ML20058K115
| ML20058K115 | |
| Person / Time | |
|---|---|
| Issue date: | 10/20/1989 |
| From: | Jordan E Committee To Review Generic Requirements |
| To: | Arlotto G NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20058A334 | List: |
| References | |
| NUDOCS 8911020125 | |
| Download: ML20058K115 (11) | |
Text
October 20, 1989 MEMORANDUM FOR:
Guy A. Arlotto, NMSS Jack R. Goldberg, OGC Luis A. Reyes, RII Denwood F. Ross,'RES James H. Sniezek, NRR j
i FROM:
Edward L. Jordan, Chairman k
Committee to Review Generic Requirements i
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SUBJECT:
MEMORANDUM ON CRGR REVIEW-PACKAGES
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Based on comments received from my memorandum of August 23, 1989, the descrip-tion of the analysis needed-in the CRGR package has-been reworced. The example summary statement for.a compliance exception has been replaced and several
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example evaluations have been added.
c I would like to discuss this. package at the CRGR meeting on Octeoer anc to issue the draft memo within 5 days'following the meeting if there are25, 1989, not major comments.
c Originals;gned by: '
ELkdm Edward:L. Jordan, Chairman Committee to Review Generic
= Requirements
Enclosures:
As stated Distribution:
Central File (w/o ene.)
CRGR CF CRGR SF E. Jordan J. Heltemes J. Conran
- . Allisoin i
i to Enclosure 4 M
AL OFC AE00:
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NAME :0Allison:cg : CJ temes
- dan DATE I o/l4/89
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i gM{M OFFICIAL RECORD COPY
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'-ORAFT-o MEMORANDUM FOR:
Thomas E. Murley, Oirector.
Office of.Huclear Reactor Regulation-Eric S. Beckjord, Director Office of Nuclear Regulatory Research Robert M. Bernero, Director-Office of Nuclear Materials Safety and safeguards FROM:
Edward L. Jordan, Chairman Committee to Review Generic Requirements
SUBJECT:
SUBMITTAL OF CRGR REVIEW PACKAGES In response to concerns expressed by many licensees and discussion with the E00 on this subject, I am requesting that the following action be implemented on all future packages submitted for CRGR review.
A new summary section should be included in bulletins and generic letters considered by CRGR to clearly identify if a backfit is' involved and if so, how the backfit is justified, 'i.e., necessary for adequate protection, necessary to orir.g the facilit/ into compliance, or cost-justified safety enhancement.
Examoles of such summary statements are provided in Enclosures 1, 2.and 3.
We will compile further examples and make them available in'the near future.
Consistent with the type of backfit, an analysis should be included in the-CRGR-review package that justifies the identified backfit as follows:
1.
For cost-justified safety enhancements, the' regulatory analyses ana other i
i information already called for (and'being provided) under current practice snould be sufficient.
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2.
For compliance issues, an evaluation is needed which identifies the objectives of and reasons for the modification and the basis for invoking the compliance exception.
The analysis needs to connect the requested action to a bonafide NRC regulatory requirement and a previously approved 3
implementing staff position, if one exists. Note: compliance exceptions are limited to cases of error or omission in implementing current require-I t
ments; new or modified interpretations of requirements would not fall-within this exception, and need to be addressed'under.one of~the other.
categories.
Examples of evaluations _for compliance issues are provided in Enclosures 4 and 5.
3.
Similarly, for adequate protection-issues an evaluation _ identifying the objectives of and reasons for the backfit and the-basis for invoking the adequate protection exception is needed.
In discussing proposed actions with the CRGR,-a change is being requested in how staff presentations are conaucted, Presentations should focus on'the basis and justification for. the request under_ the backfit rule.
This will make more effective use of the time available for review of eacn issue.
r Edward L. Jordan, Chairman l
Committee to Review Generic i
i Requirements
Enclosures:
o 1.
Example Summary Statement - Cost L
. Justified Enhancement
- 2. _ Example Summary-Statement - Compliance 3.
Example Summary Statement Compliance 4
Examole Evaluation - Compliance-5.
Example Evaluation - Compliance l
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L EXAMPLE SUMARY STATEMENT - COST JUSTIFIED ENHANCEMENT Pencing Generic Letter on GI-70 and GI-94 i
A section will be included entitled, Backfit Discussion.
For GI-70 the actions proposed by the NRC staff. to improve the reliability of PORVs and block valves, as identified in Section 3 of Enclosure A, represent new staff positions for some-licensees and CP holders, and this request is considered'a backfit in accordance with NRC procedures.
This backfit is a cost-justified safety enhancement.
