ML20004E369
| ML20004E369 | |
| Person / Time | |
|---|---|
| Issue date: | 02/23/1981 |
| From: | Gregg H NRC OFFICE OF STANDARDS DEVELOPMENT |
| To: | |
| Shared Package | |
| ML19252A551 | List: |
| References | |
| FOIA-81-97, TASK-OS, TASK-SC-138-1 NUDOCS 8106120094 | |
| Download: ML20004E369 (44) | |
Text
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DRAFI PREllMINARY VALUE/lliPACI 5]A]Li'ENI 102 REVISION 10 10 CIR 50 QUALIEICAIl0N DE MECHANICAL EQ'JIPflLNI IMPORIANI 10 SAEEIY
- 1. - PROPOSED ACIION 1.1 Description Issue an Advance Notice of Rulemaking (ANR) as the first step in devel-oping a regulation to require applicants and licensees of nuclear power plants to qualify mechanical equipment important to safety.
~#
1.2 Need A memorandum from H. R. Denton, Director of NRR, to R. B. Minogue, Director of OSD, dated September 2, 1980, defined the need and requested a single rule-making to include environmental qualification of electrical equipment, indepen-dent equipment qualification testing and laboratory accreditation, and qualifi-cation of both electrical and mechanical equipment.' Iha response memorandum from R. B. Minogue, Director of OSD, dated October 3, 1980, recommended separate rulemakings and an attempt to consolidate them at a later date.
Subsequent discussions were held with Z. R. Rosztoczy, Chief of Equipment Qualification Branch, and verbal agreement was reached to proceed with a separate rulemaking for qualification of mechanical equipment.
Additional background which defines a need for this rulemaking is, there are mechanical equipment problems in nuclear power plants.
Ihe large number of continuing monthly Licensee Event Reports (LERs) of valve and pump problems is evidence of mechanical equipment problems, and substantiates the need for the proposed regulation.
'8106120DR 1
H.l. Gry g:cis 2/23/81 A Eecent directives and undertakings are aiwd at electrical equipr.. ant quali-fication.
NRR is preparing an NRC Equipment ialification Program Plan which
.c4Cfw!&
will soon be issued.
This program plan inc esmechagicaleuipmentqualifica-tion.
CF M
D T*
Current /)h requirements for equipment qualification aren't clearly defined and are located under topic headings other than qualification.
The proposed regulation will cicarly identify the equipment qualification require-ment and provide for incorporation of detailed requirement as they are developed.
2.
VAtVE/I!4PfCI 2.1 NRC Equipment qualification should reduce the number of equipment problems and provide additional ensurance of safety in new and operating plants.
The regulation will provide a consistent basis for staff review of con-struction and operating permits.
Cost savings will be obtained in terms of reduced manhours and the licensing process will be accelerated.
- 2. 2 Other Government Agencies Other government agencies, such as the Department of Energy, could be impacted if they have test facilities which could be used, are requested to develop facilities, or are requested to perform subcontracting work related to l
equipment qualification.
There will also be impact on a government agency such as IVA, since this agency is also an applicant or licensee.
l 2.3 Industry 2.3.1 Applicants and Licensees Equipment qualification should reduce the number of equipment problems I
and unscheduled shutdowns.
r b
H. I. Gri ; j i;>
2/20/81 A A clearly identified requirement for equipment qualification will elimi-nate misunderstanding and licensing delays.
There could be significant impact since facilities capable of testing the If test facilities have t be con-largest size equipment are not available.
structed the cost impact will be magnified.
Backfitting costs could be significant if tests of equipment of the same design as existing installed equipment fails qualification.
2.3.2 Manuf(
rers Equipment manufacturers would depend on the licensee's or private test facilities and consultants to perform and evaluate qualification requirements.
They The manufacturers could be severely impacted due to the unknown expense.
may choose not to bid or they may furnish equipment at the licensee's risk.
2.4 Public There Public safety would be improved due to equipment qualification.
would be an increased level of confidence in the industry.
l 3.
TECHNICAL APPROACH 3.1 Alternatives There are many ways to qualify equipment.
Some alternatives are -
(1) qualification testing of actual equipment; (2) qualification testing by (1), in combination with analysis; (3) qualification testing by (1), in combination with similar usage experience; or qualif? cation testing of smaller size of similar, design equipment, l
(4) in combination with tests of actual size equipment or tests of sub-l parts of actual size equipment.
3
g, 2,... ' 1 -
is Additional alternatives and suggestions will be requested of industry and the public in the ANR.
A discussion and decision on the technical approach will be made after all comments are reviewed and evaluated.
- 4.. PROCEDURAL APPROACH 4.1 A_1ternatives The need for a regulation for mechanical equipment qualification has been recognized, and consideration was given to the procedural alternatives of -
(1) issuing a proposed rule; (2) issuing an advance notice of rulemaking before issuing a proposed rule; or '
(3) holding a public meeting to obtain information before issuing a proposed rule.
4.2 Discussion This regulation has significant impact potential, many technical alterna-tives, and possibility for controversies.
There is a shortage of published mechanical equipment qualification national standards, Regulatory Guides, and l
test facilities for large size equipment.
Many issues are undecided and the need exists to obtain industry and public input.
4.3 Decision An advance notice of rulemaking is considered a necessary prerequisite before developing the proposed rule, and is selected as the means to notify industry and the public of the proposed rule and obtain their early participa-tion in its development, G
4
I
. c!s L J.'.1 A 5.
STA1UiORY CONSIDERATIONS 5.1 NRC Authority The requirements for equipment qualification are presently, embodied in many different sections of 10 CFR Part 50, and in one case in 10 CTR Part 100, under topic headings other than qualification.
This rulemaking will expand and clarify existing requirements and make them visible.
5.2 Need for NEPA Assessment The proposed action is not a major action, as defined by paragraph 10 CFR 51.5('a)(10), and does not require an environmental impact statement.
Thiswillberecons[deredaftertheANRcommentsarereceived.
6.
RELATIONSHIP 10 OTHER EXISTING OR PROPOSED REGULATIONS OR POLICfES This proposed rule is closely related to the rulematings currently going forward on (1) electrical equipment qualification and (2) accreditation of laboratories that perform qualification testing.
