ML20043H535

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Summary of 900612 Meeting W/Ge to Discuss GE Guidelines for Evaluation of Potentially Reportable Conditions, Applicability of 10CFR21 to Commercial Grade Procurement/ Dedication & Control of Onsite or Shop Insp
ML20043H535
Person / Time
Issue date: 06/15/1990
From: Grimes B, Potapovs U
Office of Nuclear Reactor Regulation
To: Brach E
Office of Nuclear Reactor Regulation
References
NUDOCS 9006260079
Download: ML20043H535 (5)


Text

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.q hg E. William Brach,J 2 5 1990 l

MEMORANDUM FOR:

ief-Vendor Inspection Branch Division of Reactor Inspection-

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and Safeguards l

Office of Nuclear Reactor Regulation FROM:

Brian K. Grimes, Director Division of Reactor Inspection-and Safeguards Office of Nuclear Reactor Regulation

SUBJECT:

MEETING WITH GENERAL ELECTRIC REPRESENTATIVES J

On June 12, 1990, B. D. Liaw, B. Grimes, and I met with L. Gifford and R. Mitchell of GE Nuclear Energy (GENE) at their request and generally discussed GENE's guidelines for evaluation of potentially reportable conditions (PRC).

Applicability of 10 CFR Part 21 to commercial grade procurement / dedication, and GENE's control of or,-site or shop inspection and refurbishment of circuit breakers were also discussed. A copy of GENE's draft guidelines for PRC evaluation of beyond-design-basis events are enclosed. The " agreed to by NRC" statement is not correct unless we decide to endorse the document after VIB and RSXB review. This memorandum and the draft document are being placed in the PDR.

5/

Uldis Potapovs. Chief l

Reactor Inspection Section No. 2 Vendor Inspection Branch

Enclosure:

GENE's Current Guidelines

'for PRC Evaluation cc: $_ Jones,RSXB l

Distribution:

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MEMORANDUM FOR:

E. William Brach, Chief Vendor-Inspection Branch FROM:

Uldis Potapovs, Chief.

r Reactive Inspection Section No. 2 Vendor Inspection Branch

SUBJECT:

MEETING WITH GENERAL ELECTRIC REPRESENTATIVES

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On June 12, 1990, B.:D. Liaw, B. Grimes, and I met with L. Gifford and c

R. Mitchell of GE Nuclear Energy (GENE) at their request and generally discussed GENE's guidelines for evaluation of potentially reportable conditions (PRC).

J Applicability of 10 CFR Part 21 to connercial grade procurement / dedication, and e

GENE's control of on-site or shop inspection and refurbishment of circuit breakers were also discussed. A copy of GENE's draf t guidelines for PRC evaluation of beyond-design-basis events are enclosed. The " agreed to by HRC" 1

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statement is not correct unless we decide to endorse the document after VIB and RSXB review. 'This memorandum and the draft document are being placed in the PDR.

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W...

Uldis.Potapovs Chigf' Reactor Inspection Section No. 2 Vendor Inspection Branch

Enclosure:

GENE's Current Guidelines for PRC-Evaluation q

k. Jones,RSXB

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ENCLOSURE 5/10/90 Basis for PRC Evaluations of Beyond Desian Basis Events gp/p

, /) sk The following guidelines have been d to by t

, and should be followed in GE Nuclear Energy (GENE) Potentially Reportable Condition (PRC) evaluations:

1)

Events / Evaluations do not need to be reported to the. NRC if they:are shown to be beyond-design-basis.3 2)

Beyond-design-basis events for Minimum Critical Power Ratio (MCPR) safety limit considerations are ones which have a low frequency of' occurrence.

Beyond -the infrequent occurrence category of the Safety Analysis Report (SAR),

i.e.,

less than once every 50 years.2 Frequency of occurrence is acceptable as a consideration-in l determining reportability as long as it is properly -

justified.2 3)

A partial power condition will be the basis for analysis if it is more limiting than full power.2 For evaluation purposes, the most limiting power-level (partial or full power) will be utilized in the analysis.

Fraction of time at a given power level cannot be used to justify a lower frequency of occurrence.

4)

Analyses which show exceedance of the Technical Specification Safety Limit for anticipated events (one or more every 50 years) will be reported to the NRC even if there is no substan-tial safety hazard.I 4

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5/10/90

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The potential for common mode failures will be considered in PRC evaluations.2 Postulated multiple failures which are not related to a common-failure mode'do not have to be considered.3 I

~6)

Hypothetical events cannot be excluded from consideration

~ imply because the event has not been known to occur.4 s

Such events-should be considered in the context of the-other bases given here.

7)

GENE has a responsibility to determine the generic implications

.if GE supplied equipment or information caused the-plant to operate outside the design basis and to inform either their customers gr the NRC.2 8)

If in. doubt on reportability, contact Bill Brach of the Vendor Inspection Branch '(301/492-0961) or Bob Jones of The Reactor

-Systems Branch (301/492-0896)- for an interpretation.

Err on the communicative side References-t 1.

Letter,-R. Artigas to J. G. Partlow, dated 3/7/88 (MFN-018-88).

2.

Letter, B. K. Grimes to N. L. Felmus, dated 10/7/88 (MFN-068A-88).

3.

Letter, P. W. Marriott to B. K. Grimes, dated 9/25/89 (MFN-064-89).

4.

. Letter, G. C. Lainas to P. W. Marriott, dated 2/15/90 (MFN-011-90).

c l-PRCEVAL.TXT,

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5/10/90 L

Additional PRC Evaluation Guideline _1 1.

Changes in MCPR evaluation results which are less than 0.01 (non-conservative) are not considered to meet the significance j

threshold for' potential reportability.

2.

Licensing basis values (wcrst case or bounding) are generally utilized in evaluations.

Use of parameters consistent with the SAR evaluations is the normal basis.

Where individually justified, and with licensing concurrence, limited use of realistic values is permitted.

1 PRCEVAL.TXT

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