. The standard requires that margins be applied to all test parameters, where as the guidelines would -

[. only require that margins be applied bo the most significant

parameters (e.g., time).

In curry,Te only advantage of requiring operating reactors to comply with the letter of IEEE Std. 323-1974 is some unquanti-fiable additional assurance that equipment is qualified over the reasonable level of assurance that the staff believes will be achieved as a result of its ongoing reevaluation program. The primary disadvantage of backfitting the standard would be an.

unwarranted expenditure of licensee and staff resources to demon-strate compliance with those pmvisions of the standard whick ne1*

no do yield significant additional confidence in equipment quali-3 fication.

In addition, backfitting the standard would extend the date by which the ongoing reevaluation program could be completed and possibly delay the overal upgrading of equipment qualification that the staff program is designed to achieve.

b.

Based on the discussion above, we do not believe that any backfitting W

apart,that which will result from the ongoing staff reevaluation program strikes a favorable value-impact balance. The' provisions of IEEE Std. 323-1974 which are safety significant will be included in the guidelines in a manner in which they can be implemented l

cost effectively. The issue of equipment aging discussed in II.a.

i above is an example of how certain pmvisions of the standard would

[

3-be backfitted.

In is likely that backfitting an aging require.

ment in this manner will require some requalification and that Etherequalificationwillrequiresomeretesting. We believe Ithat this type of backfitting is justified on a value-impact

basis, c.

As stated in the response to question 1.c. above, the ongoing staff program for upgrading equipment qualification is expected to be completed by If a complete backfitting of the letter of IEEE 323-1974 were to be substituted for using the staff guidelines in the program, an additional 1 to 2 years would be required to complete the reevaluation.

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ENCLOSURE

(,

1 g (ErsovEs g

RESPONSE TO COMMISSION QUESTIONS DATED AUGUST 8,1979 CONCERNING

.4 THE UCS PETITION FOR RECONSIDERATION _

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[,

b

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Ik order to facilitate a response to the Commissionf,s questions l.a tatf.e

... t..

s 323-1971 and IEEE Std. 323-1974.has h,-p epaced f,:.

' h

• comparing IEEE Std. .7 % _

I<

e(se: :..;.; wit This table illustrates the fact that with a few notable exceptions (i.e., aging, margins, and detailed requirements for maintaining documentation) both of these standards address all of the major aspects of equipment qualification. The principle difference in the two is the level of detail provided in the 1974 version as opposed to the interpretations and judgements required in the implementation of the 1971 version.

However, even with its greater detail, IEEE Std. 323-1974 still requires a significant amount of engineering judgement in its implementation especially in the area of aging and margins.

The significant point in these introductory remarks is that neither the 1971 version nor the 1974 version of IEEE Std. 323 can be applied effective-

, i.

I,-

ly without guidelines for the necessary interpretations and judgements. It y

is important to note that in the most recent and current reviews of f

('.

7 license applications referencing IEEE Std. 323-1971 the staff is requiring interpretations and making judgements that bring the level of assurance of equipment qualification in these plants to essentially the same level as that which will be achieved in future plants from a literal application of IEEE Std. 323-1974.

These interpretations and judgements are part of the centinuing process of evolution of equipment qualification requirements discussed in NUREG 0413, Appendix A, " Report on the Historical Evolution of Environmental Qualification Requirements for Safety-Related Electrical Equip ent."

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Question !

IEEE Standard No. 323 - 1971 Version How many operating nuclear power plants are not now fonnally a

coranitted to comply with the provisions of this Standard?

b.

What are the advantages to be gained by requiring those facilities to formally comply with the provisions of this Standard? the disadvantages?

Based on the r tsponse to I.b. above, if such compliance were c.

required by the Commission, what would be a reasonable schedule for demonstration of such compliance?

Response

- - ---tP-power reactors are currently licensed to operate with no f*

a.

. YJnU U 'g <}

femel reference to IEEE Std. 323-1971 eW:E d::k:ts as the

,c.

in this f

~Lj d.

basis for equipment qualification. The :p::i'i: plant:

nMd L. adied's akn; #.th an identifi,-

d "

---catecery :re 1Me cation-o?-de-equip cnt qvcW4cptien-requkenent-epea which-the q 7.J '

Liccase w: W ad--

b.

In order to provide a meaningfull response to this question it must be answered within the context of a consideration of the current ongoing staff program to upgrade the qualification of electrical t.h e-,g equipment,in aM operating reactors. This program was outlined for the convnission at a briefing on July 11, 1979 to discuss the licensee responses to IE Bulletin 79-01.

The end result of this program will be a higher level of confidence in equipment qualification at operating reactors. This higher level of confidence

QuestionII IEEE Standard No. 323 - 1974 Version

a.,What are the advantages to be gained by requiring operating nuclear power plants to comply with this Standard? the disadvantages?"

b. ' Based on the response to II.a. above, which specific provisions of this Standard strike a favorable value-impact balance with respect J

to backfitting cunsiderations?

Based on the response to II.b. above, what would be a reasonable c.

schedule for demonstration of compliance with these provisions?

Response

As stated above, the ongtseg staff program for reassessing the a.

adequacy of equipment qualification operat'ing reactors will be aA-

~% _

based on guidelines which are g e 't ally ~ft w +

4 ~ thr 4

level c',c"'4dene that equipment is qualified to essentially

'.w the same level that would be achieved byirequiring MW compliance 4

w M *% lotter-of IEEE Std. 323-1974,.

Therefore, equipment that is found to be qualified in accordance with these guidelines m-4 would comply with the intent of all theqafety significant a

D f

aspects of the standard.

R. Cont. kequiring full compliance d-4 - Al with all provisions of the standard woutd provide some measure f

of additional assurance.

For example, the application of IEEE 323-1974 would require that a qualified life be established for all safety related equipment, where as the guidelines as re 1 - r--k-i pu ~A l

0 l

wr44teMr. draft-h would only require that a specific qualified life be established for components using materials know to exhibit degradation with age (e.g., nylon in solenoid valves).

Another l

l t

example would be margins. The standard requires that margins be applied to all test parameters, where as the guidelines would f only require that margins be applied o the most significant ".

.1 parameters (e.g., time).

~

4r. Or:ry, the only advantage of requiring operating reactors to conply with the letter of IEEE Std. 323-1974 is some unquanti-fiable additional assurance that equipment is qualified over the reasonable level of assurance that the staff believes will be

,, j f e

achieved as a result of its ongoing reevaluation program. The

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W primary disadvantage of backfitting the standard would be an

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i unwarranted expenditure of licensee and staff. resources to demon-

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strate compliance with those provisions of the standard whick

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no do yield significant additional confidence in equipment quali-

/

s fication.

In addition, backfitting the standard would extend the

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date by which the ongoing reevaluation program could be completed I

and possibly delay the overal upgrading of equipment qualification that the staff program is designed to achieve.

b.

Based on the discussion above, we do not believe that any backfitting W

apart,that which will result from-the ongoing staff reevaluation program strikes a favorable value-impact balance.

The provisions 1

l of IEEE Std. 323-1974 which are s7Eg;ty significant,will be included i

in the guidelines in a manner in which they can be implemented cost effectively.

The issue of equipment aging discussed in II.a.

above is an example of how certair, provisions of the standard would I

3-be backfitted.

In is likely that backfitting an aging require-ment in this manner will require some requalification and that !

the requalification will require some retesting. We believe 5

. phat this type of backfitting is justified on a value-impact b& sis, c.

As stated in the response to question I.c. above, the ongoing staff program for upgrading equipment qualification is expected

w. ur a-s c winM4ackfitting.y*W, ds.

to be completed by pI;M.:_

N I.I If a of-thed : - '- n f I E EE 323-1974 were to Se :Mtituted fer uset d..d \\

r the staf' psd(44nehragre, an additional 1 to 2 years.

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mid be i cyw ired w wwpie;e th:

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GBcW O

TASLi l

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COMPARISON OF IEEE STD 323-1974 AND 323-1971

~

1974 1971

'? c E,L--14d requirements Geraral @ements

.e

1.. Equipment Specification

~

including:

a) performance characteristics b) vo.1tage, frequency ranges c) installation d) maintenance e design life f control, indication g environment h) operating cycle

1) qualified life 2.

Principles of Qualification bSI 2 requirements General re d s.ents for re type tests, partial type a)garding:

type tests tests,and analyses,and b) partial type tests operating experience and analyses c) operating experience d) equipment interface 3.

Documentation Specific and detailed less specific and requirements for diff-detailed with no erent qualification specific requirement methods.

Pequirement to maintain documenta-to maintain documenta-tion files tion files.

4.

Type test Qualification Envy 6/pecific test Bric?.stiine of general Procedure plan, including:

test plan in the form a) mounting of data requirements for:

b) connections a) mounting c) monitoring b connections d) margin c monitoring e test sequence d test sequence f aging e) vibration f) radiation g) vibration g) operation h radiation i) operation h) acceptance criteria j) inspection NOT INCLUDED ARE:

k) acceptance criteria a) aging b) margin c) inspection i

r n

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' 1974 1971 5.

0;erating Experience Qualifi-E91ained4n-dete41 Briefautline of

'fp.[-

(general'. procedure in cation Method the' form of data requirements.

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6. ' Qualification by Analyses hplaihed f a detail

-!irnrf. outline of

, Procedure cgeneral.procedurein tne torm of data requirements

%,.p-

.EmphLcd 'ir. detail Not included 7.

On-Going Qualification Procedure 8.

Simulated Service Condition Description and

.Not included Typical Test Profile figures shewing:

a) margin (additional peak temp., press, and time) b) operation c) pressure and temperature d) time period Appendi,xAandBInot/dfthe

~

I!EEE328-19FbuIinclude #p fp t:84 Staidard as/a represen}ative df lJWR,L3WR,pJnd'HTGRis)3 LDBE gnvIro' m tal sidulatl ion for i

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9 Ctestien I:

d IEEE Standard No. 323 - 1974 Versien What are the advantages to be,cained by requiring operating nuclear a.

pcwer plants to cc.r '.

ith tc.is Standard? Tr.e disadvantages?

b.

Based on the respense tc 11.3. above, wh'ch specific provisions of this Standard strike a favora31e value-imcact balance with respect to backfitting considerations?

Based on the response to II.b. above, what would be a reasonable schedule c.

for demonstration of ccmpliance with these provisions?

Response

As noted above, the staff pecgram for reassessing the adequacy of equipment qualification at operating plan;s will be based on guidelines which closely follow the require _ments of IEEE-722-1974. Therefore, equipment tha,t is found to be qualified in accordanct -

tr.ese guidelines should comply with most as-pects of that Standard. Nevertheiess, requiring that operating plant comply fully with all requirements of ::. standard would provide further assurance that

, equipment is adequately qualif;c_. Specifically, the application of this standard to operating plants *.:ould require a more rignorous and complete camonstration that aging effects r:rs adequately accounted for. The qualified

~

life of all the equiphent would te established.

