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Category:Memoranda
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2023-02-15
[Table view] |
Text
May 10, 2006 MEMORANDUM TO: Luis A. Reyes Executive Director for Operations FROM: Sher Bahadur, Chairman IRA!
Committee to Review Generic Requirements
SUBJECT:
COMMITTEE TO REVIEW GENERIC REQUIREMENTS: MINUTES OF THE MEETING NUMBER 408 The Committee to Review Generic Requirements (CRGR) Meeting Number 408 was held on April 25, 2006, at 1:00 P.M., with the attendees listed in the Attachment. The purpose of the meeting was to review the Generic Letter (GL), "Post-Fire Safe-Shutdown Circuit Analysis Spurious Actuations." The transmittal memo, GL, comment resolutions, Appendix C questions, and presentation slides are located in ADAMS (respectively, ML060800076, ML060800647, ML060800651, ML060800625, and ML061150192).
Mr. Sunil Weerakkody, Office of Nuclear Reactor Regulation (NRR), gave introductory statements and Mr. Robert Wolfgang (NRR) briefed the CRGR on the proposed GL.
The Committee provided comments and gave recommendations largely on apparent backfit implications, document consistency and clarification, which the staff agreed to incorporate in the revision of the proposed GL.
The following is the list of CRGR recommendations:
- 1. Revise the GL to clearly show how the phrase "one-at-a-time" is connected to the regulatory requirements since it does not appear in any of the regulations.
- 2. Revise the GL to clearly communicate that (a) the staff position has always been that multiple spurious actuations must be considered, and (b) the NEI/EPRI cable fire test results simply reinforced the staff position. The staff should refer to pertinent documents to support the their position.
- 3. The GL appears to be a generic backfit, since the staff acknowledges that a number of licensees may not be in compliance. Explain why the staff is not simply backfitting the licensees.
- 4. Add a paragraph in the GL body that discusses the safety gain associated with its issuance.
- 5. Include a description of the staff's plan and the basis to address potential non-compliance at the "Byron and Braidwood" units.
L. Reyes 2
- 6. Edit the GL to eliminate following wording that goes beyond 10 CFR 50.54f information request:
On page 1, under PURPOSE, item (1) states "Request licensees to...
take additional actions to return to compliance." It is not within the authority of 50.54f to request licensees to take action to return a plant to compliance.
On page 4, line 8 states that licensees "should implement compensatory actions..."
On page.7, the staff states in the "Requested Actions" section, "All licensees are requested to take the following action: ...make plans within 6 months of this letter for plant modifications. . ." An information request should not request licensees to, "make plans" for modifications.
Also, identify and modify any other text where there are indications that the GL oversteps 10 CFR 50.54f authority.
- 7. Avoid implication of backfitting when referencing the EPRI tests. For example, the last paragraph on page 1 states that the EPRI tests form the reason for the GL. This statement would tend to support the view that this is a backfit based on "new information." Amend this and any other similar sentences in the GL.
- 8. Revise parts of the proposed GL where the text is disjointed, particularly in the "Discussion" section, page 3. For example, two paragraphs in this section conclude that alternative requirements (1I G. 3 and ll.L) do not provide the same level of protection as III.G.2. However III.G.2 is not described until the next section, "Applicable Regulatory Requirements," page 5.
- 9. The staff input to Section (3)(ix)(a)(3)(B) of the Appendix C CRGR Charter questions (enclosure 2) discusses how the EPRIINEI cable fire tests "exposed the cables to temperatures more severe than those expected at nuclear power plants for areas where the cables are installed." The paragraph goes on to state that, "The NRC considers safety margins between the test and actual conditions to be significant enough that the integrity of installed cables has a minimal chance of being challenged" and that "the NRC does not foresee a large number of high-risk-significant situations that require expedited regulation." These statements appear contradictory to the statement in the previous paragraph that the EPRI/NEI cable fire tests "showed a relatively high probability of multiple spurious actuations occurring simultaneously or in rapid succession during or after a fire." Explain this apparent contradiction and reflect it in the body of the GL.