This proposed rule relates to the TMI-2 Lessons Learned and Action Plan requirements of, qualification and testing of BWR and PWR safety and relief valves, and PWR block valves.
7.
CONCLUSION An advance notice of rulemaking will be prepared as the first step in the development'of a regulation on qualification of mechanical equipment important to safety in nuclear power plants.
5 1
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,,1 A DRAEI l'RLill11f:ARY VALUE/ll11'ACI 5] Alll1LNI 102 REVISION 10 10 ClR 50 QUALIEICAIlON DE l1ECilANICAL EQUIN1ENI IllPORIANI 10 SAEEIY 1.-
PROPOSED ACIION 1.1 Description Issue an Advance Notice of Rulemaking (ANR) as the first step in devel-oping a regulation to require applicants and licensees of nuclear power plants to qualify mechanical equipment important to safety.
1.2 Need A memorandum from H. R. Denton, Director of NRR, to R. B. Minogue, Director of 05D, dated September 2,1980, defined the need and requested a single rule-raking to include environmental qualification of electrical equipment, indepen-dent equipment qualification testing and laboratory accreditation, and qualifi-cation of both electrical and mechanical equipment.
The response memorandum from R. B. Minogue, Director of OSD, dated October 3, 1980, recommended separate l
rulemakings and an attempt to consolidate them at a later date.
Subsequent discussions were held with Z. R. Rosztoczy, Chief of Equipment Qualification Branch, and verbal agreement was reached to proceed with a separate rulemaking for qualification of mechanical equipment.
l Additional background which defines a need for this rulemaking is, there are mechanical equipment problems in nuclear power plants.
Ihe large number of continuing monthly Licensee Event Reports (LERs) of valve and pump problems is evidence of mechanical equipment problems, and substantiates the need for the proposed regulation.
1
.:(1s e
- A Scent directives and undertatings are ai..ed at electrical equir:.nt quali-fication.
IIRR is preparing an llRC Equirn.ent Qualification Program Plan vehich will soon be issued.
This program plan includes mechanical equipment qualifica-tion.
Current legal requirements for equipment qualification aren't clearly defined and are located under topic headings other than qualification.
The proposed regulation will clearly identify the equipment qualification require-ment and provide for incorporation of detailed requirement as they are developed.
2.
VALUE/IliPACI 2.1 l4RC Equipment qualification should reduce the number of equipment problems and provide additional ensurance of safety in new and operating plants.
The regulation will provide a consistent basis for staff review of con-struction and operating permits.
Cost savings will be obtained in terms of reduced manhours and the licensing process will be accelerated.
- 2. 2 Other Government Agencies Other government agencies, such as the Department of Energy, could be impacted if they have test facilities which could be used, are requested to l
develop facilities, or are requested to perform subcontracting work related to l
equipment qualification.
There will also be impact on a government agency such l
as IVA, since this agency is also an applicant or licensee.
1
- 2. 3 Industry i
2.3.1 Applicants and Licensees l
Equipment qualification should reduce the number of equipment problems and unscheduled shutdowns.
l 2
. u: t p
'. 1-A A clearly identified requiru. ant for equir.ent qualification will elimi-nate misunderstanding and licensing delays.
There could be significant impact since facilities capable of testing the largest size equipment are not availab'le.
If test facilities have to be con-structed the cost impact will be magnified.
Cackfitting costs could be significant if tests of equipment of the same design as existing installed equipment fails qualification.
2.3.2 Manufacturers Equipment manufacturers would depend on the licensee's or private test facilities and consultants to perform and evaluate qualification require nents.
The manufacturers could be severely impacted due to the unknown expense.
They may choose not to bid or they may furnish equipment at the licensee's risk.
2.4 Public^
Public safety would be improved due to equipment qualification.
There would be an increased level of confidence in the industry.
l t
3.
TECHNICAL APPROACH l
3.1 Alternatives There are many ways to qualify equipment.
Some alternatives are -
(1) qualification testing of actual equipment; (2) qualification testing by (1), in combination with analysis; (3) qualification testing by (1), k ombination with similar usage experience; or (4) qualification testing d snum size of similar design equipment, in combination with tests of actual aJze equipment or tests of sub-parts of actual size equipment.
3
H.J. Grc;g:tp 2/20/61 A Additional alternatives and suggestions will be rcqa sted of industry and the public in the ANR.
A discussion and decisica on the technical apprcach will be made after all comments are reviewed and evaluated.
4.,
PROCE3 URAL APPROACH 4.1 Alternatives The need for a regulation for mechanical equipment qualification has been recognized, and consideration was given to the procedural alternatives of -
(1) issuing a proposed rule; (2) issuing an advance notice of rulemaking before issuing a proposed rule; or (3) holding a public meeting to obtain information before issuing a proposed rule.
4.2 Discussion This regulation has significant impact potential, many technical alterna-tives, and possibility for controversies.
There is a shortage of published mechanical equipment qualification national standards, Regulatory Guides, and j
test facilities for large size equipment.
Many issues are undecided and the L
need exists to obtain industry and public input.
1 1
l l
4.3 Decision l
An advance notice of rulemaking is considered a necessary prerequisite before developing the proposed rule, and is selected as the means to notify industry and the public of the proposed rule and obtain their early participa-tion in its development.
l 4
H. l. '-
+
2/23/81 - :-A 5.
STATU10RY CON 51DERA110NS 5.1 HRC Authority The requirements for equipment qualification are presently; embodied in many different sections of 10 CFR Part 11), and in one case in 10 CFR Part 100, under topic headings other than qualification.
This rulemaking will expand and clarify existing requirements and make them visible.
5.2 Need for NEPA Assessment Theproposedactionisnotamajoraction,asdefinedbyparagraph 10 CFR 51.5(a)(10), and does not require an environmental impact statement.
This will be reconsidered after the ANR comments are received.
6.
RELATIONSHIP TO OTHER EXISTING OR PROPOSED REGULATIONS OR POLICIES This proposed rule is closely related to the rulemakings currently going forward on (11 electrical equipment qualification and (2) accreditation of laboratories that perform qualification testing.