Further, the margins to be applied to test paramatars would 55 determined more conservatively.

The prihary disadvantages of forcir.g compliance with IEEE-323-1974 is that many Licensees will required to re est some fraction of their equipment to comply

.. with the aging requirement.

Scra retesting ray tisc 53 required to ccrply with more conservative application of the margir. req:;iremants.;.

c Ne believe that neither the aging nor the margin requirements of IEEE-323-1974, when compared to the guidelines to be used in the upccabing staff reassess. rent, warrent backfit consideration. While requiring compliance with these requirements would provide some additional assurance regarding the adequacy of qualification, the benefit is marginal.

The staff guidelines mentioned above w1 1 require that aging be considered for that equipment identified as being suseptable to aging effects (e.g.

).-

?

We believe that approach is adequate for the present We are now reviewing operating license applications for plants already complying with the 1974 version of the standard and therefore we are assessing aging data for electrical equipment generally. As that review process proceeds and our understanding of aging effects improve, we will reassess the need for further backfitting the aging requirements.

With regard to margin, we believe that the application of tne staff guidelines to operating plants will ensure that sufficient margins have been applied during qualification testing. More conservative margins would probably be required i

if the qualification data were being reviewed agaid the 1974 Standard since those decisions will establish a president for similar decisions yet to be made on operating lisence applications where compliance with the standard and is already required. We believe this added conservatism is unnecessary.

l I

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. In summary, full compliance with the standard would recuire sor$e additional 2

.* testing by the licensees the extent of which we are unable to', assess at this time.

In our judgement, the benefit to safety of such testing is marginal and is rat worth the cost.

s.

While, as we noted above, there is marginal benefit to backfitting either

~

the margin or aging requirements of the 1974 version of the standard, we

~.

believe compliance with the standard could be demonstrated in 2 to 4 years given there are adequate test facilities available during that time.

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ENCLOSURE g g7,v.0E0VZ s

RESPONSE TO COMMISSION QUESTIONS

. i DATED AUGUST 8,1979 CONCERNING THE UCS PETITION FOR RECONSIDERATION f

-\\

C In order to facilitate a response to the Commissionf questions, 'a table co'mparing IEEE Std. 323-1971 and IEEE Std. 323-1974 has been prepared

~ 3 /c (see Ocb5 u. u-1).

This tat,le illustrates the fact that with a few notable exceptions (i.e., aging, margins, and detailed requirements for maintaining documentation) both of these standards address all of the major aspects of equipment qualification.

The principle difference in the two is the level of detail provided in the 1974 version as opposed to the interpretations and judgements required in the implementation of the 1971 version.

However, even with its greater detail, IEEE Std. 323-1974 still requires a significant anount of engineering judgement in its implementation especially in the area of aging and margins.

3.

~

j..

n-The significant point in these introductory remarks is that neither the 1971 version nor the 1974 version of IEEE Std. 323 can be applied effective-ly without guidelines -for the necessary interpretations and judgements. It is important to note that in the most recent and current reviews of license applications referencing IEEE Std. 323-1971 the staff is requiring interpretations and making judgements that bring the level of assurance of equipment qualification in these plants to essentially the same level as V

that which will be achieved in future plants from a 14teret application of IEEE Std. 323-1974.

These interpretations and judgements are part of the continuing process of evolution of equipment qualification requirements discussed in NUREG 0413, Appendix A, " Report on the Historical Evolution of Environmental Qualification Requirements for Safety-Related Electrical Equipment."

. Question I IEEE Standard No. 323 - 1971 Version a.'- How many operating nuclear power plants are not now forma"v -

comitted to comply with the provisions of this Standard?

b.

What are the advantages to be gained by requiring those facilities to fomally comply with the provisions of this Standard? the disadvantages?

c.

Based on the response to I.b. above, if such compliance were required by the Comission, what would be a reasonable schedule for demonstration of such compliance?

Response,

. s.

~~

,.! )

y;.g s

a.x

' power reactors ace. currently licensed to operate eth no fomal reference to IEEE Std. 323-1971 on their dockets as the basis for equipment qualification.

The specific plants in this category are listed in Table 'l (attached).ahng ith-an-4 dent +fb cation of the-equipmentplification requirementmpon which the l

14 cense-was-bx ed-l b.

In order to provide a meaningfull response to this question it must be answered within the context of-ar-contiNration of the current ongoing staff program to upgrade the qualification of electrical l

p % 3h equipmentJin aM operating reactors. This program was outlined for the comission at a briefing on July 11, 1979 to discuss l

the licensee responses to IE Bulletin 79-01. Tte end result of this program will be a higher level of confidence in equipment qualification at operating reactors. This higher level of confidence

will be achieved by a ripec= compone t by compo$ent reevaluation of existing qualification information and documentation for l

[ compliance with a set of guidelines established specificaliy '.

, to provide a level of confidence essentially equivalent to that which would be achieved from the application of IEEE Std. 323-1974.

Therefore, there is little advantage to be gained from fonnally f'

T.,

requiring complience with ti.; 1;;;ci of IEEE Std. 323-1971 since the current ongoing staff prograiis designed to provide a hibbed le,el of confidence in equipment qualification than one would get from a mere backfit of the standard without also specifying

n. c.

.R. :,..;

guidelines for implementation.

In fact.there could even be a certain disadvantage in such an approach in that a b ckfit restricted

~

to.the-letter of-IEEE 323-1971 woula not require consideration of aging or margins, nor would it include any specific requirement

,,4 to maintai,n., qualification documentation.

.s c.

The current staff program for upgrading equipment qualification is

.J expected to be completed by Since a-c pi r

/

14Wral backfitting of IEEE Std. 323-1971 would be less comprehensive than the current program, such a backfitting

.9Lf could be accomplished within the same time frame.

2

'O O l

Enck erc =1 TASLE l

COMPARISON OF IEEE STD 323-1974 AND 323-1971

,1974 1971:

1.

Equipment Specification Detailed requirements Genehalreq ements including:

a) perfennance characteristics b) voltage, frequency ranges c) installation d) maintenance e) design life f) control, indication g) environment h) operating cycle

1) qualified life 2.

Principles of Oualification Detailed requirements General requirerents for regarding:

type tests, partial type a) type tests tests,and analyses,and b) pa/

al type tests operating experience and analyses c) operating experience d) equipment interface 3.

Documentation Specific and detailed Less specific and requirements for diff-detailed with no erent qualification specific requirement methods.

Requirement to maintain documenta-to maintain documenta-tion files r, %.,,

tion files.

... ;J w _ _

Bhih ut1"ine f 'eneral 4.

Type test Qualification Very specific test 9

Procedure plan, including:

test plan in the form a) mounting of data requirements for:

b) connections a) mounting c) monitoring b) connections d)v.argin c) monitoring e) test sequence d) test sequence f) aging e) vibration g vibration f) radiation h radi." tion g) operation i operntion h) acceptance criteria j) inspection NOT INCLUDED BRE:

l k) acceptance criteria a) aging b) margin f

c) inspection l

l

1974 1971 5.

Operating Experience Qualifi-Explained in detail Brief outline of cation Method genetal procedure in the form of data requirements.

6.

Qualification by Analyses Explained in detail Brief outline of

-Procedure general procedure in the form of data requirements 7.

On-Going Qualification Explained in detail Not included Procedure 8.

Simulated Service Condition Description and Not included Typical Test Profile figures showing:

a) margin (additional peak temp., press.

and time) b) operation c) pressure and temperature d) time period Appendix A and B (not of the IEEE 323-1974 but included in the Standard as a representative of DBE environmental simulation for PWR, BWR, and HTGR's).

I e

I i

l I

- -. + +

QuestionII IEEE Standard No. 323 - 1974 Version

,?

A

~

a. 'What are the advantages to be gained by requiring operating nurlear

,ower plants to comply with ;his Standard? the disadvantages?

p b.

Based 'on the response to II.a. above, which specific provisions of this Standard strike a favorable value-impact balance with respect to backfitting considerations?

c.

Based on the response to II.b. above, what would be a reasonable schedule for demonstration of compliance with these provisions?

s

Response

.'....: At.q %& h ', W.:....

~

a.

As stated'above, the ongoing staff program for reassessing the adequacy of equipment qualification at operating reactors will be based on guidelines which are specifically written t Ils'NN6f-b level of confidence that equipment is qualified to essentially the same [eMhIt would be achieved by requiring 444-compliance c, -

with the= tere +cof. IEEE Std. 323-1974.

Therefore, equipment that is found to be qualified in accordance with these guidelines would comply with the intent of all the safety significant aspects of the standard. Nevertheless, requiring full compliance with all provisions of the standard would provide some measure of additional assurance.

For example, the application of IEEE 323-1974 would require that a qualified life be established for all safety related equipment, where as the guidelines as now written in draft form would only require that a specific qualified life be established for components using materials know to exhibit m.h.:

~.

degradation with age (e.g., nylon in solenoid ~ valves). Another

o.,

example would be margins.

The standard requires that margins be applied to all test parameters, where as the guidelines would.'

i 2only require that margins be applied bo the most significant

. parameters (e.g., time).

Ir. Ou-ry,Te only advantage of requiring operating reactors

%..11o-_,

to'.compTy s'ith the__lattee-of IEEE Std. 323-1974 is some unquanti-h-5 C fiable additional,afsurance that equipment is qualified over the

, e. r. L-s

• J /

' re:MWievel of assurance that the staff believes will be

,x achieved as a result of its ongoing reevaluation program.' 'The primary disadvantage of backfitting the st,andard would be an unwarranted expenditure of licensee and staff resources to demon-strate compliance with those provisions of the standard whick l, F T.

.... ' d neD

• ask,de} yield significant additional confidenceh,equTpment,quali-

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fi[it. ion.

In additili6' b~ackfTt'tiWf, tee'sfaWdaFdh_uld extend' the.4f

-^

date by which the ongoing reevaluation, prog. ram could be complete.d,

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and possibly delay the avt ral upgrading'oT,equipiFnUM'is' that the staff program is designed to achieve.

l b.

Based on the discussion above, we do not believe that any backfitting

&~~~

apart,that which will result from the ongoing staff reevaluation program strikes a favorable value-impact balance. The provisions of IEEE Std. 323-1974 which are safety significant will be included in the guidelines in a manner in which they can be implemented A

,.......w.

- cost. effectively.The issue of equipment aging discussed in II.a.

l above is an example of how certain pitvisions of the standard would l

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q 3-be backfitted.

In is likely that backfitting an aging require-AJ

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ment in this manner will require some requalification aM-that-4

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Qe.requ... :alification will require some gatestig. We believe

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that this typs of backfitting is justified on a value-finpact basis.

