ML20058C905
| ML20058C905 | |
| Person / Time | |
|---|---|
| Issue date: | 11/19/1993 |
| From: | Pulsifer R Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 9312020618 | |
| Download: ML20058C905 (6) | |
Text
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'o UNITED STATES g
NUCLEAR REGULATORY COMMISSION n
E WASHINGTON, D. C. 20555
/
November 19, 1993 r
ORGANIZATION:
Nuclear Management and Resources Council (NUMARC)
SUBJECT:
MEETING
SUMMARY
- DISCUSSION OF NRC RESPONSE TO NUMARC SECOND DRAFT DOCUMENT " GUIDELINE FOR LICENSING DIGITAL UPGRADES" On October 28, 1993, a meeting was held at NRC Headquarters in Rockville, Maryland, to discuss the second draft of the NUMARC document " Guidelines for Licensing Digital Upgrades," issued September 17, 1993, and the NRC response to this document issued October 26, 1993. Meeting participants included representatives of NUMARC, various utilities and consultants, and employees of the NRC's Office Of Nuclear Reactor Regulation (NRR). A list of attendees is enclosed.
The following items were discussed regarding these guidelines:
NUMARC stated that the second draft of the guidelines focused on NSAC 125 which looks at system level failures. The draft uses the words of NSAC 125 in discussing the 10CFR50.59 process.
NUMARC also stated that credit in an Unreviewed Safety Question (USQ) determination under 50.59 would be taken only for those. systems mentioned in Chapter 15 of the FSAR. The licensee will not be allowed to take credit where credit couldn't be taken for previous modifications.
This document is not to predetermine a 10 CFR 50.59 outcome. The document would provide guidance for what to do whether or not the 50.59 outcome is a USQ.
The second draft was blurred between the 50.59 evaluation and the follow-up evaluation criteria.
NUMARC will review and clarify this area for the final document.
NUMARC feels that requiring a submittal to the NRC because the modification involves a system above a certain " threshold" is precluding a 10 CFR 50.59 result.
It is the licensee's responsibility to perform an evaluation under 10 CFR 50.59 to determine whether a submittal is required. However, NUMARC said the Post Accident Monitoring (PAM) category 1 item changes would not be over the " threshold" because of low complexity, redundant instrumentation, and low probability.
g t-The NRC stated that the electromagnetic interference (EMI) draft document has not been approved and probably should not be referenced in 1
these guidelines. NUMARC stated it agrees that limits have not been I
set, but it is a good reference document.
It is not approved, but
\\q should be referenced under proper context.
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cr-p 1 The NRC stated that the examples should address both evaluations for upgrades that lead to a USQ and some that don't and explain the process once that determination is made.
NUMARC indicated that 15 utilities responded to the second draft and appreciated the NRC response that provided the basis of their comments.
NUMARC intends to publish the final document by the end of 1993. They I
will not request follow-up review by the NRC before publication.
The NRC will issue a Generic Letter following the publication of the
-i final NUMARC guidelines' either endorsing the document, endorsing with comments or providing other guidance. The Generic Letter will probably i
be issued as a draft for public comment in early 1994.
NUMARC is planning a workshop on these guidelines for the first half of 1994, hopefully when the Generic Letter is in draft for public comment.
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Robert M. Pulsifer, Project Manager Project Directorate Ill-3 Division of Reactor Projects III/IV/V Office of Nuclear Reactor Regulation
Enclosure:
List of attendees P
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. The NRC stated that the examples should address both evaluations for upgrades that lead to a USQ and some that don't and explain the process once that determination is made.
NUMARC indicated that 15 utilities responded to the second draft and appreciated the NRC response that provided the basis of their comments.
NUMARC intends to publish the final document by the end of 1993. They will not request follow-up review by the NRC before publication.
The NRC will issue a Generic Letter following the publication of the final NUMARC guidelines either endorsing the document, endorsing with-comments or providing other guidance. The Generic Letter will probably be issued as a draft for public comment in early 1994.
