ML20045B569
| ML20045B569 | |
| Person / Time | |
|---|---|
| Issue date: | 06/08/1993 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Jordan E Committee To Review Generic Requirements |
| Shared Package | |
| ML20045B565 | List: |
| References | |
| RTR-REGGD-01.160, RTR-REGGD-1.160 NUDOCS 9306180079 | |
| Download: ML20045B569 (4) | |
Text
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UNITED STATES g
NUCLEAR REGULATORY COMMISSION
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WASHINGTON, D. C. 20555 t
i June 8, 1993'
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i MEMORANDUM FOR:
Edward L. Jordan, Chairman l
Committee to Review Generic Requirements FROM:
James M. Taylor Executive Director for Operations l
SUBJECT:
CRGR COMMENTS CONCERNING IMPLEMENTATION GUIDANCE FOR THE MAINTENANCE RULE, 10 CFR 50.65 1
By your memorandum to me dated April 21, 1993, you provided conclusions'and recommendations on the Staff's proposed regula',ory guidance for the-maintenance rule. The following actions have been taken in response to your comments:
1.
The issue regarding " problem diese's generators" is to be addressed by a generic letter to licensees. The Staff = determined that it is not-necessary to rely on accelerated testing to ensure emergency diesel generator reliability if licensees perform a' root cause analysis of a failure. The Staff plans to. propose that those licensees that adopt the maintenance rule guidance regarding emergency diesel generators be allowed to eliminate accelerated testing from'their technical.
specifications. The generic letter is scheduled to_ be issued by December 1993, and will be provided to the CRGR for review prior to that time. The guidance concerning accelerated testing of. " problem diesel generators" was-excluded from the regulatory guidance for the maintenance rule, based on the planned actions' described above.
2.
On April 28, 1993 the DEDR sent a letter to NUMARC to suggest improvements to their guidance document.
A copy of the letter is enclosed.
Item 2 of the DEDR's letter addressed the issue of excessive emphasis in the NUMARC guidance on core damage frequency as an indicator of risk significance.
NUMARC agreed that the modification proposed in the DEDR's letter would be an improvement and revised their guidance-document.
3.
The CRGR described a perceived inconsistency in the NUMARC guidance concerning the definition of " risk significance." The CRGR considered the definition to be somewhat different than that normally used. The Steering Committee to prepare regulatory guidance to implement the maintenance rule reviewed this matter and concluded the use of the term is acceptably explained 'in the text of the NUMARC' guidance document and a clarification is not necessary.
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Edward L. Jordan ;
4 4.
The CRGR recommended that explicit guidance to evaluate the qualification of the members of the licensee established " expert panel" to determine risk significance be provided in the guidance that is to be developed for use by NRC inspectors. The recommendation of the CRGR will be considered during the development of the inspection guidance, i
5.
The CRGR recommended that the NUMARC guidance be clarified on the subject of " inherent reliability." This concept was adopted by NUMARC l
and used in their drafts of their guidance submitted to the NRC. The Staff's position was that the concept is clearly explained but not particularly useful because very few SSCs will be found to be inherently reliable.
This recommendation was described to NUMARC in the first item of the DEDR's letter of April 28, 1993. NUMARC has since modified their guidance document to clarify that an OSC that fails cannot be considered to be inherently reliable.
I 6.
The CRGR offered specific word changes (Recommendation 6.a.) to the first two sentences of the Regulatory Position section of the Staff's Regulatory Guide (since designated Regulatory Guide 1.160), regarding the scope of the maintenance rule. These changes have been incorporated.
7.
The CRGR recommended (Recommendation 6.b.) that HUMARC be advised to delete or modify the sentence in their guidance document, "However, the event is not required to form the basis for requiring SSCs involved in the event to be included within the scope of the Maintenance Rule by utilities that have not experienced the event."
It is considered that this is in conflict with the intent of the maintenance rule.
Item 3 of the DEDR's letter to NUMARC of April 28, 1993 addressed this issue and recommended that wording from another part of the NUMARC guidance that is more compatible with the maintenance rule be substituted.
Although NUMARC did not use the wording recommended in the DEDR's letter, they have revised their guidance document to clarify that events involving non-safety related SSCs that have occurred at a similarly configured plant should be considered for applicability by the reviewing utility.
8.
The CRGR made several additional comments and recommendations (6.c.,
6.d., and 6.e.) relating to the Staff's Regulatory Analysis and Analysis of Public Comments.
The recommended changes have been made.
Enclosed are copies of the regulatory guidance (R. G.1.160 and NUMARC 93-01, May 1993), the Regulatory Analysis, the Backfit Analysis, and the Analysis of Public Co aments.
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$h aiesM.Tafor ecutive Director for Operations
Enclosures:
As stated
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