As stated in the response to question I.c. above, the ongoing c.

staff program for upgrading equipment qualification is expected to be.c wpleted by If r complete backfitting of the-httee46 IEEE 323-1974 were to be substituted for using the staff guidelines in the program, an additional 1 to 2 years would be required to cceplete the reeval::ation.

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f RESPONSE TO C0!NISSIONER KENNEDY'S QUESTIONS

\\

DATED AUGUST 8, 1979 CONCERNING

[

THE UCS PETITION FOR RECONSIDERATION J/

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[

I.

IEEE Stanc'ard No. 323 - 1971 Version In order to facilitate a response to questions I & II, a table comparing IEEE Std. 323-1971 and IEEE Std. 323-1974 has been prepared (see Attachment).

This table illustrates he-fact that with a few notable exceptions (i.e., aging, margins, and detailed requirements for maintaining documentation) both of these standards address all of the;.-

major aspects of equipment qualificatien. Theprincihedifferencein -

the two is the level of detail provided in the 1974 version as opposed to the interpretations and judgements required in the implementation of the 1971 version.

However, even with its greater detail, IEEE Std. 323-1974 still requires a signif.icant amount of engineering judgement in its implementation especially in the area of aging and margins.

The significant point in these introductory remarks is that neither the 1971 version nor the 1974 version of IEEE Std. 323 can be applied effective-It ly without guidelines for the necessary interpretations and judgements.

isimportanttonotethatinthe@st@c=t=[currentreviewsof

^

license applications referencing IEEE Std. 323-1971 the staff is requiring interpretat ons and making judgements that bring the level of assurance of equipment qualification in these plants to essentially the same level as that which will be achieved in future plants from an application of i

O

~.,

,m

2-IEEE Std. 323-1974. These interpretations and judgements are part of the continuing pmcess of evolution of equipment qualification rehuire-

.a ments discussed in NUREG 0413. Appendix A. " Report on the Histori' cal Evolution of Environmental Qualification Requirements for Safety-Related Electrical Equipment."

Question a How many operating nuclear power plants are not now formally committed to comply with the provisions of this Standard?

Response

Fiftyeight of the 70 power reactors currently licensed to operate (including Indian Point 1 and Humboldt Bay) have no specific reference to IEEE Std. 323-1971 as the basis for equipment qualification. bA d~ Egj '

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.A A )~

t~% L%

What are the advantages to be gained by requiring those facilities to fomally comply with the provisions of this Standard? the disadvantages?

Response

In order to provide a meaningfulh} response to this question it must be answered within the context of the current ongoing staff program to upgrade the qualification of electr' cal equipment in all operating reactors. This program was outlined for the Commission at a briefing on July 11, 1979 to discuss the licensee responses to IE Bulletin 79-01. The end result of this progran will be a higher level of confidence in equipment qualifica-tion at operating reactors. This higher level of confidence will be achieved by evaluating existing qualification infomation and documentation for compliance with staff guidelines to be established. These guidelines

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o. will provide a level of confidence essentially equivalent to that which would be achieved from the application of IEEE Std. 323-1974 i dich is more stringent than the earlier version of the standard. 1 N' / r 4 , \\ &...%, Therefore, there is little advantage to be gained from limiting ,/ (4 compliance to IEEE Std. 323-1971. The current staff program is intended to provide a higher level of confidence in equipment quali-fication than one would get from the standard alone without also specifying guidelines for implementation. In fact there would be a f disadvantade i'n'that IEEE 323-1971 does not require consideration of aging or margins, nor would it incli je any specific requirement to 0,CAcyk maintain qualification documentatie.1; all of which will be included 4 in the staff's guidelines. _uestion c Q Based on the response to I.B. above, if such compliance were required by the Commission, what would be a reasonable schedule for demonstration of such compliance?

Response

l The current staff pr'ogram for reevaluating. equipment qualification is 5,, expected to be completed by April 1981 Since the requirements of (~.- ./ -~. ~4 IEEE Std 323-1971 are e'ss comprehensive than the staff's guidelines, a reevaluation using this standard could be accomplished within the same time frame. ~ ^ 's .jsat the Commission-briefing on July 11, 1979, referred to in response to ' question a. above, the staff stated that the reviews of licensees responses to IE Bulletin 79-01 for compliance with the staff guide-Tines being prepared could be completed by March 1980. As a result l j of subsequent work in connection with preparing the guidelines the staff has determined that April 1981 is a more realistic estimate. .) j s

11. IEEE Standard No. 3:3 - 1974 Version _ ~ Question a_ Wge ' are the advantages to be gained by requiring operating nuclear power plants to comply with this Standard? the disadvantages?

Response

As noted above, the staff program for reassessing the adequacy of equipment qualification at operating plants will be based on guidelines which closely follow the requirements nf IEEE 323-1974. Therefore, equipment that is found to be qualified in accordance with these guidelines should comply with most aspects of that Standard. Nevertheless, there are advantages to requiring that operating plants comply fully with all requirements of the 1974 standard. Specifically, the application of this standard to operating plants would require a more rigo ous and complete demonstration that aging effects were adequately accounted for and the establishment of a qualified life of all safety related equipment. Further, margine would be applied to all test parameters whereas the guidelines would require only that margins be applied to the most significant parameters (e.g., time). Implementation of both the margin and aging requirements would result in a somewhat hioher level of assurance of the adequacy of qualification. The significant disadvantage of requiring licensees with operating pla;.ts to comply with IEEE 323-1974 is that many licensees will be required to retest some fraction of their Some retesting equipment to comply with the aging requirement. may also be required to coinply with more a conservative appitca-tion of the margin requirements. Where testing is not required, y -r-.__. ,-y-, ,.g.,--, ., - + -

compliance may also be demonstrated by analysis. In either n.e. signi'icant licensee and staff resources would be required tof s } implement these provisions and review the documentation. In ~ addition, backfitting the standard would extend the date by which the ongoing reevaluation program could be completed and possibly delay the over:nl upgrading of equipment qualification that the staff program is designed to achieve. Question b Based on the response to II.a. above, which specific provisions of this Standard strike a favorable value-impact balance with respect to backfitting considerations?

Response

We believe that neither the aging nor the margin requirewnts of IEEE 323-1974, when compared to the draft guidelines to be used in the upcoming staff reassessment of operating plants, warrant backfit consideration. The benefit of backfitting either the aging or the margin requirements of the 1974 Standard is a srtall, unquan-tifiable increase in the level of atevrance that equipment is qualified. Yet the costs, in terms of manpower, the testing required to impl'ement these provisions, and the possible delay in the staff review effort may be significant. The staff guidelines mentioned above will require that aging be considered, but only for that equipment identified as beir., s,.e.!?e w susceptibl'e to aging effect;. We believe that approach is g

e. a adequate for the present. We are ser reviewing operating applications for plants already required to comply with the e-

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C' k# v 0.( 1974 version of the stan 6 rd and therefore we are assessing, a d,)y 4 i aging data for electrical equipment generally. As that V. :. ; ' Y; e review process proceed:, and our understanding of aging effects improve, we will reassess the need for further backfitting the aging requirements. With regard to margin, we believe that the application of the staff guidelines to operating plants will ensure that adequate margins have been applied during qualification testing. We believe that the more conservative application of margins required by the 1974 Standard, while appropriate for plants yet to be licensed, is unnecessary for operating plants. Question c Based on the respense to II.b. above, what would be a reasonable schedule for demonstration of compliance with these provisions? ftESp0NSE p *. We believef compliance with the 1974 version of the standard could be demonstrated idte 4 veass given there are adequate test facilities available,during that time. a ggy' ulef p"l9ll ,c tj t y W/ P' i y. ),(, / s [0W 'JA p3' ,, :0!{ { bl f *,

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NUCLEAR REGULATORY COMMISSION g* -(,,f j W ASHINGTON. D. C. 2 CMS { ' (.,#f f i i

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6 J' Dat Qual. Standard Applicable OL Is ued (None IEEE 323-1971. IEEE 323) )0CKET NO. FACILITY 'ower Reactors i 50-155 Big Rock Point T[(,7 ( pol) 5'[4 t/@7o L. ) fM 7/'Il(POL) I 00( Nh .f E0-10 Dresden 1 lyG%Pok) i0-237 h Dresden 2 7/(p3 (pol 50-244 Ginna r-/7 y(Frot) /.o[Of(p o( } l 50-213 Haddam Neck 7/67(Po '7 50-409 La Crosse go/70(T*oL[- 50-245 Millstone 1 gg,g (poc,% 50-219 Oyster Creek 3/7((Foc-[ 50-255 Palisades 3 47 Qe t.[ 50-206 San Onofre 1 g 6/ (;,[(p TO L. 50-29 Yankee Rowe N \\ s%. ~ Am LFfC 7 L2 - All ~ ' r Y. b

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P/2 l rna c c,,. n -- a Date Qua Standard Applicable ? Plant & Doc. No. OL Issued (W IEEE 323-1971, IEEE 323).l37 e, a z i.G. 3 ?3- \\9,1 1 l-30-7s caver va11ey 1 Sn.334 ock 1/2 50-315/316, I0-25-74 ME!TlM ~~ rd :.!TRN.R . a rl ey 1 50-348 G -S-77 ~ ~//

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lndian Pointer /2 E27/247 ,10 71 N 5 C~I ' EmK (2.-l3.~78 indian Point 3 50-286 l3.-3I-73 METN I Kewaunee 50-305 tdEiT!4ER Point Beach 1/2' 50-266/301 !O 5-70, 2 'I-7J .st E. i rs t Prairie Island 1/2 50-282/306 E.9-7.2, > o '.'9-x'/ ?obinson 2 50-261 7.3! 'l

) c,1,].(r p T_-1._. ~ lf. '.. - ; ? ? i 2. ~i- ? ~ h Salem 1 50-272 tJ '.G6 E'-,

@urry 1/2 50-280/281 ' - E S ,d II" 2 I-76 l EE.E ~'. 21 ~ i S I I ~~ Trojan 50-344 N 5 i TV O-Turkey Point 3/4 50-250/251 7 [$ ' Zion 1/2 50-295/304 y f3) ll-14 -74 blEITelEE, ~ I ~

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d fu.g I ' E') ( pu irm 23 , N U~>% ~ L 2nc\\ ' [ Date Qual. Standard Applicable Plant & Doc. No. OL Issued (None,IEEE 323-1971 IEEE 323F /97y,'

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( ~ N JY eJ v Ca g **,, / 9 ~ \\ g* te Qual. Standard Applicable 3 Plant & Doc. No. OL ssued (None,IEEE 323-1971, IEEE 323)-l )~17/ 2 - o / f.ty c 3-:..? ^ h :/C q.4 - 2 o . r-d ' p,. :;~ 1.,. 4 =v~- s ~:;:. { ?> - E; ? = v.' .. i; ;