- 10. Text in Bin 3, "Comments on Circuit Analysis" (enclosure 3), include comments from TVA that indicate use of the proposed GL requirements on a piloted basis did not identify any applications which were not considered "green" using the
L. Reyes 3 NRC significance determination process. Include a discussion of the pilot program, including the results and how they support the need for the GL, in the body of the GL.
The staff will incorporate CRGR recommendations and resubmit a revised GL package for CRGR review and endorsement.
Enclosure:
As stated cc: See attached list
d B *q L. Reyes 3 NRC significance determination process. Include a discussion of the pilot program, including the results and how they support the need for the GL, in the body of the GL.
The staff will incorporate CRGR recommendations and resubmit a revised GL package for CRGR review and endorsement.
Enclosure:
As stated cc: See attached list E:\Filenet\ML061310097.wpd OAR in ADAMS? (Y or N) Y ADAMS ACCESSION NO.: ML061310097 TEMPLATE NO. CRGR-001 Publicly Available? (Y or N) N. DATE OF RELEASE TO PUBLIC N/A SENSITIVE? N To receive a copy of this document, Indicate In the box: 'C" = Copy without attachmentlenclosure "E"= Copy with attachment/enclosure "N"= No copy
- See Previous Concurrence OFFICE CRGR CRGR NAME L. Cupidon S. Bahadur DATE 05/10/06 05/10/06 (RES File Code) RES
do
L. Reyes 4
4 MEMORANDUM DATED: 05/10/2006
SUBJECT:
COMMITTEE TO REVIEW GENERIC REQUIREMENTS: MINUTES OF THE MEETING NUMBER 408 cc w/atts: (via e-mail)
Chairman Diaz Commissioner McGaffigan Commissioner Merrifield Commissioner Jaczko Commissioner Lyons Annette Vietti-Cook, Secretary of the Commission Luis A. Reyes, EDO William F. Kane, DEDR Martin J. Virgilio, DEDMRS Hubert T. Bell, OIG Karen D. Cyr, OGC Kathryn L. Winsberg, OGC John T. Larkins, ACRS Jack R. Strosnider, NMSS Margaret V. Federline, NMSS James E. Dyer, NRR Roy P. Zimmerman, NSIR Brian W. Sheron, RES James T. Wiggins, RES Farouk Eltawila, RES Sher Bahadur, RES
.Les R. Cupidon, RES Eliot B. Brenner, OPA Michael R. Johnson, OE Samuel J. Collins, Region I William D. Travers, Region II James L. Caldwell, Region III Bruce S. Mallett, Region IV Thomas P. Gwynn, Region IV Richard J. Barrett, RES Bruce A. Boger, NRR Joseph G. Guitter NMSS Theodore R. Quay, NRR Christopher P. Jackson, NRR Sunil D. Weerakkody, NRR Robert J. Wolfgang, NRR
CRGR MEETING No. 408 LIST OF ATTENDEES (April 25, 2005)
CRGR Members Sher Bahadur, Chairman Joseph G. Giitter NMSS/FCSS/SPB for Margaret V. Federline, NMSS Thomas P. Gwynn, RIV Bruce A. Boger, NRR/ADRO for Brian W. Sheron, NRR R. William Borchardt, NSIR Richard J. Barrett, RES/DRASP for James T. Wiggins, RES Kathryn L. Winsberg, OGC Les R. Cupidon, CRGR Staff NRR Theodore R. Quay, NRR/ADRA/DRA Christopher P. Jackson, NRR/ADRA/DPR/PGC Sunil D. Weerakkody, NRR/ADRA/DRA/AFPB Robert J. Wolfgang, NRR/ADRA/DRAIAFPB Raymond H. Gallucci, NRR/ADRA/DRA/AFPB Bob F. Radlinski, NRR/ADRA/DRA/AFPB Brian J. Richter, NRR/DRP/PRAB Theresa M. Valentine, NRR/DORL/LPL1-2 Quynh T. Nguyen, NRR/DRP/PGCB Daniel M. Frumpkin, NRR/DRA/AFPB OGC Geary S. Mizuno, OGC/GCLR/RFC Enclosure