This proposed rule relates to the TMI-2 Lessons Learned and Action Plan requirements of, qualification and testing of BWR and PWR safety and relief l
valves, and PWR block valves.
l l
7.
CONCLUSION An advance notice of rulemaking will be prepared as the first step in the development of a regulation on qualification of mechanical equipment important to safety in nuclear power plants.
I 5
l
CliiCE OF Si A',
..T TASK CC:iii.0L i LATE:,_ ? /, ?)f R 1, _
================================================.==,
==============::=.===.=====a
REQUESTOR Z. R. Rosztoczy EXT.28035 ORGANIZATION
!;RR TASK LEADER H. I. Gregg INI BR. CHIEF W. F. Anderson INIT
- u)34 TASK'HUMBER SC 138-1
~
DU/PA !! UMBER1111 TASK DESCRIPTION (100 CHARACTERS)
Develop Reg. on Qualif. of l'ech. Equip. via idv. f:otice of Rulemaking Process TASK PRIORITY ^A TASK TYPE START DATE Jan 14.193L ESTIMATED CORP DATE Auo. 15,1981_to issue ANR TASK ACTION ADD X DELETE CHAf:GE TPWiSFER
\\
I!!TO HOLD OUT OF HOLD -
NEW TASK NO. SC 138-1 EFFECTIVE DATE OF ACTION Feb. 2 0, 1981 UORKING DAYS SLIPPAGE
=================================================================================
COGNIZANT INDIVIDUALS DIVISION APPROVAL DATE NRR C. Hofmayer
- DE NMSS IE W. R. Rutherford DRRRI OTHER RES (SPECIFY)
J. Burns /M. Stolzenberg,'
DRSR liregg PS BC. O (W AD_
SD APPROVAL:_TI.
DATE 2// Z
/
ATE DAlt
/ d l DATE l
'DATE APPROVED ASST. DIV. DIR. (SD)
COMMENTS This is the task initiatio'n for developing a regulation on qualification of mechanical equipment 'via an advance ' notice of rulemaking.
a Th3 draft preliminary Value/ Impact Statement is attached.
===================================================c
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cc: SD OFFICE DIRECTOR COGNIZANT DIV. DIRECTOR SD DEPUTY DIRECTOR COGNIZANT INDIVIDUALS SD DIVISION DIRECTOR HPA ANALYST l
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s ADVANCE NOTICE OF PROPOSED RULEMAKING; MECHANICAL ~
EQUIPMENT QUALIFICATION Prepare Prelim. Value/ Impact Statement & TIF 2-20-81 l
TIF Approved 2-30-81 Initial ANR Draft Complete.
3-30-81 Prelim. Interoffice Review Complete 4-25-81 Resolution of Comments Complete 5-15-81 Final ANR Complete 5-25-81 FINAL ANR Concurrence Complete 6-20-81 Submit to ED0/Comission 6-30-81 ANR Published in Federal Register 8-15-81 e
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DRAFT PRELIMINARY VALUE/ IMPACT STATEMENT FOR REVISION TO 10 CFR 50 QUALIFICATION OF MECHANICAL EQUIPMENT IMPORTANT TO SAFETY 1.
PROPOSED ACTION 1.1 Description Issue an Advance Notice of Rulemaking (ANR) as the first step in devel-oping a regulation to require applicants and licensees of nuclear power plants to qualify mechanical equipment important to safety.
1.2 Need A memorandum from H. R. Denton, Director of NRR, to R. B. Minogue, Director of OSD, dated September 2, 1980, defined the need and requested a single rule-making to include environmental qualification of electrical equipment, independent equipment qualification testing and laboratory accreditation, and qualification of both electrical and mechanical equipment.
The response memorandum from R. B. Minogue, Director of OSD, recommended separate rulemakings and an attempt to consolidate them at a later date.
Subsequent discussions were held with Z. R. Rosz.toczy, Chief of Equipment Qualification Branch, and verbal agreement was reached to proceed with a separate rulemaking for qualification of mechani-cal equipment.
Additional background which defines a need for this rulemaking is, there are mechanical equipment problems in nuclear power plants.
The large number of continuing monthly Licensee Event Reports (LERs) of valve and pump problems is evidence of mechanical equipment problems, and substantiates the need for the proposed regulation.
Recent directives and undertakings are aimed at electrical equipment qualification.
NRR is preparing an NRC Equipment Qualification Program Plan 1
- i rg: rp
- 1 k which will soon be issued.
This program plan includes mechsnical equipment qualification.
Current legal requirements for equipment qualification aren't clearly defined and are located under topic headings other than qualification.
The proposed regulation will clearly identify the equipment qualification require-ment and provide for incorporation of detailed requirement as they are developed.
2.
VALUE/ IMPACT 2.1 NRC Equipment qualification should reduce the number of equipment problems and provide additional ensurance of safety in new and operating plants.
The regulation will provide a consistent basis for staff review of con-struction and operating permits.
Cost savings will be obtained in terms of reduced manhours and the licensing process will be accelerated.
2.2 Other Government Agencies Other government agencies, such as the Department of Energy, could be impacted if they have test facilities which could be used, are requested to develop facilities, or are requested to perform subcontracting work related to equipment qualification.
There will also be impact on a government agency such as TVA, since this agency is also an applicant or licensee.
2.3 Industry 2.3.1 Applicants and Licensees Equipment qualification should reduce the number of equipment problems and unscheduled shutdowns.
1 2
H.l. Giegg:rp 2/20/81 A A clearly identified requiiu.ent for equipment qualification will elimi-nate misunderstanding and licensing delays.
There could be significant impact since facilities capable.of testing the largest size equipment are not available.
If test facilities have to be con-structed the cost impact wili be magnified.
Backfitting costs could be significant if tests of equipment of the same design as existing installed equipment fails qualification.
2.3.2 Manufacturers Equipment manufacturers would depend on the licensee's or private test facilities and consbltants to perform and evaluate qualification requirements.
The manufacturers could be severely impacted due to the unknown expense.
They may choose not to bid or they may furnish equipment at the licensee's risk.
2.4 Public Public safety would be improved due to equipment qualification.
There would be an increased level of confidence in the industry.
3.