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01. Issued (None,IEEE 323-1971,IEEE323)

,s., M\\. e.. n 3rowns Ferry 1 259 05-26-73 None (comply with IEEE-279) Browns Ferry 2 260 06-28-74 None (comply with IEEE-279) \\ ' Browns Ferry 3 296 07-02-76 None(complywith15EE-279) Brunswick}-50-325 09-08-76 IEEE 323 (Amendment 13 M7.2-3) Brunswick 2 324 12-27-74 IEEE 323 (Amendment 13 M7.2-3)

• Cooper 298 01-18-74 No standard - Qualification discussed throughout FSAR, no direct statement IEEE-279, None-D-3 was evaluated against,itted" t Dresden 3 240 01-12-71 but plant is not " formally comm to comply (the question asked'by Comissioner Kennedy)
• Duane Arnold 331 02-22-74 None (Comply with IEEE-279)

\\ FitzPatrick 333 10-17-74 Intent of IEEE-323 ' Hatch 1 321 08-06-74 No.Istd SER p7-4 (general discussion of rod qualification) Hatch 2 366 06-13-78 IEEE 323 - 1971 (SER p 3-23)

• Menticello 263 09-08-70 None (partial compliance witn IEEE-279 which was in draft form at time Monticello constructed)

\\ Nine Mile Point 220 08-22-69 No standard used Pilgrim 293 '06-08-72 None (Q 7.1.5 and 7.1.6) Amend 18 Peach Bottom 2 277 08-08-73 no specific std, SER p 80 states capabili-under post-accident T, P, humidity are acceptable k Peach Bottom 3 278 07-02-74 no specific std, SER p. 80 states'capabil-l under post-accident T, P, humidity are acceptable Quad Cities 1 254 10-01-71 None - QC 1/2 were evaluated against IEEE-279 & 308, but plants are not committed to comply i had Cities 2 265 03-31-72 .None-QC 1/2 were evaluated against IEEE-279 & 308, but plants are not I committed to comply Jermont Yankee 271 03-21-72 no std - see SER p. 42 6/1/71 4umboldt Bay 133 08-28-62 no std.

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(* deno es significant differences) 1. Temperature ar.d Pressure Service Conditions i GL: For LOCA, accepts the analysis in the FSAR 6 46 h t; b b' b o - Tut L.A. IP: Requires the use of specific codes id For MSLB, uses best estimate approach on a typical plant p w GL: A-It Q h xa. W 4 J.k. J.xh :.ebh M wsd. 6Requires the use of specific codes and uses a best estimate IP: approach on the specific plant. 2. Radiation Identifies acceptable methods and sample calculations for IP: deterr.ining dose and wi,1Levaluate-on a case basis. 7 Assumes a upper bounding dose of 2 X 10 rads for inside containment GL: (for LOCA) and 2 x 100 rads for a (MSLB) and provides scaling factors to further reduce the values. ' flu + U Does not require Beta radiation environments be addressed durin d GL: qualification j Requires that Beta radiation bedddresseiRduring qualification or IP: justification be provided excluded from qualification. L} a6e:3. n.kh g 3. Test Duration R0 quires that the applicants define operability duration. IP: Requires that testing should be performed for as long as it takes GL: for the temperature and pressure conditions to reach the same levels as before the accident. 4. Test Sequence Recomends a specified order and requires the sequence to be justified IP: if different from the preferred method. bnot address any sequencTbut allows radiation to be conducted GL: any time as long as the same specimen is used during the test IM ; m b.k.n sequence. w AJL % N ,f.,,y.(,j-M % wm t. g,",, h 4... dn

e. n' W

l n p 5. Margin IP: Provides specific guidance. ~ GL: Does not require any margins _beyond the test duratrion re uiremen3 M ~W ~ & '. n v s.h;g & } he dN 6. Submergence. ,n If the equipment is submerged, it murt be qualified by# :4' +,u ) test. IP: GL: Pennig analysis. [ M M 7 7. Caustic Sprays p Provides specific guidelines for test and when using / analysis. IF: GL: On4y Jdentifies that equipment should be qualified for the most severe environment lapHes that only. analysis is -required. IW utWE [ 8. Qualification Outside Containment ,q Assumes that for these areas if the equipment is designed anc installed Ic 5'" 'k." GL: . 1 M- &, M, using codes such as ANSI, NERA, Electric codes failure f. p [#,' ,.r I + L ,.+- y " IP: Requires qualification, preferrably by test byt will accept analysis, s p. operating history, etc. Also provides requirements for monitoring . *g...d,(

• the environmental conditions at the specified locations, j

yQ h &;Q \\ .~' V 9. Qualification Test c

4. - / 'l ',.

e f' N f (p i'h*~g he GL: Addresses vendor certification. 3 IP: Provides specific guidance when and how testing should be performed.

10. Failure Criteria s

IP: Does not address this issue. t GL: Dee:; n o t all e., oisi Tailurn ei asia L6. [dple 4 A;d , [l l' k ' w om -Ja.ap,o/gn'r 3,9-M D

11. Aging

/ I, GL: Provides a list of materials that are succeptable to thermal and radiation stresses. IP: Infers that a list of materials will be identified later. IP: Describes in detail acceptable methods for addressing aging. l 1

3-p.

12. Synergistic Effects GL: Does not address this issue o

9

t , y.. COMPARISON OF IEEE STD 323-1974 AND 323 1971 c m pagio.o a,uac, ecp,p m.g m.,pa g,o.o g a - m 19!4-1971 s w Guita war f. ta / R E " -:,re 53 eu. d.. 4!

p. 4J.,., G -q sr.~..fsp.f.= b 'ag

.l. C.ep., l.,.c.(..4.-, i e. 1. Equipment Specification Speci.fic reautrements General requirements

• -sa t

J e~ M. k., - 3.( ini;1uding: a) perfonnance 3... p.e d e d.% 0 t c.e.n m- - e A.. r e s e in - m., characteristic 5 w. a4 k s maa e p.g J k u .wI-% e.d. 4 3 t C b) voltage, frequency .y 4 w., gu g..a .. ; c.., g, . ranges .g.nea, Q,e,,g , J ,,,it a. f c) installation g w w(.y g m,,,g,4, J :,, d) maintenance 4,c L. e) design life f control. indication g environment h operating cycle

1) qualified life 2.

Principles of Qualification Specific requirements General for C ec.{.c y. 4.kw C,- :t\\td...s S a-as

b..a f.. An. s... d ut d p(t. L d:,.,.4., d, r.. g.i.h.

regarding:. type tests, partial type g g,h.u s. %g....e , 4.g.7 a) type tests tests and analyses and l f., f, {,, f q.g,,ag,,,4 ,,4,, 4 3 g x b) partial type tests operating experience l g:Q g, i and analyses i c)' operating experience I d) equipment interf ace q.c.,,,,;l; (,,..,.nde M sa% a, tae p ;&d..u 3 Specific and detailed Less specific and l p Q. Documentation requirements for diff-detailed with no y,gt,,, g,. n g erent qualification specific requiren.ent ..,_,A g.4 4 u m g a....,., s;..t. ...i methods. Requirement to maintain c;ocumenta-g ..d a. M...p. g ese.(y to maintain documenta-tion files .I w 4-g tion files. c. A. k d ../.a.c 4 w .,,..,. w. a. tt.e form of data require. l y g, m.,,(,, General test plan in g,4 gg,, 4,,,.g g, Q 4. Type test Qualification specific test plan. s

m..d '9 """' #' IM

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Procedure including: gy., g, s., a) mounting ments for: l 3 .. A,.. b) connections a) mounting ., 4 c) monitoring ' b) connections q.,p., d.,.,. U ..t v.. a...,..a

c..g. M. C (.

y A,,:, b (,, d) margin c) monitoring A t,..,..j J. 6,. g rJ e) test sequence d) test sequence g,., t...g. u .,7.,. ( t s.M - l.3 . g, 4.,,,,,d t,, y, f) aging e) vibration e g,, p g) vibration f) radiation (, ,,, h..

.1, j

'y g gyt g,, L,,,, g gg j . 3g f,f,,,4 h) radiation g) operation l F i) operation h) acceptance Criteria d 4 g j) inspection 90T INCLUDED ARE: k) acceptance criteria al aging td r s iln l

l a e s w.. 6 1 l 1974 1971 t/ c

r. n ty. igg

_untG ed,9 E,, 5. Operating [sperience Qualifi. Specific General outline of

r... 4,,.. 4 g. f,g,% 4

.s., i........ 9, procedure in the cation Method form of data . i g,, ).l d, u, [.., t .,., w. ;g. ,,,1 g, requirernents. s t 4,.. .\\ ..s w.,... s., r j 6. Qualification by Analyses Specific General outline of q,t.,. _4

4.,,g,,,;

procedure in the I.,,($ ..,. 3,,,, 4,,,,,,, -g, Procedure M. .. 49 L., form of data 4. whu g c., s d 3.. i 4,J.,,. requirements. E s..., g 7. On-Going Qualification Specific Not included Procedure

..~.hk h sc... (

s.p s;[:s ~hla b Le, .d b i B. Simulated Service Condition Description and Not included (k,.. t <. s, Typical Test Profile figures showing: .., A;;;s. ggd 7.. (. ',. g.,* o.

c. W W u,<..t t 4.

e s m. Q.. g,, 4. a,e q w t L... v. g..L4 a) margin (additional sp,.{ y p &,g y, h ., press. ,,,j,,,,,, 3, 4,,,,,,g,,4 (,, s "I*'b **' N N s' r** f*IC-Oe j s.i g g,, J 49, e=d.. b %c e e,- a c) pressure and [' ',,[J']' g'] ' (.e.g a 4 t,, 4,g.,,y Q J,} Q temperature ,,, g g s ,;(., o p p,,4,,, m f ,,,,,,,, g g g Q_g ,s3..d 4. W.d i.e4 (< eaA Q d) time period sep nk %<g; f,,d.... m,e,

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t e e>.. pWM N9 # es.J-. e w id m e w. M u.i N,m w cxx u s r.74 [ C0dPARI$0tt-OF/ IEEriSTD-38-19743Ml?3-1971 Irrt iTn. n r _ '~ 1974-1971 cme GuitA tMK & fjfRtr,..orey a /sc. e. ft. C-ev. M. M.,.\\.m. t-a1.1....% v -.dr e w.f M.aa l, a,h *A. .. rese us m.+ & y.d .(. 9. { l. Epu geent Spe,cJfles tan Specific reoutrements General requirements M N. < - w.( % r -k including: paw.4 4. % g.e.,,,,e,5 w.

