IEB 79-01b Environmental Qualification of Class 1E Equipment (Generic Letter 80-05)

GL80005

                         SAMPLE LETTER (FOR ACTION)

Docket No(s).                                               Date

NAME AND ADDRESS

Gentlemen:

Enclosed is IE Bulletin 79-01B which requires action by you with regard to 
your power reactor facility with an operating license.

Should you have questions regarding this Bulletin or the actions required of 
you, please contact this office.

                                        Sincerely,



                                        (Regional Director)

Enclosures:
1.   IE Bulletin No. 79-01B with Attachmnets
2.   List of Recently Issued IE Bulletins

CONTACT:  S. D. Ebneter
          (215-337-5296)

.

GL80005                                                    SSINS No.:  6820 
                                                           Accessions No.: 
                                                           7910250528      

                                  ENCLOSURE 1 

                                 UNITED STATES 
                         NUCLEAR REGULATORY COMMISSION                        
                     OFFICE OF INSPECTION AND ENFORCEMENT 
                            WASHINGTON, D.C. 20555 

                                                     IE Bulletin No. 79-01B 
                                                     Date:  January 14, 1980
                                                     Page 1 of 4            

ENVIRONMENTAL QUALIFICATION OF CLASS IE EQUIPMENT 

Description of Circumstances: 

IE Bulletin No. 79-01 required the licensee to perform a detailed review of 
the environmental qualification of Class 1E electrical equipment to ensure 
that the equipment will function under (i.e., during and following) 
postulated accident conditions. 

The NRC staff has completed the initial review of licensees' responses to 
Bulletin No. 79-01.  Based on this review, additional information is needed 
to facilitate completion of the NRC evaluation of the adequacy of 
environmental qualification of Class 1E electrical equipment in the 
operating facilities. In addition to requesting more detailed information, 
the scope of this Bulletin is expanded to resolve safety concerns relating 
to design basis environments and current qualification criteria not 
addressed in the facilities' FSARS.  These include high energy line breaks 
(HELB) inside and outside primary containment, aging, and submergence. 

Attachment 4, "GUIDELINES FOR EVALUATING ENVIRONMENTAL QUALIFICATION OF 
CLASS IE ELECTRICAL EQUIPMENT IN OPERATING REACTORS", provides the 
guidelines and criteria the staff will use in evaluating the adequacy of the 
licensee's Class 1E equipment evaluation in response to this Bulletin. 

In general, the reporting problems encountered in the original responses and
the additional information needed can be grouped into the following areas: 

1.   All Class 1E electrical equipment required to function under the 
     postulated accident conditions, both inside and outside primary 
     containment, was not included in the responses. 

2.   In many cases, the specific information requested by the Bulletin for 
     each component of Class 1E equipment was not reported. 

3.   Different methods and/or formats were used in providing the written 
     evidence of Class 1E electrical equipment qualifications.  Some 
     licensees used the System Analysis Method which proved to be the most 
     effective approach.  This method includes the following information: 
.

Enclosure 1                                         IE Bulletin No. 79-01B 
                                                    Date:  January 14, 1980 
                                                    Page 2 of 4 
                                          
     a.   Identification  of the protective plant systems required to 
          function under postulated accident conditions.  The postulated 
          accident conditions are defined as those environmental conditions 
          resulting from both LOCA and/or HELB inside primary containment 
          and HELB outside the primary containment. 
          
     b.   Identification of the Class IE electrical equipment items within 
          each of the systems identified in Item a, that are required to 
          function under the postulated accident conditions. 

     c.   The correlation between the environmental data requirements 
          specified in the FSAR and the environmental qualification test 
          data for each Class IE electrical equipment item identified in 
          Item b above. 
          
4.   Additional data not previously addressed in IE Bulletin No. 79-01 are 
     needed to determine the adequacy of the environmental qualification of 
     Class IE electrical equipment.  These data address component aging and 
     operability in a submerged condition. 

Action To Be Taken By Licensee Of All Power Reactor Facilities With An 
Operating License (Except those 11 SEP Plants Listed on Attachment 1) 

1.   Provide a "master list" of all Engineered Safety Feature Systems (Plant
     Protection Systems) required to function under postulated accident 
     conditions.  Accident conditions are defined as the LOCA/HELB inside 
     containment, and HELB outside containment.  For each system within 
     (including cables, EPA's terminal blocks, etc.) the master list 
     identify each Class IE electrical equipment item that is required to 
     function under accident conditions.  Pages 1 and 2 of Attachment 2 are 
     standard formats to be used for the "master list" with typical 
     information included. 
     