2ECHNICAL APPROACH 1
3.1 Alternatives There are many ways to qualify equipment.
Some alternatives are -
(1) qualification testing of actual equipment; (2) qualification testing by (1), in combination with analysis; (3) qualification testing by (1), in combination with similar usage experience; or (4) qualification testing of smaller size of similar design equipment, in combination with tests of actual size equipment or tests of sub-parts of actual size equipment.
3
H. l. Gn gg: rp c/ 20/51 A Additional alternatives and suggestions will be requtsted of industry and the public in the ANR.
A discussion and decision on the technical approach will be made after all comments are reviewed and evaluated.
4.
PROCEDURAL APPROACH 4.1 Alternatives The need for a regulation for mechanical equipment qualification has been recognized, and consideration was given to the procedural alternatives of -
(1) issuing a proposed rule; (2) issuing an advance notice of rulemaking before issuing a proposed rule; or (3) holding a public meeting to obtain information before issuing a proposed rule.
4.2 Discussion This regulation has significant impact potential, many technical alterna-tives, and possibility for controversies.
There is a shortage of published mechanical equipment qualification national standards, Regulatory Guides, and test facilities for large size equipment.
Many issues are undecided and the need exists to obtain industry and public input.
4.3 Decision An advance notice of rulemaking is considered a necessary prerequisite before developing the proposed rule, and is selected as the means to notify industry and the public of the proposed rule and obtain their early participa-l tion in its development.
4
H.l. Gregg:rp 2/20/81 A
~'
5.
STATUTORY CONSIDERA110NS 5.1 NRC Authority The requirements for equipment qualification are presently embodied in many different sections of 10 CFR Part 50, and in one case in 10 CFR Part 100, under topic headings other than qualification.
This rulemaking will expand and clarify existing requirements and make them visible.
5.2 Need for NEPA Assessment The proposed action is not a major action, as defined by paragraph 10 CFR 51.5(a)(10), and does not require an environmental impact statement.
4 RELATIONSHIP TO OTHER EXISTING OR PROPOSED REGULATIONS OR POLICIES 6.
This proposed rule is closely related to the rulemakings currently going forward on (1) electrical equipment qualification and (2) accreditation of laboratories that perform qualification testing.
This proposed rule relates to the TMI-2 Lessons Learned and Action Plan requirements of, qualification and testing of BWR and PWR safety and relief valves, and PWR block valves.
l 7.
CONCLUSION An advance notice of rulemaking will be prepared as the first step in the development of a regulation on qualification of mechanical equipment important to safety in nuclear power plants.
1 5
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,=========================-===================================================-=z.
r REQUESTOR Z. R. Rosztoczy EXT.28035 ORGANIZATION URR TASK LEADER H. I. Gregg INIT I BR. CHIEF W. F. Anderson INIT 3 t:4 TASK NUP.BER SC 138-1 DU/PA NiMBER 1111
~
TASK DESCRIPTION (100 CHARACTERS)
Develop Reg. on Qualif. of l'ech. Equip. via Adv. Notice of Rulemaking Process TASK PRIORITY A
TASK TYPE START DATE Jan 14. 1981_
ESTIMATED COMP DATE Auo. 15, 1981 to issue ANF TASK ACTION ADD X DELETE CHANGE TRANSFER INTO HOLD OUT OF HOLD NEW TASK NO. SC 138-1
\\
EFFECTIVE DATE OF ACTION Fek3.10,1981 WORKING DAYS SLIPPAGE
============================================================================-==
COGNIZANT INDIVIDUALS DIVISION APPROVAL DATE 2
IE W. R. Rutherford DRRRI OTHER RES (SPECIFY)
J. Burns /M. Stolzenberg -
DRSR
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SD APPROVAL:._T1. H. I. 'Gregg PS BC_ O S
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p///.81DhTE DATE.23:'./9 /
ATE
- DATr, APPROVED ASST. DIV. DIR. (SD)
DATE COMMENTS
================================================================================
cc: SD OFFICE DIRECTOR COGNIZANT DIV. DIRECTOR SD DEPUTY DIRECTOR 40GNIZANT INDIVIDUALS SD DIVISION DIFECTOR MPA ANALYST
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ADVANCE NOTICE OF PROPOSED RULEfMKING; NECHANICAL EQUIpMENTQUALIFICATION Prepare Prelim. Value/ Impact Statement & TIF 2-10-81
- ?r TIF Approved 2-20-81
- 2. - 3 0 - E I Initial ANR Draft Complete 3-20-81 3
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Prelim. Interoffice Concurrence Complete 4-15-81 4 - sf-8 /
Resolution of Coments Complete 5-5-81 s ~ /f-U
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Final ANR Complete 5-15-81 f - 2 T-T /
Final ANR Concurrence Complete" 6-10-81 4
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Submit to ED0/Comission 6-20-81 6 - La~8/
ANR Published in Federal Register 7-30-81 t-/f-E' l
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2/12/81 A DRAFT PRELIMINARY VALUE/ IMPACT STATEMENT FOR
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M REVISION TO 10 CFR 50 p fp
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$ g' k l, z QUALIFICATION OF MECHANICAL EQUIPMENT IMPORTANT TO SAFETY v,-
/-
1.
PROPOSED ACTION f.,
1.1 Description Issue an Acvance Notice of Rulemaking (ANR) as the first step in'devel-oping a regulation to require applicants and licensees of nuclear er plants to qualify mechanical equipi,3;it important to safety p
~
1.2 Need There are mechanical equipment problems in nuclear power plants.
The large number of continuing monthly Licensee Event Reports (LERs) of valve and pump Poblems is evidence of mecim';al equipment problems, and substantiates the net. for the proposed regulation.
Recent dir ctives and unoartakings are aimed at electrical equipment
' AY qualification Th e n
qu m tQ cation Program Plan in final 1
4 l
stage of preparation.
This program plan includes mechanical equipment qualification.
Current legal requirements for equipment qualification aren't clearly j
defined and are located under topic headings other than qualifica proposed regulation will clearly identify ti.e equipment qualification req 1re-ment ar.d provide for incorporation of detailed requirement as they are developed.
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2r K,E1 A 2.