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u t i 2 ep,a r c,. n s 9 2, 1974 1971 (f.c, c,.n t t u.uc. l 5. Operating Emperience Qualift. Specific General outilne of w.. t,g. 4 f f,J.% 4. % g,, 4; g,,3,, ' ; prt,cedure in the . aq d,.,,,.M, q,,,,, g,,,,g,,, cation Method form of data requirements. .f,,,,, m ( y, y,,,4 44, 5 4. 4 -.+ '...t. ,.. ~,,r . % 4.,,, __,,; General outline of 4,, t..$.., ; a,, ,,,,,,,4, 6. Qualificatten by Analyses specific procedure in the l... q, a Jw.a 41.t d - .est i.e. . Procedure form of data 4.. i s g e.,. ;,.,, requirement 5. g,,,, A,, @/ l,/,, Sa *g Not included 7. On. Going Qualtfication Specific fes:k I hh b be...el b Procedure L h d se e. <. s 8. Simulated Service Condition Description and Not incl.Jded f.4 a, c,.i. .. AA... h :t r ~*f ' t - e*' '5-

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~ ~ ..x..... ENCLOSURE g g5,y350'fI RESPONSE TO COMMISSION. QUESTIONS DATED AUGUST 8,1979 CONCERNING ? ,I THE UCS PETITION FOR RECONSIDERATION ~ ~ 1 IEEE Standard No. 323 - 1971 Version e 9, W, In order to facilitate a response to thbission'+ questions a table ' comparing IEEE Std. 323-1971 and IEEE Std. 323-19, has been prepared. Q et 4WJ /) see ?:hw$ This table illustrates the fact that with a few u notable exceptions (i.e., aging, margins, and detailed requirements for maintaining documentation) both of these standards address all of the major aspects of equipment qualification., The principle difference in the two is the level of detail provided in the 1974 version as opposed to'the interpretations and judgements required in the implementation of the 1971 version. However, even with its greater detail, IEEE Std. 323-1974 1 still requires a significant amount of engineering judgement in its I implementation especially in the area of aging and margins. i The significant point in these introcuctory remarks is that neither the 1971 version nor the 1974 version of IEEE Std. 323 can be applied effective-l ly without guidelines for the necessary interpretations and judgements. It is important to note that in the most recent and current reviews of license applications referencing IEEE Std. 323-1971 the staff is requiring interpretations and making juogements that bring the level of assurance of l equipment qualification in these plants to essentially the same ' level as I that which will be achieved in future plants from agiteral application of

3] IEEE Std. 323-1974. These interpretations and judgements arp part of the continuing process of evolution of equipment qualificatton requirements discussed in NUREG 0413, Appendix A " Report on the Historical Evolution of Environmental Qualification Requiremerts for Safety-Related Electrical Equipment." &ss ch W-i 7How many operating nuclear power plants are not now fonnally r_ comitted to comply with the provisions of this Standard? fe. c go nR Y f u w *r-r'- Q G ') m.' hiR o~ g kitwJd i op+- hb 1

.( e..

C ur i n) ~ a-. E eQ &g L &. rn es.& \\ pe ci-fi o dum -k YE E^ =~ .4 M s d '1 ?, ~1 ~ th D l %1 kR\\ ?.} p k ~ ]MK i

t. A.

A i 1 I . O s. cT. W b. l ~ What are the advantages to be gained by requiring those facilities to fonnally comply with the provisions of this Standard? the disadvantages? M e .-g _-e .y, w -,w.,.9 ,3 ,-p,-- g

,y gj / e ( 1 J' y : >..c 3 f. g h In order to provide a meaningfull response to this question it must - be answered within the context of a cencidcretic a f the current ongoing staff program to upgrade the qualification of electrical equipment in all operating reactors. This program was outlined for the commission at a briefing on July 11, 1979 to discuss . ; the licensee responses to IE Bulletin 79-01. The end result of this program will be a higher level of confidence in equipment qualification at operating reactors. This higher level of confidence will be achieved by c. rigorI E cT-nt by co pen;at e ;s..L o w

# existing qualification information and documentation for c4//

t.L2-M compliance with h.f guidelines, established, specifically TI w'bb rovide a level of confidence essentially equivalent to that which would be achieved from the application of IEEE ,el @ 72~f/ d M s.[N N4. Std. 323-1974 M u r4 1 ' Therefore, there is little advantage to be gained from fema 4P; J% / -9 6 . rrqui,159 compliance with t..: lett;r--ef IEEE Std. 323-1971gs4 nee dhe current ompsag staff program is to provide a higher level of confidence in equipment qualification than one would get L from a m: c L -ba P 4t c' the standardjwithout also specifying ( guidelines for implementation. In fact there cet44 4*ea be a a ceMn disadvantage ir cud zw g,v4 in that e-+ack'it

tMed e

1 dts l -tc th: h m, uf IEEE 323-1971 woo 4d not require consideration h 1 l ef aging or margins, nor would it include any specific requirement to caintain qualification documentation) N I ' M 4 ,pe-

s 1 D.A :h >. C. ,5Sased on the response to I.b. above, if st.: A compliance were _ required by the Commission, what would be a reasonable schedule . for demonstration of such compliance? kipW.A2. a t ~~ f_evakr%g ve ~ _ _. a The current staff program for .pg,eggipmentqualificationis p n e,., expected to be completed by "7~% Since a-s491e E E. w C t. ~^ ~ ._ J i t. d, backfitti,ig -of IEEE Std. 323-1971 wov4d be less ca 'g comprehensive than the cm;/L; b.A, w a tv d J w d e / k'. 'l -,- j @,-Soe' : N %tdri r - ~~ could be accomplished within the same time frame. ~ ----.- 1 .... -. -_._ f i 7,. IEEE 5 tans rd Nn 6 4 Versicn i ~ 6 W O y / &o*//g 1 s t~ r' l G*1 b lb A- . s,. a.1,a + <eed.n x:m b sU'l A M sd n _ o( llc W A :fw :4.1 h JC 0-lI? U , I. l a v; % J fc. ' Q.M s ;- % h

bY yI Ln % p9d i

cA se +g_ L, w4 n i c. C a cu& A, w h o y.'c p 3 m w p d ~.;- k u-A. y:Lj_ he st / 4 u S.: d ll & <e >, N h s Y :~ > h. ! : i hplll } 8T/ i.c s. m o << a i. !& I : L, e . r _ ;, _, -c. y -wv. m..- - ~ o

5.) l p u -'3 2 \\ p d ' #,*, [a v;M / b 'p A" y I i l [g [T2r' l [ IEEE Standard No. 323 - 1974 Version What are the advantages to be gained by requiring operating nb: lear power a. l l plants to comply with this Standard? The disadvantages? l b. Based on the response to II.a. above, which specific provisions of this Standard. strike a favorable value-impact balance with respect to back-l l fitting considerations? Based on the response to II.b. above, what would be a reasonable schedule c. for demonstration of compliance with these provisions?

Response

As noted above, the staff program for reassessing the adequacy of equipment a. ~ qualification at operating plants will be based on guidelines which closelv follow the requirements of IEEE-323-1974. Therefore, equipment that is found to be qualified in accordance with these guidelines -hould comply with most aspects of that Standard. Nevertheless, there are advantages to requiring that operating plants comply fully with all requirements of the 1974 standard. Specifically, the application of this standard to operating plants would require a more rigorous and complete demonstration that aging ,uu J M 4 yf.J/ 4ni of<- -T4.2 qualified life of all equip-effects were adequately accounted forg uW h ment.would be c:t01hhcd. Further, -%e margins % be applied to, test A h rildd ~ d EU~ Y M *

• u "%-

parametersh vid Lc dcLcw.incjiime wanrvcti=17. a w +c.c. u m or 4 % m of4L.eA g q =T -c;-- e 4~ - %, i licensees with operating plants to comply The disadvantage of with IEEE-323-1974 is that many licensees will be required to retest some % Al-r.g.s r A g I. d -> W i Mws aLu 7 6 A. 4 s. y k s,~ ns (y.+.~ )

.2 2-fraction of their equipment to comply with the aging requirement. Some retesting may also be required to comply with more conservativ& application r of the margin requirements. Where testing is not required, coopliance WM y be demonstrated by analysis. In e:ther case, significant licensee and staff resources would be required to implement these provisions and review the documentation. <- N b. We believe that neither the aging nor the margin requirements of IEEE-323-1974, when compared to the draft guidelines to be used in the upcoming staff reassessment of operating plants, arrent backfit consideration. The benefit of backfitting either the aging or the margin requirements of the 1974 Standard is a small, unquantifiable increase in the level of assurance that A equipment is qualified. Yet the costs, in tenns of manpower, aed testing MQu.W dd3~4:M %b = r% + required to implement these provisions, may be significant. A The staff guidelines mentioned above will require that aging be considered,Ld % for that equipment identi'fied as being susceptible to aging effects. - M. We believe that approach is adequate for the present. We are now reviewing operating license applications for plants already required to comply with the 1974 version of the standard and therefore we are assessing aging data for electrical equipment generally. As that review process pro-ceeds, and our understanding of aging effects improve, we will reassess the need for further backfitting the aging requirements. With regard to margin, we believe that the application of the staff guidelines to operating plants 'ill ensure that adequate margins hava been applied during w In addition, backfitting the standard would extend thel / date by which the ongoing reevaluation program coulo be completed f and possibly delay the overal upgrading of equipment qualification that the staff program is designed to achieve. \\_.__.___..-.. 4 -,-- ~,g-g ,m ,,w -e -,.-,-,.,,y. .y .---,-..,4-.

tM 3-Q <. l h.y.O L) pyl.c.al.~oh N qualification testing. A' More conservative margins wesid mbbij bc requirJed r q, ~ Jf th: qualiff raticr. d2t2 ;;c e being re'tiewd againer he 1974 Standard A f LCCdd$e I CCC C C d ~4 UB 44 Ull asedi S i&& [h 4 Ca c$ .S

• f0 I C I b I.

di h aacicinne we,=aa nn 5,,+,,re g 7;;pg, $ g.,;; ; pp; ; gg,,,,, g,,, _ _ yet +n f $ 2r c e ' A t' e.: : tar.da rd i: :!re dy.c3..:.d. ': icli;v; 21; added g sw = ti =, whila appropriate for plants yet to be licensed, is unnecessary for operating plants. c. While, c:, we uded oL;.;, there i: =r3 r21 b0r.0 fit to 53C'#itti"Acith?" - f ne aninn ~ - - ranniremonte of-the 1974 version of the sterd::d, we the ~2rnin believa compliance with the standard could be demonstrated in 3 to 4 years given there are adequate test facilities available during that time. i i l l l l \\ l I l l l l

Erd esu m 1 A7,.~ J . COMPARISON OF IEEE STD 323-1974 AND 323-1971 1974 19il .:ec 5

1. iEquipment Specification B'etaWefrequirements Gen"eral muirc:Ms including:

a) perfont.ance characteristics b/ voltage, frequency ranges c) installation di maintenance e) design life f control, indication g environment h operating cycle

1) qualified life hec.;4;t 2.