     Electrical equipment items, which are components of systems listed in 
     Appendix A of Attachment 4, which are assumed to operate in the FSAR 
     safety analysis and are relied on to mitigate design basis events are 
     considered within the scope of this Bulletin, regardless whether or not
     they were classified as part of the engineered safety features when the
     plant was originally licensed to operate.  The necessity for further up
     grading of nonsafety-related plant systems will be dependent on the 
     outcome of the licensees and the NRC reviews subsequent to TMI/2. 

2.   For each class IE electrical equipment item identified in Item 1, 
     provide written evidence of its environmental qualification to support 
     the capability of the item to function under postulated accident 
     conditions. For those class IE electrical equipment items not having 
     adequate qualification data available, identify your plans for 
     determining qualifications of these items and your schedule for 
     completing this action.  Provide this in the format of Attachment 3. 
.

Enclosure 1                                         IE Bulletin No. 79-01B 
                                                    Date:  January 14, 1980 
                                                    Page 3 of 4 

3.   For equipment identified in Items 1 and 2 provide service condition 
     profiles (i.e., temperature, pressure, etc., as a function of time). 
     These data should be provided for design basis accident conditions and 
     qualification tests performed.  This data may be provided in profile or
     tabular form. 

4.   Evaluate the qualification of your Class IE electrical equipment 
     against the guidelines provided in Attachment 4.  Attachment 5, 
     "Interim Staff Position on Environmental Qualification of 
     Safety-Related Electrical Equipment,"  provides supplemental 
     information to be used with these guidelines.  For the equipment 
     identified as having "Outstanding Items" by Attachment 3, provide a 
     detailed "Equipment Qualification Plan." Include in this plan specific 
     actions which will be taken to determine equipment qualification and 
     the schedule for completing the actions. 
     
5.   Identify the maximum expected flood level inside the primary 
     containment resulting from postulated accidents.  Specify this flood 
     level by elevation such as the 620 foot elevation.  Provide this 
     information in the format of Attachment 3. 
     
6.   Submit a "Licensee Event Report" (LER) for any Class IE electric 
     equipment item which has been determined as not being capable of 
     meeting environmental qualification requirements for service intended.  
     Send the LER to the appropriate NRC Regional Office within 24 hours of 
     identification.  If plant operation is to continue following 
     identification, provide justification for such operation in the LER. 
     Provide a detailed written report within 14 days of identification to 
     the appropriate NRC Regional Office.  Those items which were previously 
     reported to the NRC as not being qualified per IEB-79-01 do not require
     an LER. 
     
7.   Complete the actions specified by this bulletin in accordance with the 
     following schedule: 

     (a)  Submit a written report required by Items 1, 2, and 3 within 45 
          days from receipt of this Bulletin. 

     (b)  Submit a written report required by Items 4 and 5 within 90 days 
          from receipt of this Bulletin. 

This information is requested under the provisions of 10 CFR 50.54(t). 
Accordingly, you are requested to provide within the time periods specified 
in Items 7.a and 7.b above, written statements of the above information, 
signed under oath or affirmation. 

Submit the reports to the Director of the appropriate NRC Regional Office. 
Send a copy of your report to the U.S. Nuclear Regulatory Commission, Office
of Inspection and Enforcement, Division of Reactor Operations Inspection, 
Washington, D.C. 20555. 
.

Enclosure 1                                         IE Bulletin No. 79-01B 
                                                    Date:  January 14, 1980 
                                                    Page 4 of 4 

Approved by GAO, B180225 (R0072); clearance expires 7/31/80.  Approval was 
given under a blanket clearance specifically for identified generic 
problems. 

Attachments: 

1.  List of SEP Plants
2.  Master List Standard Format, Typical
3.  System Component Evaluation Work Sheet
4.  Guidelines for Evaluating Environmental Qualification of Class IE 
    Electrical Equipment in Operating Reactors
5.  Interim Staff Position on Environmental Qualification of Safety-Related 
    Equipment (To Addressees Only)