VALUE/ IMPACT 2.1 NRC Equipment qualification should reduce the number of equipraent problems 4
and provide additional ensurance of safety in new and operating plants.
The regulation will provide a consistent basis for staff review of con-struction and operating permits.
Cost savings will be obtained in terms of reduced manhours and the licensing process will be accelerated.
l
- 2. 2 Other Government Agencies Other government agencies, such as the Department of Energy, could be impacted if they have test facilities which could be used, are requested to develop facilities, or are requested to perform subcontracting work related i
to equipment qualification.
There will also be impact on a government agency such as TVA, since this agency is also an applicant or ifcensee.
- 2. 3 Industry l
2.3.1 Applicants and Licensees Equipment qual'fication should reduce the number of equipment problems and unscheduled shutdowns.
limi-A clearly identified requirement for equipment qualificatiogwill nate misunderstanding and licensing delays.
There could be significant impact since facilities capable of testing the largest size equipment are not available.
If test facilities have to be con-I j
l structed the cost impact will be magnified.
~Rj f
l Backfitting costs could be significant if existing equipment fails ual y
fication a 7~r ;t e, i
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2A 2/81 A 2.3.2 Manufacturers Equipment manufacturers would depend on the licensee's or ripate test s
facilities and consultants to perform and evaluate qualificatiogrequirements.
The manufacturers could be severely impacted due to the unknown expense.
They may choose not to bid or they may furnish equipment at the licensee's risk.
2.4 Public Public safety would be improved due to equipment qualification.
There would be an increased level of confidence in the industry.
3.
TECHNICALAPPkOACH 3.1 Alternatives There are many ways to qualify equipment.
Some alternatives are -
(1) qualification testing of actual equipment; (2) qualification testing by (1), in combination with analysis; (3) qualification testing by (1), in combination with similar usage experience; or (4) qualification testing of smaller size of similar design equipment, in combination with tests of actual size equipment or tests of sub-
~
parts of actual size equipment.
Additional alternatives and suggestions will be requested of industry and the public in the ANR.
A discussion and decision on the technical 1
approach will be made after all comments are reviewed and evaluated.
_.... _ _ _ - - - - - -, _.. _ - ~ - _...... - ~ _ _ _ _ _ - - _
H. i. P cclb i.
/
2/i ; 1-A 4.
PR0CED'Ji:AL APPROACH 4.1 Alternatives Thy need for a regulation far mecpanical equipment qualificatio#n has been
/.ect?
AWM u show, and the decision was made to proceed.
Consideration was given to the procedural alternatives of -
(1) issuing a proposed rule; q pm y>1' (2) issuing an advance notice of rulemaking-rs \\
le (3) holding a public meeting to obtain information.lt
'I 4.2 Discussion This regulatioii has significant impact potential, many technical alterna-tives, and possibility for controversies, here is a shortage of published mechanical equipment qualification Nat4cna tandards, Regulatory Guides, and test facilities for large size equipment.
Many issues are undecided and the
.uh need exists to obtain industry and public input.
j),f.#o
.L.
Y jar J-4.3 Decision y
s dvance notice of rulemaking as considere necessary and was selected as the means to notify industry and the public of the proposed rule and to obtain their early participation in its development.
7-5.
STATUTORY CONSIDERATIONS 5.1 NRC Authority l
Therequirementsforequipmentqualificatiogarepresenti embodied in I
many different sections of 10 CF and @ case '
10' FR "
topic headings other than qualificati is rulemakin xpand and j
clarify existing requirements and make them visible.
~ ~
4 l
N. I. Gre09:cib a
2/12/81 A 5.2 Need for NEPA Assessment The proposed action is not a major action, as defined by paragraph 10 CFR 51.5(a)(10), and does not require an environmental impact statement.
6.
RELATIONSHIP TO OTHER EXISTING OR PROPOSED REGULATIONS OR POLICIES This proposed rule is closely related to the rulemakings currently going forward on (1) electrical equipment qualification and (2) accreditation of laboratories that perform qualification testing.
This proposed rule relates to the THI-2 Lessons Learned and Action Plan requirements of, qualification and testing of BWR and PWR safety ar,d relief valves, and PWR block valves.
7.
CONCLUSION An advance notice of rulemaking will be pr ared as the first step in the
-WI.
development of a regulation on qualification of mechanical equipment important to safety in nuclear power plants.
G 5
~..
'Lf H. I. Gregg:cib 2/12/81 A I
l DRAFT PRELI!!INARY VALUE/ IMPACT STATEMENT TOR REVISION TO 10 CFR 50 QUALIFICATION OF MECHANICAL EQUIPMENT IMPORTANT TO SAFETY
~
1.
PROPOSED ACTION 1.1 Description Issue an Advance Notice of Rulemaking (ANR) as the first step in devel-oping a regu15 tion to require applicants and licensees of nuclear power plants to qualify mechanical equipment important to safety.
1.2 Need There are mechanical equipment problems in nuclear power plants.
The large number of continuing monthly Licensee Event Reports (LERs) of valve and pump problems is evidence of mechanical equipment problems, and substantiates the need for the proposed regulation.
Recent directives and undertakings are aimed at electrical eq0ipment qualification.
There is an NRC Equipment Qualjfication. Program PTan in final stage'of preparation.
This program plan includes mechan'ical equipment i
l qualification.
Current legal requirements for equipment qualification aren't clearly defined and are located under topic headings other than qualification.
The proposed regulation will clearly identify the equipment qualification require-ment and provide for incorporation of detailed requirement as they are, developed.
e 1
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H. l. G-
' c t-2/12/61 - l-is 2.
VALUE/ IMPACT 2.1 NRC Equipment qualification should reduce the number of equipment problems and provide additional ensurance of safety in new and operating plants.
The regulation will provide a consistent basis for staff review of con-struction and cperating permits.
Cost savings will be obtained in terms of
?
reduced manhours and the licensing process will be accelerated.
2.2 Other Government Agencies Other government agencies, such as the Department of Energy, could be impacted if they have test facilities which could be used, are requested to develop facilities, or are requested to perform subcontracting work related to equipment qualification.
There will also be impact on a government agency such as TVA, since this agency is also an applicant or licensee.