Principles of Qualification -9at444ed requirements General requiwe e ta for regarding: type tests, partial type a) type tests tests and analyses,and b) partial type tests operating experience and analyses c) operating experience d) equipment interface 3. Documentation Specific and detailed Less specific and requirements for diff-detailed with no erent qualification specific requirement methods. Requirement to maintain documenta-to maintain documenta-tion files tion files. l 4. Type test Qualification Vewdpecifictest frief et"c: Of[neral l Procedure plan, including: test plan in the form l a) mounting of data requirements for: b) connections a) mounting c) monitoring b) connections d) margin c) monitoring e) test sequence d) test sequence f) aging e) vibration g) vibration f) r,adiation ( h) radiation g)) operationacceptance cr h

1) operation j) inspection NOT INCLUDED ARE:

k) acceptance criteria a). aging b) margin L) inspection i

1974 1971 4 9 sinid in detaib -outline of 1 5. Operating Experience Qualifi-cation Method. Qet; k enera procedure in t..e fann of data rei uirements. l r Er ph g.< :. : 1- ;c S t .ned 4-dtm -Br4ef outline of 6. Qualification by Analyses general procedure in j Procedure the fonn of data r requirements ! cec % 7. On-Going Qualification sphdeed ia dettrtt Not included Procedure 8. Simulated Service Condition Description hnt Not included Typical Test Profile figures showing: a) n,srgin (additional peak temp., press. and time) b) operation c) pressure and temperature d) time period -# 1 / ~) Appendirf and B.-(not of th(-[' the Sti.ndar,as a/repr'uded i IEEE3/2-197 but ncl f esentative 'of DBE enyf'r'onme'ntaVs' icd (ation ' fopPWR pWR, fnd H}GR'r/). / t i i I I r f

ENCLOSURE e RESPONSE TO COMMISSION QUESTIONS DATED AUGUST 8, 1979 CONCERNING THE UCS PETITION FOR RECONSIDERATIO_N_ = ? hn order to facilitate a response to the Commission's questions,* a table comparing IEEE Std. 323-1971 and IEEE Std. 323-1974 has been prepared (see Enclo::ure 1). This table illustrates the fact that with a few notable exceptions (i.e.. aging, margins, and detailed requirements for maintaining documentation) both of these standards address all of the major aspects of equipment qualification. The principle difference in the two is the level of detail provided in the 1974 version as opposed to the interpretations and judgements required in the implementation of the 1971 version. However, even with its greater detail, IEEE Std. 323-1974 still requires a significant amount of engineering judgement in its implementation especially in the area of aging and margins. The significant ooint in these introductory remarks is that neither the l 1971 version nor the 1974 version of IEEE Std. 323 can be applied effective-ly without guidelines for the necessary interpretations and judgements. It is important to note that in the most recent and current reviews of license applications referencing IEEE Std. 323-1971 the staff is requiring interpretations and making judgements that bring the level of assurance of equipment qualification in these plants to essentially the same level as that which will be achieved in future plants from a literal appitcation of IEEE Std. 323-1974. These interpretations and judgements are part of the continuing process of evolution of equipment qualification requirements discussed in NUREG 0413, Appendix A, " Report on the Historical Evolution of Environmental Qualification Requirements for Safety-Related Electrical Equipment.' l

Question I IEEE Standard No. 323 - 1971 Version E. How many operating nuclear power plants are not now formally. comitted to comply with the provisions of this Standard? b. What are the. advantages to be gained by requiring those facilities to formally comply with the provisions of this Standard? the disadvantages? c. Based on the response to I.b. above, if such compliance were required by the Commission, what would be a reasonable schedule for demonstration of such compliance?

Response

power reactors are currently licensed to operate with no a. formal reference to IEEE Std. 323-1971 on their dockets as the basis for equipment qualification. Th.e specific plants in this category are listed in Table 1 (attached) along with an identifi-cation of the equipment qualification requirement upon which the license was based. b. In order to provide a meaningfull response to this question it must be answered within the context of a consideration of the current ongoing staff program to upgrade the qualification of electrical equipment in all operating reactors. This program was outlined for the comission at a briefing on July 11, 1979 to discuss the licensee responses to IE Bulletin 79-01. The end result of this program will be a higher level of confidence in equipment qualification at operating reactors. This higher level of confidence -.m-- e -..n. .e-

• will be achieved by a rigorous component by component reevaluation of existing qualification information and documentation for f j compliance witn a set of guidelines established specifically [

. to pmvide a level of confidence essentially equivalent to that which..culd be achieved from the application of IEEE Std. 323-1974. Therefore, there Is little advantage to be gained from fonnally requiring compliance with the letter of IEEE Std. 323-1971 since the current ongoing staff program is designed to provide a higher level of confidence in equipment qualification than one would get from a mere backfit of the standard without also specifying guidelines for implementation. In fact there could even be a certsin disadvantage in such an approach in that a backfit restricted to the letter of IEEE 323-1971 would not require consideration of aging or margins, nor would it include any specific requirement to maintain qualification documentation. c. The current staff program for upgrading equipment qualification is Since a simple expected to be completed by literal backfitting of IEEE Std. 323-1971 would be less comprehensive than the current pmgram, such a backfitting could be accomplished within the same time frame. ,,,.-.--.m-- ,c.. ,.-y-- y

, Question II i IEEE Standard No. 323 - 1974 Version 5 a.}Whataretheadvantagestobegainedbyrequiringoperatingnu' clear , power plants to comply wi'.n siiis Standard? the disadvantages? b. Based on the response to II.a. above, which specific provisions of this Standard strike a favorable value-impact balance with respect to backfitting considerations? Based on the response to II.b. above, what would be a reasonable c. schedule for demonstration of compliance with these provisions?

Response

As stated above, the ongoing staff program for reassessing the, a. adequacy of equipment qualification at operating reactors will be based on guidelines which are specifically written to raise the level of confidence.that equipment is qualified to essentially the same level 'N would be achieved by requiring full compliance with the let .. (EEE Std. 323-1974. Therefore, equipment that is found to be qualified in accordance with these guidelines would comply with the intent of all the safety significant aspects of the standard. Nevertheless, requiring full compliance with all provisions of the standard would provide some measure of additional assurance. For example, the application of IEEE 323-1974 would require that a qualified life be established for all safety related equipment, where as the guidelines as now written in draft form would only require that a specific qualified life be established for components using materials know to exhibit degradation with age (e.g., nylon in solenoid valves). Another l

. example would be margins. The standard requires that margins be uilneswould[ applied to all test parameters, where as the gu c 5 only require that margins be applied bo the most significant , parameters (e.g., time). In summary, the only advantage of requiring operating reactors to comply with the letter of IEEE Std. 323-1974 is snme unqua'1ti-fiable additional assurance that equipment is qualif ted over the reasonable level of assurance that the staff believes will be achieved as a result of its ongoing reevaluation program. The primary disadvantage of backfitting the standard would be an unwarranted expenc'-.tre of licensee and staff resources to demon-strate compliance with those pmvisions of the standard whic no do yield significant additional confidence in a luipment quali-fication. In addition,:backfitting the standard would extend the date by which the ongoing reevaluation program could be completed and possibly delay the overal uograding of equipment qualification that the staff program is designed to achieve. b. Based on the discussion above, we do not believe that any backfitting apart that which will result from the ongeing staff reevaluation program strikes a favorable value-firpact balance. The provisions l of IEEE Std. 323-1974 which are safety significant will be includet! in the guidelines in a manner in which they can be implemented cost effectively. The issue of equipment aging discussed in II.a. above is an example of how certain pmvisions of the standard would i r _-,,__,7.__--s_ _ _ ~ _.,, -,..y.--

._= . be backfitted. In is likely that backfitting an aging require-ment in this manner will require some requalification and that.f . he requalification will require some retesting. We believe t ,that this type of backfitting is justified on a value-impact basis. c. As stated in the response to question I.c. above, the ongoing staff program for upgrading equipment qualification is e.voected to be completed by If a complete backfitting of the letter of IEEE 323-1974 were to be substituted for using the staff guidelines in the program, an additional 1 to 2 years would be required to complete the reevaluation. l P f I I i

ENCLOSURE 7.., f RESPONSE TO C0ffilSSIONER KENNEDY'S QUESTIONS c DATED AUGUST 8, 1979 CONCERNING THE UCS PETITION FOR RECONSIDERATION .f ? ? I. [EEEStandardNo. 323 - 1971 Version In order to facilitate a response to questions I & II, a table comparing IEEE Std. 323-1971 and IEEE Std. 323-1974 has been prepared (see Attachment 1). This table illustrates the fact that with a few notable exceptions (i.e., aging, margins, and detailed requirements for maintaining documentation) both of these standards address all of the major aspects of equipment qualification. The principle difference in the tt;o is the level of detail provided in the 1974 version as opposed to the interpretations and judgements required in the implementation of the 1971 version. However, even with its greater detail, IEEE Std. 323-1974 s'.ill requires a significant amount of engineering judgement in its implementation especially in the area of aging and margins. The significant point in these introductory remarks is th6t neither the 1971 version nor the 1974 version of IEEE Std. 323 can be applied effective-ly without guidelines for the necessary interpretations and judgements. It is important to note that in the most recent and current reviews of license applications referencing IEEE Std. 323-1971 the staff is requiring interpretations and making j !dgements that bring the level of assurance of equipment qualification in these plants to essentially the same level as that which will be achieved in future plants from an application of

. IEEE Std. 323-1974. These interpretations and judgements are part of the continuing process of evolution of equipment qualification re uire-mhnts discussed in NUREG 0413, Appendix A. " Report on the Histori, cal Evolution of Environmental Qualification Requirements for Safety-Related Electrical Equipment." Question a How many operating nuclear power plants are not now formally committed to comply with the provisions of this Standard?

Response

Fif ty nine of the 70 power reactors currently licensed to operate (including Indian Point 1 and Humboldt Bay) with no specific reference to IEEE Std. 323-1971 as the basis for equipment qualification. Question b What are the advantages to be gained by requiring those facilities to fomally comply with the provisions of this Standard? the disadvantages?

