United States Nuclear Regulatory Commission - Protecting People and the Environment

Information Regarding the Program for Environmental Qualification of Safety-related Electrical Equipment (Generic Letter 81-05)



                                UNITED STATES
                        NUCLEAR REGULATORY COMMISSION
                           WASHINGTON, D.C. 20555

                              January 19, 1981

ALL LICENSEES OF OPERATING PLANTS AND APPLICANTS FOR OPERATING LICENSES AND 
     HOLDERS OF CONSTRUCTION PERMITS 

SUBJECT:  INFORMATION REGARDING THE PROGRAM FOR ENVIRONMENTAL QUALIFICATION 
          OF SAFETY-RELATED ELECTRICAL EQUIPMENT (GENERIC LETTER 81-05) 

Reference (a) - Order for Modification of License concerning the  
                Environmental Qualification of Safety-Related 
                Electrical Equipement, October 24, 1980 

Reference (b) - Commision Memorandum and Order of May 23, 1980 (80-CLI-21) 

Reference (c) - I&E Bullentin 79-01B Supplement No. 3, October 24, 1980 

On October 24, 1980, the staff issued Orders [Refernce (a)] to all power 
reactor licensees, which modified their Technical Specifications in 
accordance with the Commission-ordered Environmental Qualification 
Requirements [Reference (b)]. The purpose of this letter is to provide 
information in response to licensee requests, regarding these Orders and the
associated staff actions. The specific items to be addressed involve the 
environmental qualification (E-Q) requirements of the electrical equipement 
for the following:  (1) equipment necessary to achieve a cold shutdaown, (2)
replacement parts, (3) Three Mile Island (TMI) Action Plan (NUREG-0737) 
equipment and (4) the June 30, 1982 deadline of Ref. (a). 

(1)  Cold Shutdown - Reference (c) requires licensees to submit E-Q 
     information for the equipment necessary to achieve and maintain a cold 
     shutdown condition. This Bullentin requirement was not intended to 
     invoke a change in the licensing basis of the plant. Plants licenses to
     a hot "safe shutdown" condition are only required by Reference (a) to 
     qualifiy the equipment necessary to achieve a hot shutdown (i.e., plant
     specific safety-related equipment). However, the Bullentin (Reference 
     c) does require that the licensee submit the presently available 
     information for one path to achieve the cold shutdown conditions. The 
     Refernce (c) position represents an enveloping staff position to be 
     implementd on a case-by-case basis. Regulatory Guide 1.139 contains the
     implementation plans for the cold shutdown requirements, of which E-Q 
     is a part. Staff reviews are in progress on this issue. 

(2)  Replacements Parts - We note that this requirement is set forth in 
     reference (b) but not explicitly in the ordering clauses of reference 
     (a). In this regard, the E-Q requirements for replacemenmt parts are 
.

                                    - 2 -

     clearly presented in Supplement No. 2 to IEB 70-01B (September 30, 
     1980). It is the licensee's responsibility to justify deviation from 
     the Category I column of NUREG-0588 in an auditiable manner. "Sound 
     reasons" for such deviation are plant/equipment specific. Examples such 
     as availability or system incompatability, are a matter of degree and 
     will be judged accordingly. 

(3)  NUREG-0737 Equipment - The qualification requirements for this 
     equipment are described in Appendix B to the NUREG. The schedule for 
     submitting the information to the NRC is contained in Reference (c). 
     Contingencies for equipment unavailability are addressed in the NUREG. 
     If the licensee's position on any of this quipment is that it is not 
     safety-related within the meaning of reference (a), that position 
     should be justified in the submittal. Staff judgements in this regard 
     will be made in a Supplement to the original Safety Evaluation. 

(4)  June 30, 1982 Deadline - Some licensees have indicated that the new E-Q 
     requirements have resulted in saturation of the test/production 
     capabilities of the industry, and violations of the deadline may occur.  
     Licensees should note that Ref. (a) orders implemented a Commission 
     imposed deadline [Ref. (b)] and the staff is not authorized to grant 
     relief from this deadline.

Some licensee have submitted either a hearing request or a request for an 
extension of the time to request a hearing in regard to  Ref. (a). Others 
have submitted letters of concern regarding specific requirements. The 
former will be addressed on an individual basis. This letter responds to the 
generic concerns of both groups. 

                         Sincerely, 


                         Darrell G. Eisenhut, Director 
                         Director of Licensing 

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