2.3 Industry b.
2.3.1 Applicants and Licensees Equipment qualification should reduce the number ofiequipment problems and' unscheduled shutdowns.
A clearly identified requirement for equipment qualification will elimi-(
nate misunderstanding and licensing delays.
There could be significant impact since facilities capable of testing the largest size equipment are not available.
If test facilities have to b,e con-structed the cost impact will be magnified.
1 Backfitting costs could be significant if existing equipment fails qualf-I fication.
l l
i 2
l
. - - - -. - -. -. ~
H.I. Gregg:cib 2/12/81 A 2.3.2 Manufacturers Equipment manufacturers would depe.d on the licensee's or private test n
facilities and consultants to perform and ev.iluate qualification requirements.
The manufacturers could be severely impacted due to the unknown expense.
They may choose not to bid or they may furnish equipment at the licensee's risk.
2.4 Public Public s5fety would be improved due to equipment qualification.
There would be an increased level of confidence in the industry.
TECHNICALAPPkOACH 3.
3.1 Alternatives There are many ways to qualify equipment.
Some alternatives are -
(1) qualification testing of actual equipment; (2) qualification testing by (1), in combination with analysis; (3) qualification testing by (1), in combination with similar usage I.
experience; or (4) qualification testing of smaller size of simil'ar design equipment, in combination with tests of actual size equipment or tests of sub-parts of actual size equipment.
l Additional alternatives and suggestions will be requested of industry and the public in the ANR. A discussion and decision on the technical approach will be made after all comments are reviewed and evaluated.
l 1
i W
H. I. Gregg:cib 2/12/81 A 4.
PROCEDURAL APPROACH
]
4.1 Alternatives l
h The need for a regulation for mechanical equipment qualification has been l
1 shown, and the decision was made to procted.
Consideration was given to the procedural alternatives of -
(
(1) issuing a proposed rule; (2) issuing an advance notice of rulemaking; or l
(3) holding a public meeting to obtain information.
l l
l 4.2 Discussion l
w This regulation has significant impact potential, many technical alterna-j tives, and possibility for controversies.
There is a shortage of published l
mechanical equipment qualification National Standards, Regulatory Guides, and I
test facilities for large size equipment.
Many issues are undecided and the need exists to obtain industry and public input.
b*
4.3 Decision The advance notice of rulemaking was constriered nec'essary and was selected 1
l as the means to notify industry and the public of the proposed rule and to i
obtain their early participation in its development.
l S.
STATUTORY CONSIDERATIONS 5.1 NRC Authority The requirements for equipment qualification are presently embodied in many different sections of 10 CFR 50, and in one case in 10 CFR 100, under topic headings other than qualification.
This rulemaking will expand and clarify existing requirements and make them visible.
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2/12/81 A 5.2 Need for NEPA Assessment The proposed action is not a major action, as defined by paragraph 10 CFR 51.5(a)(10), and does not require an environmental impact statement.
6.
RELATIONSHIP TO OTHER EXISTING OR PROPOSED REGULATIONS OR POLICIE3 This proposed rule is closely related to the rulemakings currently going forward on (1) electrical equipment qualification and (2) accreditation of laboratories that perform qualification testing.
This proposed rule relates to the THI-2 Lessons Learned and Action Plan requirements of, qualification and testing of BWR and PWR safety and relief valves, and PWR block valves.
7.
CONCLUSION An advance notice of rulemaking will be prepared as the first step in the development of a regulation on qualification of mechanical equipment important
~
to safety in nuclear power plants.
6 t
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T;.51; C: M i.0c iL.J:
DATE:_Pj_)J1P4
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REQUE!,10R Z. R. Rosztoczy EXT.28035 ORGANIZATION NRR TASK LEADER H. I. Gregg INIT HIG BR. CHIEF W. F. Anderson
- INIT TASK NUMBER SC 138-1 DQ[PA NUMBER lill
~
TASK DESCRIPTION (100 CHARACTERS) Develop Reg. on Qualif. of Mech. Equip. via Adv. Notice of Rulemaking Process TASK PRIORITY A
TASK TYPE START DATE Jin 14.1981 -
ESTIMATED COM.P DATE July 30,1981 to issue.1NF TASK ACTION ADD _X DELETE _
CHANGE _
TRANSFER __
INTO HOLD _ \\ OUT OF HOLD NEW TASK NO. SC 138-1 EFFECTIVE DATE OF ACTION Feb. 10, 1981 L'ORKING DAYS SLIPPAGE y
===========================================================
....=======
COGNIZhNTINDIVIDUALS DIVISION APPROVAL DATE
[
{
IE W. R. Rutherford DRRRI OTHER RES (SPECIFY)
J. Burns /M. Stolzenberg -
DRSR SD APPROVAL:
- L H.I. Dregg PS8_
BC, AD_
A DATE 2/2/2/
DATE 0.;TE
_ DATE I
APPROVED ASST. DIV. DIR. (SD)
DATE COMMENTS
.....................==============.
================================..============..
cc: SD OFFICE DIRECTOR COGNIZANT DIV. DIRECTOR SD DEPUTY DIRECTOR COGNIZANT INDIVIDUALS
~
SD DIVISION DIRECTOR HPA ANALYST
....o....====.========.=========....=================...================================...
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ADVANCE NOTICE OF PROPOSED RULEl% KING; MECHAf(ICAL EQUI 0 MENT QUALIFICATION Prepare Prelim. Value/ Impact Statement & TIF 2-10-81 TIF Approved 2-20-81 Initial ANR Draft Complete 3-20-81 Prelim. Interoffice Concurrence Complete 4-15-81 Resolution of Coments Complete 5-5-81 Final ANR Complete 5-15-81 Final ANR Concurr.ence Complete 6-10-81 Submit to ED0/Comission 6-20-81 ANRPubYishedinFederalRegister 7-30-81 O
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DI:Afl PREll!!1riARY VALUE/ IMPACT STATElEl4T FOR REVISION TO 10 CFR 50 QUALIFICATION OF MECHANICAL EQUIPMENT IMPORTANT TO SAFETY 1.
PROPOSED ACTION 1.1 Description j
(hMD Issue an Advance Notice of Rulemaking as the first step in developing a l
regulation to require applicants and licensees of nuclear power plants to qualify mechanical equipment important to safety.