NUMARC is planning a workshop on these guidelines for the first half of 1994, hopefully when the Generic Letter is in draft for public comment.
Original Signed By:
Robert M. Pulsifer, Project Manager Project Directorate III-3 Division of Reactor Projects III/IV/V Office of Nuclear Reactor Regulation
Enclosure:
List of attendees c
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Tony Pietrangelo Siemans Power Corporation NUMARC ATTN: Daryl Hershberger 1776 Eye Street, NW 2101 Horn Rapids Rd.
Suite 300 Richland, Washington 99352 i
Washington, DC 20006-3706 EPRI ABB-Combustion Engineering i
ATTH: Ray Torok ATTN:
Ed Brown P.O. Box 10412 MS 9393-1922 Palo Alto, California 94303 1000 Prospect Rd.
Windsor, Connecticut 06095 MPR Associates ATTH: Bob Fink Westinghouse Corporation 320 King Street Energy Center Site Alexandia, Virginia 22314 ATTN: Carl Vitalbo P.O. Box 355-EPRI Pittsburg, Pennsylvania 15230-0355 i
ATTN: Albert J. Machiels P. O. Box 10412 John Hefler Palo Alto, California 94303 Pacific Gas & Electric Company 77 Beale Street MPR Associates San Francisco, California 94106 ATTN: Jeff Betlack 320 King Steet - 4th Floor Alexandia, Virginia 22314 Commonwealth Edison Company ATTN:
Richard Blauw 125 S. Clark Room 422 Chicago, Illinois 60603 GE - Nuclear Energy ATTN: David Reigel 175 Curtner Avenue i
MK236 San Jose, California 95125 Mr. Michael Hellums TVA 1101 Market Street Chattonooga, Tennesse 37401 Calvert Cliffs Nuclear Power Plant ATTN: Carl Yoder i
1650 Calvert Cliffs Parkway MS-1-DEF Lusby, Maryland 20657
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g-MEETING WITH NUMARC ON DIGITAL UPGRADE GUIDANCE OCTOBER 28, 1993 ATTENDANCE LIST HAHg ORGANIZATION PHONE NUMBER Paul Loeser NRC/NRR/HICB (301) 504-2825 Bruce Boger NRC/NRR/DRCH (301) 504-1004 Jared Wermiel NRC/NRR/DRCH/HICB (301) 504-2821 Tony Pietrangelo NUMARC (202) 872-1280 Robert Pulsifer NRR/DRPW/PD III-3 (301) 504-3016 Edgar Brown ABB-CE (203) 285-9283 Carl A Vitalbo Westinghouse (412) 374-4507 Ray Torok EPRI (415) 855-2776 Bob Fink MPR Associates (703) 519-0200 Albert J Machiels EPRI (415) 855-2054 John Hefler PG&E (415) 973-9766 Jess Betlack MPR Associates (703) 519-0200 Richard J Blauw CECO (312) 394-8893 Dave Reigel GE-Nuclear Energy (408) 925-2094 Michael Hellums TVA (615) 751-2695 i
Carl Yoder, Jr.
BG&E (410) 260-3618 Doug Coe NRR/ACRS staff (301) 492-8972 i
S.V. Athavale NRC/NRR/DRCH/HICB (301) 504-2974 M.E. Waterman NRC/NRR/DRCH/HICB (301) 504-2818 Cliff Doutt NRC/NRR/DRCH/HICB (301) 504-2847 Daryl Hershberger Siemane power Corp.
(509) 375-8100
.i MEETING SUMilARY FOR OCTOBER 28, 1993
-DISTRIBUTION:
Central File NRC & Local P0Rs l
PD3-3 Reading File TMurley/FMiraglia LCallan, Acting JRoe
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JZwolinski JHannon RPulsifer i
MRushbrook OGC EJordan PLoeser BBoger JWermiel SAthavale l
MWaterman CDoutt l
ACRS (10) l BMcCabe MSI7G21 EGreenman, RIII l
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