Response

In order to provide a meaningfull response to this question it must be answered within the context of the current ongoing staff program to upgrade This the qualification of electri.a1 equipment in all operating reactors. program was outlined for the Commission at a briefing on July 11, 1979 to discuss the licensee responses to IE Bulletin 79-01. The end result of this prugram will be a higher level of confidence in equipment qualifica-tion at operating reactors. This higher level of confidence will be achieved by evaluating existing qualification infomation and documentation for compliance with staff guidelines to be established. These guidelines ..-,,-y ,m,._. i,-y-- - -. -.-

i . will provide a level of confidence essentially equivalent to that which would be achieved from the application of IEEE Std. 323-19i4 pich-are-more-stringent-than-~the earlier-versio4 oYthe-standar. Therefore, there is little advantage to be gained from limiting compliance to IEEE Std. 323-1971 above. The current staff program is intended to pmvide a higher level of confidence in equipment quali-fication than one would get from the standard above without also specifying guidelines for implementation. In fact there would be a disadvantage in that IEEE 323-1971 does not require consideration for ai, ting or margins, nor would it include any specific requirement to maintain qualification documentation; all of which ivill be included in the staff's guidelines. ,uestion c Q Based on the response to I.B. above, if such compliance were required by the Commission, what would be a reasonable schedule for demonstration of such compliance?

Response

The cutient staff program for reevaluating equipment qualification is I I expected to be comp 14ted by April 1981. Since the requirements of IEEE Std 323-1971 are less comprehensive than the staff's guidelines, a reevaluation using this standard could be accomplished within the same time frame. IAt the Commission briefing on July 11, 1979, referred in response to question a. above, the staff stated that the reviews of licensees responses to IE Bulletin 79-01 for compliance with the staff guide-lines being prepared could be completed by March 1980. As a result of subsequent work in connection with preparing the guidelines the staff has detennined that April 1981 is a more realistic estimate. I

o s II. IEEE Standard No. 323 - 1974 Version \\ Question a Wpat are the advantages to be gained by requiring operating nuc1 ar power plants to comply with this Standard? the disadvantages? Rbsponse !.a i J._ v.t w % Q d I_) As noted' ahe, the staff program for reassessing the adequacy of equipment qualification at operating plants will be basad on guidelines which cYROyNNow the requirements of IEEE 323-1974. Therefore, equipment that is found to be qualified in accordance with these guidelines should comply with most aspects of that Standard. Nevertheless, there are advantages to requiring that 't% operating plants comply fully with eM r.equirements of the 1974 standard. Specifically, the application of this standard to operating plants would require a more rigourous and complete demonstration that aging effects were adequately accounted for and the establishment of a qualified life of all safety related equipment. Further, margins would be applied to all test parameters whereas the guidelines would require only that margins be applied to the most significant parameters (e.g., time). Implementation of both the margin and aging requirements would result somewhat higher level of assurance of the adequacy of qualification. The significant disadvantage of requiring licensees with operating plants to comply with IEEE 323-1974 is that many licensees will be required to retest some fraction of their equiprent to comply with the aging requirement. Some retesting may also be required to comply with more conservative applica-tion of the margin requirements. Where testing is not required.

2-compliance may also be demnstrated by analysis. In either case, significant licer:see and staff resources would be required to? s 3 implement these provisions and review the documentation. In addition, backfitting the standard o ( er by ~ which the ongoing reevaluation program could be completed and possibly delay the overall upgrading of equipment qualification that the staff program is designed to achieve. Question b Based on the response ti II.a. above, which specific provisions of this Standard strike a favorable value-impact balance with respect to backfitting considerations?

Response

We believe that neither the aging nor the nargin requirements of IEEE 323-1974, when compared to the draft guideli'nes to be used in the upcoming staff reassessment of operating plants, warrent backfit consideratior.. The benefit of backfitting either the aging or the margin requirements of the 1974 Standard is a small, unquaa, tifiable increase in the level of assurance that equipment is qualified. Yet the costs, in terms of manpower, the testing required to implement these provisions, and the possible delay in the staff review effort may be significant. The staff guidelines mentioned above will require that aging be considered, but only for that equipment identified as being susceptible to aging effects. We believe that approach is nN adequate for the present. We are M reviewing operating applications for plants alt:3dy required to comply with the e= .m -we , - - - ~ -, - -, n

~ -3_ 1974 version of the standard and therefore we are assessing aging data for electrical e.quipment generally. As that .f $ review process proceeds, and our understanding of aging effec,ts improve, we will reassess the need for further backfitting the aging requirements. With regard to margin, we believe that the application of the staff guidelines to operating plants will ensure that adequate largins have been applied during qualification testing. We believe that the more conservative application of margins

equired by the 1974 Standard, while appropriate for plants yet to be licensed, is unnecessary for operating plants.

Question c Based on the response to II.b. above, what would be a reasonable schedule for demonstration of compliance with these provisions?

RESPONSE

We believe compliance with the 1974 version of the standard could be demonstrated in 3 to 4 years given there are adequate test r facilitics available during that time. i t \\ l

ATTACHMENT COMPARISON OF IEEE STD 323-1974 AND 323-1971 ,1974 19h1

1. iEquipment Specification Specific requirements General requirements including:

~ a) perfonnance characteristics b) voltage, frequency ranges c installation d maintenance e design life f) control, indication g) environment h) operating cycle

1) qualified life 2.

Principles of Qualification Specific requirements General for re type tests, partial type a)garding: type tests tests and analyses and b) partial type tests operating experience and analyses c)operatingexperience d) equipment interface 3. Documentation Specific and detailed Less specific and requirements for diff-detailed with no ercnt qualification specific requirenen', methods. Requirement to maintain documenta-to maintain documenta-tion files tion files. 4. Type test Qualification $ipecific test plan, General test plan in the fonn of data require-Procedure including: g a) mount.n ments for: b connections a mounting c moaitoring b connections d margin c monitoring e test sequence d) test sequence f aging e) vibration g vibration f radiation h radiation g operation i operation h acceptance criteria j) inspection NOT INCLUDED ARE: k) acceptance criteria a aging b margin c inspection -r ,-w, v. -... ~ e --- -,,y -e -e.-.-.

• 1974 1971 5.

Operating Expe;ience Qualifi. Specific General outline of cation Method proqedure in the form of data reqdirements. 1 6. Qualification by Analyses Specific General outline of Procedure procedure in the form of data requirements. 7. On'-Going Qualification Specific Not included Procedure 8. Simulated Service Condition Description and Not included Typical Test Profile figures showing: a) margin (additional peak temp., press. and time) b) operation c) pressure and temperature d) time period ,mm ---4----.~.-,.%-

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e e.. IEE M TD. 323 D0R GUIDEllNE5 NUREG-0588 J971 1971 tio specific guidelines for evalua-specific guidance is provided 1. Equipment Specification Spect.fic requireeents General requirements ting c4uipment specifications are in Sections 1.1 thru 1.4 on including: provided. 1he 0014 reviews are ad acceptable mettmds to estab-a)performane hoc and equipment has already been lash environmental conditions characteristics purchased and installed. Therefore. to which equipment must be b) voltage, frequency it is not possible to backfit purchase qualified. . ranges specification requirements. c) installation d) maintenance eh design life f? control, indication gi environment h) operating cycle

1) qualified life Specific guidance is provided in Section 2.1 on selection 2.

Principles of Qualification Specific requirements General for Specific guideline:, for selection of of qualification methods, regarding: type tests, partial type qualification methods app wpriate for The hUREG states that quali-a) type tests tests and analyses and dif ferent applications are providad fication of equipment subject-b) partial type tests operating emperience in Section S.I. ed to an accident environment without test data is not ade-y and analyses quate to denenstrate function-D c)' operating esperience al operability. d)*quipmentinterface Section b.0 includes a requirement for Specific guidance is provided g Documentation Specific and detailed Less specific and complete and aeiltable records to be in 5cction 5.0 on documen-maintained evallable which describe the tation, liicluding information requireraents for dif f

• detailed with no erent Qualification specific requirement qualification method used in suf ficient required during licensing methods. Requirer.ent to maintain documenta.

detail to verify the extent of compliance reviews. Q to maintain documenta-tion flies with the D0R guidelines. tion files. @. Type test Qualification Specific test plan, General test plan in Specific guidelines for evaluating type Specific guidance is provided ammmme the form of data require. tests are provided in Section 5.2 for in Section 2.2 Qualificattun

• 6/ tests, 2.3 Test Sequence, Procedure including:

the following: a) mounttry inents f or;

3. Margins, and 4. Aging.

m, b) connections a) mounting a. mounting plants sequired to conform f c) monitriring b) connections b, connec t ions operation (functional testing with 323-1911 must address d) margin c) snonitoring L. and failure criteria)

a. jing concerns.

5" e) test sequence d) test sequence d. test sequence f) aging e) vibration e. aging g) vibration f) radiation f. test specimen selection y h) radiation g) operation m i) operation h) acceptance criteria g. test duration \\ /s j) inspection 140T Il4CLUDED ARE: p k) accettance criteria EgE~g j l-) ma rgin \\

~ e e .e.. IEEE-$TD. 323 DDR GUIDtLINES NUREG-0588 1971 393 5. Operating Esperience Qualtfl. Specific General outitne of These types of qualification methods $ #'ggic guidance is a e lumped in a single category called id cation Method qualification by a combinatics of [,"o'the r procedure in the a t form of data methods (Section 5.3). In general methods

• requi repen ts,

k the combination anast include some General outline of type testing when the equipment is 6. Qualification by Analyses Specirte located inside containment. Any procedure in the analysis relied on must be based Procedure form of data on test data. requirements. 7. On-Going Quellfication Specific Not included Procedure 8. Simulated service Condition Description and Not included No generic simulated service condi-Sections 1.1(3) and (4) tion test profile is provided. Specific and 1.2(3) and (4) provide Typical Test Prof *?e figures showing: guidelines for evaluating the service specific guidance on test a) margin (additional conditios.s specified for a particular proflies. peak terrp., press. type test or analysis are provided and time) in Section 4.0. In general the b) operation service conditions specified in the c) pressure and individual plant FSARs are considered Q temperature acceptable. No separate margin factors O d) time period are required to be added to the service conditions to estabitsh acceptable test conditions (see Section 6.0). Require-i ments for functional testing and the failure g criteria in Section 5.2 of the guidelines assure adequate cor.servatism in tie overall testing program wittout specifically e s-m identifying the margin factors that exist in the test profile. The best estimate approach for MSLB qualification emm"" is followed as set forth in NUREG-0458 Z pending completion of TAP A-21. t== w'.i1 L D 51.'.1 5 ~ g, ,q. .uc:.t t.n n: Gut Alui y co..m..:o J e.e...., son. o c. mz ! 'p, J W \\.,,",".(8 s%- GCI 3 1980

• [EM0PMDUMFOR:H. R. Denton, Director Office of Nuclear Reactor Regulation FRCM:

R, B. Minogue, Director, OSD

SUBJECT:

STA.DARD FOR QUAllFICATION OF SAFETY RELATED EQUIPI:ENT Tsd This letter responds to your letter of September 2, 19S0, requesting us to f 0 ~'I " evaluate the advisability of developing in a broad single rule:.aking action - an a.T.end..cnt to 10 CFR 50 which would include 1) the rulc.aJ.iag directed by.j the Commission, on environmental qualification of electrical equipment (CLI-80-2),