1.2 Need' There are mechanical equipment problems in nuclear power plants.
The large number of continuing monthly Licensee Event Reports (LERs) of valve and pump problems is evidence of mechanical equipment problems, and substantiates the need for the proposed regulatic.:.
Recent directives and undertakings are. aimed at electrical equipment quali-fication.
There is an NRC Equipment Qualification Program Plan in final stage i
of preparation.
This program plan includes mechanical equipment qualification.
(
Current legal requirements for equipment qualification aren't clearly defined and are located under topic headings other than qualification. The proposed i
l regulation will clearly identify the equipment qualification requirement and provide for incorporation of detailed requirement as they are developed.
2.
VALUE/ IMPACT 2.1 NRC Equipment qualification should reduce the number of equipment problems and provide additional ensurance of safety in new and operating p'lants'.
1 y
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The regulation will provide a consish'it t. asis for staff review of co l
tion and operating permits.
Cost savings will be obtained in terms of reduced manhours and the licensing process will be accelerated.
2.2 Other Government Agencies Other government agencies, such as the Department of Ener could be impacted l
if they have test facilities which could be used, are requested to develop facil-ities, or are requested to perform subcontracting work related to equipment qualification.
There will also be impact on a government agency such as Ty/ )
since this agency is also an applicant or licensee.
.e
=
2.3 Industry 2.3.1 Applicants and Licensees Equipment qualification should reduce the number of equipment problems and unscheduled shutdowns.
A clearly identified requirement for equipment qualification will eliminate misunderstanding and licensing delays.
There could be significant impact since faci ies capable of testing the l
largest size equipment are not available.
If test facilities have to be con-structed the cost impact will be magnified.
Backfitting costs could be significant if existing equipment fails quali-fication.
2I3.2 Manufacturers
_ Equipment manufacturers would depend on the licensee's or private test facilities and consultants to perform and evaluate qualification requirements.
The manufacturers could be severely impacted due to the unknown expense. They may choose not to bid or they may furnish equipment at the licensee's risk.
2
2.4 Public Public safety would be improved due to equipment qualification.
There would be an increased level of confidence in ths industry.
3.
TECHNICAL APPROACH 3.1 Alternatives There are many ways to qualify equipment.
Somealternativesare(f)
(1) qualification testing of actual equipment; (2) qualification testing by (1), in combination with analysis; (3) qualification testing by (1), in combination with similar usage
. experience; or (4) qualification testing of smaller size of similar design equipment, in combination with tests of actual size equipment or tests of sub-
~
parts of actual size equipment.
Additional alternatives and suggestions will be requested of industry and the public in the ANR.
A discussion and decision on the technical approach will be made after all comments are reviewed and evaluated.
4.
PROCEDURAL APPROACH 4.1 Alternatives l
The need for a regulation for mechanical equipment qualification has been shown, and the r< cision was made to proceed.
Consideration was given to the l
proceduralalternativesof(5)
(1) issuing a proposed rule; l
~(2) issuing an advance notice of rulemaking; or (3) holding a public meeting to obtain information.
1 e
l 3
o 4.2 Discussion This regulation has significant impact potential, many technical alternatives, Nd bl and the need exists-to-obtain-industj_and-pubW-c o nt rov e rs i e s(a n sad ' eq uepm oif clin llfitaiton Inec
--im p W.
There is a shortage of published Natidnal Standards, Regulatory Guides,and 4
test facilities for large size equipment,.end-eanyissues-are undeeided. S if /550c5 a"s undwded and -/be wd ensb to ebfany idushy am/pOc dip,
g 4.3 Decision The advance notice of rulemaking was considered necessary and was selected as the means to notify industry and the public of the proposed rnie and to obtain their early p rticipation in its development.
5.
STATUTORY CONS 40ERATIONS 5.1 NRC Authority The requirements for equipment qualification are presently embodied in many different sections of 10 CFR 50, and in one case in 10 CFR 100, under topic headings other than qualification.
This rulemaking will expand and clarify existing requirements and make them visible.
5.2 Need for NEPA Assessment The proposed action is not a major action, as defined by paragraph
'10 CFR 51.5(a)(10), and does not require an environmental impact statement.
6.
RELATIONSHIP TO OTHER EXISTING OR PROPOSED REGULATIONS OR POLICIES This proposed rule is closely related to the rulemakings currently going
~
forward on (1) electrical equipment qualification and (2) accreditation of laboratories that perform qualification testing.
4
=
This proposed rule relates to the TMI-2 Lessons learned and Action Plan requirements of, qualification and testing of BWR and PWR safety and relief valves, and PWR b1cck valves.
7.
CONCLUSION n advance notice of rulemaking {ANR) will be prepared as the first step i b development of a regulation on qualification of mechanical equipment important to safety in nucicar power plants.
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222 REQUESTOR Z. R. Rosztoczy E AT. 28035 ORGANIZATION
!;RR TASK LEADER H. 1. Gregg IfilT HIG BR. CHIEF W. F. Anderson INIT TASK NUMBER SC 138-1 DU/PAfiUMBER 1111
~
TASK DESCRIPTION (100 CHARACTERS)
Develop Reg, on Qualif. of Mech. Equip. via
- Adv. flotice of Rulemaking Process TASK PRIORITY ~ A TASK TYPE M
uu/ 30 START DATE Jan 14. 1981_
ESTIMATED COMP DA
, 1981 o issue AN TASK ACTION ADD X DELETE CHANGE TRANSFER q
INTO HOLD OUT OF HOLD NEW TASK NO. SC 138-1
\\
EFFECTIVE DATE OF ACfl0N Fe:b.10,1981
. WORKING DAYS SLIPPAGE
.................M.....=..=.....=...===..=.....==.....=..........=..........=......=.==..=.=
COGNIZINT INDIVIDUALS DIVISION APPROVAL DATE NRR C. Hofmayer DE NMSS IE W. R. Rutherford DRRRZ l
OTHER RES (SPECIFY)
J. Burns /M. Stolzenberg
- DRSR
&S$L SD APPROVAL:_TI. H.I. liregg fji_8_
BC.
