ML20004E373
| ML20004E373 | |
| Person / Time | |
|---|---|
| Issue date: | 08/14/1980 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | Minogue R NRC OFFICE OF STANDARDS DEVELOPMENT |
| Shared Package | |
| ML19252A551 | List: |
| References | |
| FOIA-81-97 NUDOCS 8106120105 | |
| Download: ML20004E373 (7) | |
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ex 4JSER'S REQUEST TO S.D.
T0:
R. B. Minogue, Director Office of Standards Development FROM:
H. R. Denton, Director Office of Nuclear Reactor Regulation
SUBJECT:
STANDARD FOR QUALIFICATION OF SAF RELATED EQUIPMENT The Comnission's Memorandum and Order of May 23,1980(CLI-80-21), directed that'the staff initiate a rulemaking on the subject of environmental qualification of safety grade electrical equipmert. We understand that this activity will be undertaken by your staff in direct response to the Commission Order. We have discussed the general subject of equipment qualification standards with your people and desire a broader approach.
We request that OSD evaluate the advisability of developing in a broad single rule making action, an amendment to 10 CFR 50 which would include, 1) the rule making directed by the Commission on. environmental qualification of electric equipment, 2) the rule making proposed in the Commission paper from 1&E, on independent verification testing and inspection program for environmental qualified equipment, and, 3) broadly address the qualification of both electrical and mechanical equipment for seismic and dynamic loadings co,nditions as well as ist a. ye nera i aper-caclx }l-other environmental conditions.
This broad rule might also address qualification 3
of chemical process equipment, such as hydrogen reconbiners'and materials com-qs cf.; r eIa tids fu e T/cvs patabilityforservice}j.sist otlier than the abovegment. The rule sho eMora llnec/anca fD 81o c nol05 J
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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 only one aspect 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 appropriate General Design Criteria in Appendix A.
We are, however, willing to accept your guidance in this respect.
Your evaluation should consider among other issues, the poter.tial for expediting or delaying issuance of specific portions of the regulation when promulgated spearately relative to their being combined i single broad regulation.
In addition to this request for a proposed new broad rule, we request that it be augumented by Regulatory Guides. A revision of Reg. Guide 1.89 to include the current staff position would probably suffice for electrical equipment qualifica-tion. There is no present equivalent guide for mechanical equipment, hence, this would be a new undertaking. We believe that it is a necessary one. We anticipate that these two mother guides would be supplemented as necessary by appropriate supporting or daughter guides.
We recognize that this additional assignment for the Office of Standards will probablyimpactotherongoingactivifs,therefore,wewillbewillingtodiscuss priorities with you to resolve the budget and schedule matters.
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 October 1, 1980. The staff of the Assistant Director for' Materials and Qualifications will assist you by providing whateverhrmati vailable}thatyoudesireindevelop ing your recocmendations.
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. USER'S REQUEST TO S.D.
u TO:
R. B. liinogue, Director Office of Standards Development FROM:
H. R. Denton, Director Office of fluclear Reactor Regulation
SUBJECT:
STAf;DARD FOR QUAllFICATI0fl 0F SAFE RELATED EQUIPMEriT The Comnission's tiemorandum and Order of flay 23,1980(CLI-80-21), directed that the staff initiate a rulemaking on the subject of environmental qualification of safety grade electrical equipment. We understand that this activity will be undertaken by your staff in direct response to the Comission Order. We have discussed the general subject of equipment qualification standards with your people and desire a broader approach.
We request that OSD evaluate the advisability of developing in a broad single rule making action, an amendment to 10 CFR 50 which would include, 1) the rule making directed by the Com:aission on: environmental qualification of electric q S c e n 3 0 p)>
equipment, 2) the rule making proposed in the Commission paper from I&E3 on independent verification testing and inspection program for environmental qualified equipment, and, 3) broadly address the qualification of both electrical/
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- and cechanical equipment for seismic.and-dynamiciloadings. conditions as well as in a. ye.s ea l arreca ch il:e
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, is broad rule might also address qualification other environmental conditions.
Th of chemical proce D equipment, such as hydrogen recombiners,and materials com-(4 patability for servMw Qdy relattb funcDco s r
n other than the above equipment.
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. f) 2 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 adjresses only one aspect 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 appropriate General Design Criteria in Appendix A.
We are, houcver, willing to accepi. your guidance in this respect.
Your evaluation should consider among other issues, the potential for expediting or delaying issur.nce of specific portions of the regulation when promulgated haratelyrelativetotheirbeingcombinedi single broad regulation.
In addition to this request for a proposed new broad rule, we request that it be Naugumented by Regulatory Guides. A revision of Reg. Guide 1.89 to include the current staff position would probably suffice for electrical equipment qualifica-tion. There is no present equivalent guide for mechanical equipment, hence, this would be a new undertaking. We believe that it is a necessary one. We anticipate r
that these two C N guides would be supplemented as necessary by appropriate er supporting @Idaughtc3 guides.
We recognize that this additional assignment for the Office of Standards will probably impact other ongoing activit s, therefore, we will be willing to discuss 4
priorities with you to resolve the budget and schedule matters.
1 Since we would not want to delay unnecessarily the start of your efforts on portions
- 1) and 2), t e would appreciate receiving your recommendations on this request by October 1, 1980.
ThestaffoftheAssistantDirectorfor![aterialsandQualifications will assist you by pro d ding whatever rmati ilableythat you desire in develo; ing your reco m.andations.
F#1 USER'S REQUE5T TO S.D.
TO:
R. B. Minogue, Director Office of Standards Development FROM:
H. R. Denton, Director Office of Nuclear Reactor Regulation
SUBJECT:
STANDARD FOR QUALIFICATION OF SAFETY RELATED EQUIPMENT The Commission's Memorandum and Order of May 23,1980 (CLI-80-21) directed that,the staff inita[te a rulemaking on the subject of environmental qualification of safety grade electrical equipmant. Uc understand that this activity will be undertaken by your staff in direct response to the Commission Order. We have fidscussed the general subject of equipment qualification standards with your
- 7rople and desire a broader approach.
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We request that the proposed rule and associated regulatory guides address the s
F qualification of both electrical and mechanical equipment for seismic (earth-g Lt quake induced vibrations) and dynamic (vibrating loads resulting from postulated
, accidents) conditions as well as the other environmental conditions (temperature,
.inadva(hf*'I# sprays, etc.) resulting from post [ lated accidents.. The rule should e n~ cad
-J ides address requirements for operating as well as new facilities. He believe that the broader rule would be of greater benefit to the staff and give better guidance to the industry than one that addresses only one aspect of equipment qualification. We suggest that the proposed new rule be in the form of a new appendix to 10 C01 Part 50 which refers back to appropriate General Design Criteria in Appendix A.
He are, however, willing to accept your guidance in this respect.
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In addition to the proposed new rule, we request that it be augc.ented by g
?D f 'icl. n Regulatory Guides. A.v:e;rsion of Reg. Guide 1.89 to include the current staff position would probably suffice for electrical equipment qualification.
Thsre is no present equivalent guide for mechanical equipment, hence, this u t.
would be a new undertaking.
He believe that it is a necessary re.
We anticipatej that these two nother guides would be supplem:nted as necessary by appropriate supporting or daughter guides.
!.'s reccgnize that this additicnal assigna:nt for the Office of St nd:rds
/ill probably inpact other ongoing activities, therefore, we will be willing Y
to discuss priorities with you to resolve the budget and schedule matters.
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