ML093080063

Letter to NEI on NUMARC 93-01 Revision to EOP Scoping

ML093080063
Person / Time
Site:	Nuclear Energy Institute
Issue date:	11/04/2009
From:	Kobetz T NRC/NRR/DIRS/IRIB
To:	Bradley B Nuclear Energy Institute
Bowen, Jeremy NRR/DIRS/IRIB 415-3471
References
NUMARC 93-01
Download: ML093080063 (3)

Text

November 4, 2009 Mr. Biff Bradley, Director Risk Assessment Nuclear Generation Division Nuclear Energy Institute

SUBJECT:

PROPOSED REVISION TO LANGUAGE SCOPING OF EQUIPMENT USED IN EMERGENCY OPERATING PROCEDURES (EOP) IN NUMARC 93-01, INDUSTRY GUIDELINE FOR MONITORING THE EFFECTIVENESS OF MAINTENANCE AT NUCLEAR POWER PLANTS

Dear Mr. Bradley:

As requested in your letter dated October 1, 2009, we have reviewed the proposed revision to the EOP scoping criteria guidance in NUMARC 93-01. There are some portions of the proposed guidance which we request clarification on, and we would like to discuss the issues during a public meeting. Please be prepared to discuss any specific examples that you believe supports the wording in the proposed revision. The items we would like to discuss include:

• The proposed revision limits systems structures or components (SSCs) used in Emergency Operating Procedures (EOPs) to only installed equipment. We believe this potentially removes equipment that should be scoped under the rule.

• The phrase SSCs used in plant EOPs is quoted and defined in the proposed revision. This phrase is part of exact wording that is used in Title 10 of the Code of Federal Regulations (10 CFR), part 50.65(b)(2)(i). Quoting this phrase implies an attempt to define the meaning of the rule rather than to clarify an earlier portion of the NUMARC guidance. The staff also feels that the proposed clarifying language of essential to mitigation is less conservative than the existing language of must add significant value to the mitigation function.

• When multiple means of achieving an implied function are available, the proposed revision states that only one means needs to be included in the scope. It is not clear to the staff how it would be determined which means would be included and why it is acceptable to exclude the other means.

• Regarding the note at the end of the proposed revision - the basis for allowing exclusion of SSCs from the scope of the rule when it can be demonstrated that a failure of the SSC will not cause a significant change in the expectation of success in accomplishing the EOP mitigating function is not clear to the staff.

We would also like to discuss the agencys plan to address some outstanding issues with regard to maintenance rule implementation and guidance. These include:

• The treatment of external events in risk assessments

• Management of risk during shutdown or low power operations

• Monitoring of unavailability during shutdown

B. Bradley 2 My staff will be contacting you in the near future to arrange a date for a public meeting. If you have any questions, please feel free to contact me at 301-415-1932 or Timothy.Kobetz@nrc.gov.

Sincerely, Timothy J. Kobetz, Chief/RA/

Reactor Inspection Branch Division of Inspection and Regional Support Office of Nuclear Reactor Regulation

B. Bradley 2 My staff will be contacting you in the near future to arrange a date for a public meeting. If you have any questions, please feel free to contact me at 301-415-1932 or Timothy.Kobetz@nrc.gov.

Sincerely, Timothy J. Kobetz, Chief Reactor Inspection Branch Division of Inspection and Regional Support Office of Nuclear Reactor Regulation DISTRIBUTION:

PUBLIC F. Brown, NRR J. Bowen, NRR M. Cheok, NRR S. Vaughn, NRR T. Kobetz, NRR P. Bonnett, NRR R. Franovich, NRR ADAMS Accession Number: ML093080063 OFFICE DIRS/IRIB DIRS/IRIB NAME JBowen TKobetz DATE 11/04/09 11/04/09 OFFICIAL RECORD COPY