ML20045H322
| ML20045H322 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 07/13/1993 |
| From: | Klasky M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Pierson R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| IEB-91-001, IEB-91-1, NUDOCS 9307200083 | |
| Download: ML20045H322 (2) | |
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MEMORANDUM FOR:
Robert Pierson, Chief Licensing Branch Division of Fuel Cycle Safety and Safeguards, NMSS THRU:
Michael Tokar, Section Leader Licensing Section 2 Licensing Branch Division of Fuel Cycle Safety and Safeguards, NMSS FROM:
Marc Klasky Licensing Section 2 Licensing Branch i
Division of Fuel Cycle Safety and Safeguards, NMSS
SUBJECT:
TRIP REPORT: JUNE 14, 1993, REGARDING SIEMENS NUCLEAR CRITICALITY SAFETY ANALYSIS UPDATE PROGRAM During the week of June 14, 1993, an inspection of the licensee's incinerator was performed.
The purpose of this inspection was to review the history of operations and to verify that the licensee was taking appropriate actions to identify the cause of the NRC Bulletin 91-01 incinerator event.
Details of the incinerator incident are contained in inspection report 70-1257/93-07.
The status of the licensee's Criticality Safety Analysis (CSA) Update Program was also reviewed and discussed with cognizant licensee representatives. The review verified that the licensee was on schedule for the completion of Phase IB of the CSA update program by the target date of June 30, 1993.
Elements of the program that are included under this phase include:
1.
Validation of assumptions, equipment locations, and listed accident conditions of existing CSAs by Plant Engineering.
2.
Review of engineering validations for NRC Bulletin 91-01 reporting and license requirements.
1 3.
Sorting CSAs into three categories:
Category I - CSAs that need urgent re-analysis due to unfounded assumptions or incomplete accident analysis.
Category II - CSAs that have some deficiencies but can be corrected by addenda for an interim period.
Category III - CSAs that are adequate and will not be revised as part of the update program.
1 At this juncture, it is my opinion that the licensee has organized individual CSAs into " groups" that pertain to a given process system in a reasonable and effective manner. This task is a necessary step in performing accident
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analyses in so far that there are many constituent systems which indirectly affects one another in a given process system.
Understanding the interaction of these constituent systems is essential in performing an integrated safety analysis.
As part of Phase I, the licensee has also performed cursory analyses of existing CSAs.
In these analyses, the licensee has enlisted the engineering.
group to " validate the assumptions" used in the individual CSAs. This i
validation is really only a preliminary verification of the explicit information contained in the CSA. That is, a check is made that equipment exists, dimensions are as stated, the correct enrichment is actually being used, etc. However, the validation does not include all inputs to the system,.
checks with engineering drawings, identification of contingencies, etc. (These elements are scheduled to be addressed in Phase 2 of the CSA update program.)
Thus, it is questionable whether the task of sorting the CSAs into the three previously described categories has been effective.
It is my contention that at this juncture, deficient analyses have only been identified for those cases in which analyses are either nonexistent or whose explicit criteria (i.e.,
dimensions, enrichment, etc.) are found to be incorrect.
Phase 2 of the update program will commence in July 1993. This Phase will include a re-analysis of Category I CSAs that will be prioritized by the potential safety impact and operational requirements. The licensee anticipates that this Phase will take about 7 months to complete.
Some of the elements of Phase 2 are:
(1) verification of systems with facility drawings and design features; (2) establishment of integrated credible accident scenarios for systems grouped into one CSA; (3) second party reviews which will verify layout configurations, dimensions, assumptions, and credible accident scenarios for each system grouping; and (4) incorporation of needed limits and controls into operating procedures. It is hoped that at this time the licensee will also provide a list of all possible contingencies that have been identified for a given process system.
It is my view that this is the most vital task in their CSA update program and must be present for the NRC to perform an adequate review.
M M EM Marc Klasky Licensing Section 2 Licensing Branch Division of Fuel Cycle Safety and Safeguards, NMSS Distribution:
Docket 70-1257
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