2) the rulemaking proposed in the Cor.nission paper from I&E (SECY-80-f,9)fon"~ [0-31 ind'epandent verification and testing and inspection of equipn2nt's environnental-

~ qualifications, and 3) broadly address the qualification of both electrical and mechanical equipment (ircluding chemical process equipment such as hydrogen reco::.biners) for seismic and dynamic loading conditions as well as other environ- .v mental conditior:s." Your proposal, that a comprchensive rulemaking addressing all aspects of qualifi-cation of all type of safety related equipment be developed, has merit. Ho.;ever, we do have a concern that the expanded assignrcent could cause delays in completing the highest priority item, nam 21y the Cornission order, since there is a wide variance in the status of: 1) time commitments and estimated completions for .those phases of the program alr'eady in process, and 2) available suppo. ting NUREGS, Reg. Guides and National Standards. A number of standards and regulatory guides are ahailable on qualification of electrical equipment, whereas some standards are in varying stages of development and no regulatory guides are presently available on qualification of mechanical Without the detailed standards required for implementation, the rule l equipment. could be judged impractical. Therefore, due to the deficiency in mechanical equip-ment standards, we are considering an advance notice of proposed rulcoaking for the l l broad rule. Since receipt of your letter, we have learned that the independent verification testing program is to include a third party accreditation system and the scope may be broadened to cover far more than equip. Tent qualification. In view of these coirplications, we.believe it to be more expedient to start the l ) project as three separate and cc~rcurrent items which we will attempt to consolidate l fYO P00R ORIGINAI. P"% LLDU 9

('h' ...., ii ,j ..u. o e :.. v 9.....o SEP 02 E 0 MEMORAIJDUM FOR: R. B. Minogue, Director Office of Standards Development FROM.- H. R. Denton, Director Office of t!uclear Reactor Regulation

SUBJECT:

STAf;D/$RD FOR QUALIFICATI0!l 0F SAFETY RELATED EQUIPMEtiT The Comission's Memorandum and Order of May 23,1980(CLI-80-21), directed that the staff initiate a rulemaking on the subject of environrental quali-fication of safety grade electrical equipment. We understand that this activity will be undertaken by your staff in response to the Comission Order. 9 We request that 05D evaluate the advisability of developing in a broad single rulenaking action, an amandment to 10 CFR 50 which would include,

1) the rulecaking directed b

.* of electrical equipment, 2) y the Co=nission on environcental qualification the rulemaking proposed in the Cocaission paper from 1&E (SECY-80-319), on independent verification testing and inspection , of equipment's environcantal qualifications, and, 3) broadly address the qualification of both electrical and mechanical equipment (including chemical process equipment such as hydrogen recombiners) for seismic and dynamic loading conditions as well as other environmental conditions. The rule should address requirements for operating as well as new facilities. We belit..! that the broader rule would be of greater benefit to the staff and give better cuidance to the industry than one that addresses a more limited scope of equipment qualification. We suggest that the proposed new rule be in the form of a new appendix to 10 CFR Part 50 which refers back to appro-priate G2neral D2 sign Criteria in Appendix A. Your evaluation should consider among other issues, the potential for expediting or delaying issuance of specific portions of the regulation when promulgated separately, relative to their being combined in a singl.e broad regulation. s C0:iTACT: C. Hofmayer t'RR/DE/EQB Ext. 2E947 y o ll ? P00R ORIGINAL d

a. s.

,ra3 su.... W

• ~

In addition to this request for a proposed broad rule, we request that it be augrented by Regulatory Guides. A revision of Reg. Guide 1.39 to include the current staff position would probably suffice for electrical equiprgnt qualification. There is no present equivalent guide for mechanical equiprant, hence, this would be a new but a very iaportant undertaking. !!c anticipate that these two guideswould be supplemented as necessary by appropriate supporting guides. Since we would not want to delay unnecessarily the start of,your efforts on portions 1) and 2), we would appreciate receiving your recor.tendations on this request by October 1,1980. The staff of the Assistant Director for I'.aterials and Qualifications will assist you by providing whatever available information that you desire in developing your recontendations. 11e are also available to reet with you and your staff to discuss the technical require-ments, pricrity, and scheduld of this activity. H. R. Denton, Director Office of tiuclear Reactor Regulation cc: W. Dircks V. Stello T. Murley l P00R ORIGINAI.

f6.'c 4f.c 4 4' /,4, ~,* k UNITED STATES s NUCLEAR REGULATORY COMMISSION , {)4( jf a wAsumcrow. o. c. zossa g g$.gf f MAR 0 2 1981 T, R. B. Minogue, Director, RES MEMORANDUM FOR: N. C. Moseley, Director, DROI, IE(2) ) IE(2 H. D. Thornburg, Director, ORCI,(5) T. E. Murley, Director, OST, NRR W. M. Morrison, Assistant Director for General Engineering FROM: Standards, SD PROPOSED RULEMAKING AND ASSOCIATED REGULATORY GU

SUBJECT:

Your assistan::e is requested in re/iewing the enclosed documents and providing The following is a sunnary of this review request: me with your coments. (1) Proposed Rulemaking, " Environmental Qualification of Electric (RS 025-1) 1.

Title:

Equipment for Nuclear Power Plants." (2) Regulatory Guide 1.89 (Revised), " Qualificatio G. W. Knighton, NRR, is requested to fomard the 2. Requested Action: enclosed copies to Messrs. Z. Roszteczy, S. Szukiewicz, and F. Rosa for their review and coment. 3. Completion Date: March 20, 1981 The proposed rulemaking is being undertaken in response to the Commission's Memorandum and Order (CLI-80-21), 4.

Background:

dated May 23, 1980, relating to the environmental qualification of electric equipment, including consideration of backfit. Reguiatcry Guide 1.89 has been concurrently revised and l contains methods acceptable to NRC Staff for meeting l the Connission's requirements for the environmental qualification of electric equipment important to safety. In view of the above, the review of both documents. Rulemaking and Regulatory Guide 1.89, should be accomplished Upon publication of the effective rule and concurrently. Regulatory Guide 1.89, the DOR Guidelines and NUREG-0588 l will be withdrawn. g/ pf D cf DJXI

5, [ NUCLEAR RE U T RY COMMIS$10N ,/ s /g g usmorow. o. c. nosss .,s,...../ SEP 0 21980 I %

• 2.

s /m i10: MEMORANDUM FOR: R. B. Minogue, Director v. Office of Standards Development FROM: H. R. Denton, Director Office of Nuclear Reactor Regulation

SUBJECT:

STANDARD FOR QUALIFICATION OF SAFETY RELATED EQUIPMENT The Comission's Memorandum and Order of May 23,1980(CLI-80-21),di*ected that the staff initiate a rulemaking on the subject of environmental quali-fication of safety grade electrical equipment. We understand that this activity will be undertaken by your staff in response to the Commission Order. We request that OSD evaluate the advisability of developing in a broad single rulen.aking action, an amendment to 10 CFR 50 which would include,

1) the rulemaking directed by the Commission on environmental qualification of electrical equipment, 2) the rulcmaking proposed in the Commission paper from I&E (SECY-80-319), on independent verification testing and inspection of equipment's environrental qualifications, and, 3) broadly address the qualification of both electrical and mechanical equipment (including chemical process equipment such as hydrogen recombiners) for seismic and dynamic

( loading conditions as well as other environmental conditions. The rule should address requirements for operating as well as new facilities. We believe that the broader rule would be of greater benefit to the staff and give better guidance to the industry than one that addresses a more limited scope of equipment qualification. We suggest that the proposed new rule be in the form of a new appendix to 10 CFR Part 50 which refers back to appro-priate General Design Criteria in Appendix A. Your evaluation should consider amsng other issues, the potential for expediting or delaying issuance of specific portions of the regulation when promulgated separately, relative to their being combined in a single broad regulation. CONTACT: C. Hofmayer 7 NRR/DE/EQB 0 )/ Ext. 28947 0 O lo ode @ q i

R. S. Minogue SEP 0 21950 In addition to this request for a proposed broad rule, we request that it be eugu.ented by Regulatory Guides. A revision of Reg. Guide 1.89 to include the current staff position would probably suffice for electrical equipment qualification. There is no present equivalent guide for mechanical equipnent, hence, this would be a new but a very important undertaking. We anticipate that these two guides would be supplemented as necessary by appropriate supporting guides. Since we would not want to delay unnecessarily the start of your efforts on portions 1) and 2), we would appreciate receiving your recommendations on this request by Octob?r 1,1980. The staff of the Assistant Director for Materials and Qualifications will assist you by providing whatever available information that you desire in developing your recoarnendations. We are also availabic to meet with you and your staff to discuss the technical require-ments, priority, and schedule of this activity. l / w H. R. Denton, Director Office of Nuclear Reactor Regulation cc: W. Dircks V. Stello ~ T. Murley e k

Secterter 1!,1930 SECY-20-423 CAS.HIN GT CN, D. C. N,55 ic.4 i IMFORViATION REPORT For: The Comissioners A*9 O From: Harold R. Denton, Director Office of Nuclear Reactor Regulation T. Office of Inspc: tion and Enforcemeny k s~~T Victor Stello, Jr., Director DnGD ADiellM i 'hru: William J. Circks iUUR UltIUg 1 L Acting Executive Director for Operations t l

Subject:

BlitCNTHLY REPCRT ON ENVIRONMENTAL QUALIFICATION OF ELECTRICAL EQUIPMENT FOR THE PERICO E. DING AUGUST 1, 1980. N Purcose: To inform the Comissicners of the progress of the staff's review of IEB 79-013 responses and to provide the status of efforts related to the staff's review of the environmental qualification of safety-related electrical equipment. Oiscussion: The Cortission '4emorandum and Order (CLI-20-21) dated "ay 23, 1980, requested that the staff provide bimonthly reports on the progress of IEB 79-013 response reviews. Ir. respense to this request, the staff has pre;ared this re;crt to the Comissioners. Equi; cent qualification reviews are bei'ig performed fcr three 8 groups of pl:nts, i.e., near term coerating license (.NTOL) plants, systamanc avaluation program 'SEP) plants., and all remaining c:erating reactors (CR's). The OR's are being l reviewed jointly by IE and the Equi; cent Outlification Branch (ECS) of !!RR. The SEP plants are being reviewed by l the EQB with technical assistance from the Franklin Research i Center (FRC). NTOL plant reviews are being perforced by the EQB. Several meetings have been held betueen *!RR, IE, and FRC in order to c: ordinate the revisws. The last such meetings were held August 12 and 13. The status and a'trief tactgr:end f:r aach of the three review eff:rts and related '.RR activi-ies Ino licensing acti:ns is given telcw. D ( CC:; TACT: R. LaGrange .NRRj0E/E06 ext. 29548 Ty 'y oA o 9 0l @O -n rl ..}}