ML12340A427
| ML12340A427 | |
| Person / Time | |
|---|---|
| Issue date: | 03/19/2013 |
| From: | Kinneman J NRC/NMSS/FCSS |
| To: | Schlueter J Nuclear Energy Institute |
| Sippel T | |
| References | |
| Download: ML12340A427 (3) | |
Text
March 19. 2013 Ms. Janet R. Schlueter, Director Fuel & Materials Safety Nuclear Generation Division Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708
SUBJECT:
RESPONSE TO TREATMENT OF NATURAL PHENOMENA HAZARDS IN THE INTEGRATED SAFETY ANALYSIS
Dear Ms. Schlueter:
As a result of the U.S. Nuclear Regulatory Commission (NRC) inspections conducted under Temporary Instruction 2600/015, Evaluation of Licensee Strategies for the Prevention and/or Mitigation of Emergencies at Fuel Facilities, the NRC issued a number of unresolved items (URIs) to most of the existing fuel cycle facilities. Because of the similarity of the URIs, the NRC staff considers them to represent a generic issue. Therefore, the NRC staff is currently developing a draft NRC generic letter that will address natural phenomena hazard events and the design/licensing basis of fuel cycle facilities. Once licensees respond to the NRC generic letter, the provided information is expected to enable resolution of the URIs in the context of resolving the generic issue.
The NRC staff has reviewed your letter, Treatment of Natural Phenomena Hazards in the Integrated Safety Analysis, dated October 12, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML122960052) and it will be considered as part of the process for developing the draft NRC generic letter. As part of the generic communication development process, you and other stakeholders will have the opportunity to comment on and provide input to the draft NRC generic letter, during the public comment period. Public meetings will also be arranged to give interested members of the public additional opportunity to comment.
The NRC staff is also interested in the industry establishing a standard methodology and process for addressing natural phenomena hazard events in the context of resolving the generic issue. The NRC staff envisions that either the NRC generic letter or an industry standard methodology, approved by the NRC, would direct facilities to address natural phenomena hazard events and the design/licensing basis of fuel cycle facilities in a consistent and predictable format that includes:
- a review of the process for identifying natural phenomena hazard events included in the ISA and licensing documents,
- any changes based on the current state of knowledge of natural phenomena hazard events,
- the likelihood and consequences of failures of systems structures and components, that lead to radiological and chemical impacts to the workers, public, and environment,
J. Schlueter 2
- a discussion of the current condition of systems structures and components (such as equipment, and walls) as evaluated by walkdowns or other documented processes,
- any proposed or completed modifications necessary for full compliance with the regulations in Title 10 of the Code of Federal Regulations (10 CFR) Part 40, Part 70, or Part 76, as applicable,
- a description of how the facility provides for the adequate protection of the public health and safety under natural phenomena hazard events, including a discussion of the safety margin of systems structures and components, human resources and organizational factors, emergency response plans, training programs and operators.
The NRC staff appreciates the industry efforts aimed at solving these issues. Your proposed methodology provides one potential framework for addressing the issues identified during the NRC staff inspections. However, it should be noted additional work is needed to develop a final product that will result in a consistent and predictable result. A key aspect of an acceptable approach is the development of criteria for determining when the aforementioned issues have been adequately addressed, and agreement on both the level of detail and documentation needed. The NRC staff welcomes the opportunity to further discuss your proposed methodology, any suggested criteria for assessment, and the resolution of these issues during a public meeting.
In accordance with 10 CFR 2.390 of NRCs Rules of Practice, a copy of this letter will be available electronically in the public electronic reading room of the NRCs ADAMS, accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.
If you have any questions regarding this letter, please contact Timothy Sippel at 301-492-3164, or by e-mail at Timothy.Sippel@nrc.gov. If you have questions regarding to the draft NRC generic letter, please contact Jonathan Marcano at 301-492-3263, or by e-mail at Jonathan.Marcano@nrc.gov. I am also available for discussion at 301-492-3123.
Sincerely,
/RA/
John D. Kinneman, Director Division of Fuel Cycle Safety and Safeguards Office of Nuclear Material Safety and Safeguards
J. Schlueter 2
- a discussion of the current condition of systems structures and components (such as equipment, and walls) as evaluated by walkdowns or other documented processes,
- any proposed or completed modifications necessary for full compliance with the regulations in Title 10 of the Code of Federal Regulations (10 CFR) Part 40, Part 70, or Part 76, as applicable
- a description of how the facility provides for the adequate protection of the public health and safety under natural phenomena hazard events, including a discussion of the safety margin of systems structures and components, human resources and organizational factors, emergency response plans, training programs and operators.
The NRC staff appreciates the industry efforts aimed at solving these issues. Your proposed methodology provides one potential framework for addressing the issues identified during the NRC staff inspections. However, it should be noted additional work is needed to develop a final product that will result in a consistent and predictable result. A key aspect of an acceptable approach is the development of criteria for determining when the aforementioned issues have been adequately addressed, and agreement on both the level of detail and documentation needed. The NRC staff welcomes the opportunity to further discuss your proposed methodology, any suggested criteria for assessment, and the resolution of these issues during a public meeting.
In accordance with 10 CFR 2.390 of NRCs Rules of Practice, a copy of this letter will be available electronically in the public electronic reading room of the NRCs ADAMS, accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.
If you have any questions regarding this letter, please contact Timothy Sippel at 301-492-3164, or by e-mail at Timothy.Sippel@nrc.gov. If you have questions regarding to the draft NRC generic letter, please contact Jonathan Marcano at 301-492-3263, or by e-mail at Jonathan.Marcano@nrc.gov. I am also available for discussion at 301-492-3123.
Sincerely, John D. Kinneman, Director Division of Fuel Cycle Safety and Safeguards Office of Nuclear Material Safety and Safeguards DISTRIBUTION:
FCSS r/f DDamon, FCSS AGody, RII NMorgan, RII JMarcano, FCSS MSykes, RII ML12340A427 OFFICE FCSS/PORSB FCSS/PORSB FCSS/PORSB FCSS/EUB FCSS NAME TSippel JMarcano SWhaley TRichmond JKinneman DATE 12/06/12 12/06/12 12/06/12 12/06/12 3/19/13 OFFICIAL RECORD COPY