AD.
e DATE 1/f z/8/
DATE DATE --
DATE s
a l
APPROVED ASST. DIV. DIR. (SD)
DATE COMMENTS oooo.................=........:.....=....===..........==.===.===..........=....=====...======
l l
cc: SD OFFICE DIRECTOR COGNIZANT DIV. DIRECTOR i
SD DEPUTY DIRECTOR COGNIZANT INDIVIDUALS l
SD DIVISION DIRECTOR MPA ANALYST
......................=......=...........=...........==..........................=...........
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ADVANCE NOTICE OF PROPOSED RULEl% KING; MECHANICAL EQUI 0 MENT QUALIFICATION Prepare Prelim. Value/ Impact Statement & TIF 2-10-81 TIF Approved 2-20-81 Initial ANR Draft Complete 3-20-81 Prelim. Interoffice Concurrence Complete 4-15-81 Resolution of Coments Complete 5-5-81 Final ANR Complete 5-15-81 Final ANR Concurr,ence Complete 4-141 = {-10-7l
-Si Submit to ED0/Comission ANRPubYishedinFederalRegister 1 7-30-9i i
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DRAFT PRELIMINARY VALUE/ IMPACT STATEMENT FOR REVISION TO 10 CFR 50 QUALIFICATION OF MECHANICAL EQUIPMENT IMPORTANT TO SAFETY 1.
PROPOSED ACTION 1.1 Description Issue an Advance Notice of Rulemaking as the first step in developing a regulation to require applicants and licensees of nuclear power plants to qualify mechanical equipment important to safety.
1.2 Need There are mechanical equipment problem; in nuclear power plants.
The large number of continuing monthly Licensee Event Reports (LERs) of valve and pump problems is evidence of mechanical equipment problems, and substantiates the need for the proposed' regulation.
Recent directives and undertakings are aimed at electrical equipment quali-fication. 'There is an NRC Equipment Qualification Program Plan in final stage of preparation.
This program plan includes mechanical equipment qualification.
Current legal requirements for equipment qualification aren't clearly defined and are located under topic headings other than qualification.
The proposed regulation will clearly identify the equipment qualification requirement and provide for incorporation of detailed requirement as they are developed.
2.
VALUE/ IMPACT l
2.1 NRC Equipment qualification should reduce the number of equipment problems and provide additional ensurance of safety in new and operating' plants'.
l 1
~
t-The regulation will provide a consistant basis for staff review of construc-tion and operating permits.
Cost savings will be obtained in terms of reduced manhours and the licensing process will be accelerated.
- 2. 2 Other Government Agencies Other government agencies, such as the Department of Energy could be impacted if they have test facilities which could be used, are requested to develop facil-ities, or are requested to perform subcontracting work related to equipment qualification.
There will also be, impact on a government agency such as TVA since this agency is,also an applicant or licensee.
2.3 Industry 2.3.1 Applicants and Licensees Equipment qualification should reduce the number of equipment problems and unscheduled shutdowns.
A clearly identified requirement for equipment qualification will eliminate misunderstanding and licensing delays.
There could be significant impact since facilties capable of testing the l
l largest size equipment are not available, If test facilities have to be con-i
[
structed the cost impact will be magnified.
Backfitting costs could be significant if existing equipment fails quali-l fication.
l 2.3.2 Manufacturers Equipment manufacturers would depend on the licensee's or private test facilities and consultants to perform and evaluate qualification requirements.
The manufacturers could be severely impacted due to the unknown expense.
They l
may choose not to bid or they inay furnish equipment at the licensee's risk.
2 l
2.4 Public Public safety would be improved due to equipment qualification.
There would be an increased level of confidence in the industry.
3.
TECHNICAL APPROACH 3.1 Alternatives There are many ways to qualify equipment.
Some alternatives are (1) qualification testing of actual equipment; (2) qualification testing by (1), in combination with analysis; (3) qualification testing by (1), in combination with similar usage experience; or (4) qualification testing of smaller size of similar design equipment, in combination with tests of actual size equipment or tests of sub-parts of actual size equipment.
Additional alternatives and suggestions will be requested of industry and the public in the ANR.
A discussion and decision on the technical approach will be made after all comments are reviewed and evaluated.
4.
PROCEDURAL APPROACH 4.1 Alternatives The need for a regulation for mechanical equipment qualification has been shown, and the decision was made to proceed.
Consideration was given to the procedural alternatives of (1) issuing a proposed rule; (2) issuing an advance notice of rulemaking; or (3) holding a public meeting to obtain information.
0 3
"6 4.2 Discussion This regulation has significant impact potential, many technical alternatives, and possible controversies, and the need exists to obtain industry and public input.
There is a shortage of published National Standards, Regulatory Guides, test facilities for large size equipment, and many issues are undecided.
4.3 Decisicn The advance notice of rulemaking was considered necessary and was selected as the means to notify industry and the public of the proposed rule and to obtain their early p rticipation in its development.
5.
STATUTORY CONSIDERATIONS 5.1 NRC Authority The requirements for equipment qualification are presently embodied in many different sections of 10 CFR 50, and in one case in 10 CFR 100, under topic headings other than qualification.
This rulemaking will expand and clarify existing requirements and make them visible.
5.2 Need for NEPA Assessment The proposed action is not a major action, as defined by paragraph 10 CFR 51.5(a)(10), and does not require an environmental impact statement.
6.
RELATIONSHIP TO OTHER EXISTING OR PROPOSED REGULATIONS OR POLICIES This proposed rule is closely related to the rulemakings currently going forward on (1) electrical equipment qualification and (2) accreditation of laboratories that perform qualification testing.
5 4
m
---v--
.,et.,e-,
q - -. ---..-
.c
-%.,v-
--+-, -
--w, r
- y. e y
-, - ---y.
r._
,9,,,s-This proposed rule relates to the THI-2 Lessons Learned and Action Plan requirements of, qualification and testing of BWR and PWR safety and relief valves, and PWR block valves.
7.
CONCLUSION An advance notice of rulemaking (ANR) will be prepared as the first step in te development of a regulation on qualification of mechanical equipment important to safety in nuclear power plants.
i 9
=
e 9
9 5
-