Therefore, a backfit analysis of the type described in 10 CFR 50.109(a)(3) and 10 CFR 50.109(c) was performeJ and a determination was made that there will be a substantial'increar in overall protection of the public health and safety and that the costs are justified in view of this increased protection.
The' analysis and determination will be made available in the Public Document Room with the minutes'of the 167th.and 168th meetings of the Committee to Review Generic Requirements.
It is noted that most of the recommended actions for GI-70 may already have been implemented by those plants that have received operating licenses in recent years. This would, therefore, represent less of a backfit for newer PWR plants than for older PWR plants that currently do not include PCRVs.and block valves in the ASME Section XI Inservice Testing Program and do not'have techni-cal specifications for PORVs and block valves or that operate with the block valves closed due to leaking PORVs.
For GI-94, the actions preposed by the NRC staff to improve the availability of the low-temperature overpressure protection (LTOP) system, as identified in
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h l-2 Section 3 of' Enclosure B,~ represent a new interpretation of existing require for some licensees and CP. holders, and this request is considered a backfit in accordance with NRC procedures.
This backfit is a cost-justified safety enhance-Therefore, a backfit analysis' of tne type described in 10 CFR 50.109(a ment.
j and 10 CFR 50 109(c) was performed and a determination was made that there w l
be a substantial increase in overall' protection of the.public health and safety and that the costs are justified in view of this increased protection.- The analysis and determination will be made'available in the Public Document Room with the minutes of the'167th and 168th meetings of the Committee to Review Generic Requirements.
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3 HOTE:
In this example the backfit discussion is divided into two parts because GI-70 represented an additional staff positions whereas-GI-94 i
represented a new interpretation of existing requirements.
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EXAMPLE
SUMMARY
STATEMENT - COMPLIANCE NRC Bu11stin 88-01:
Defects in Westinghouse Circuit Breakers
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r A new section would be added entitled, Backfit Discussion, i
The actions requested in this bulletin' represent new staff positions'and-thi :
'l request is considered a ba'ckfit in accordance with NRC procedures.
Because
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established regulatory requirements exist but were not_ satisfied, this backfit I
is to bring facilities into compliance with existing requirements.
Therefore,
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a full backfit analysis was not performed. An evaluation of the type discussed in 10 CFR 50.109(a)(6) was performed, including a statement of the objectives of and reasons for the modification and the basis for invoking the compliance exception.
It will be made available in the Public Document Room with the minutes of the 128th meeting of the Committee to Review Generic Requirements.
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Enclosure.3-
. EXAMPLE
SUMMARY
STATEMENT - COMPLIANCE IE. Compliance Bulletin No. 86-01: Minimum Flow Logic Problems That Could Disable RHR Pumps-i A new section would be added entitled, Backfit Discussion.
1.
j The actions requ'ested in this bulletin represent new staff positions and thus, this request is considered a backfit in eccordance with WRC procedures.
Because established regulatory requirements exist but were.not satisfied, this backfit is to bring facilities into compliance with existing requirements.
There fore, a full beckfit analysis was not performed. An evaluation of the type discussed in 10 CFR 50.109(a)(6) was performed, including a statement of the objectives of.
and reasons for the modification and the basis for invoking the compliance exception.
It will be made available in the Pubitc Document Room with the minutes of the meeting of the Committee of Review Generic Requirements.
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l Note:
This examole is for illustration only.
There was not actually a CRGR meeting on this bulletin.
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EXAMPLE EVALUATION - COMPLIANCE-I NRC Bulletin 88-01:. Defects in Westinghouse Circuit Breakers.
Objectives of Backfit The objective of this action is to ensure that certain Westinghouse circuit '
breakers are free of manufacturing defects that could impair their reliability or performance in safety related applications, i
l-l Reasons for Backfit As discussed in the bulletin, installed circuit breakers may contain defects.
Thus, inspection and repair (as appropriate) are necessary to find and eliminate any such defects and to assure the level of performance and reliability previously assumed in the licensing bases.
Basis for Invokina Como"ence_ Exception Reliability and Quality assurance provisions applicable to protection systems and to welds in circuit breakers installed in safety-related: applications are
. discussed in GDC 1 and GDC 21 of Appendix A to 10 CFR.Part 50 and Criteria IX, X, XIV and XVI of Appendix B to 10 CFR Part 50.
Inherent in'these provisions is that protection systems should be reliable, telding-should be controlled to preclude defects that could adversely affect performance, weld's s'hould be' inspected, the inspection status should be known,-and known defects should be These provisions, or similar provisions, have'been applied in the corrected.
licensing bases of power reactors to various degrees at various' times in the past and they-represent generic staff positions approved before October 21, 1985.
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As discussed in the bulletin there have been recent reports of weld failu in certain Westinghouse circuit breakers.
The weld failures can affect the breaker performance.
Manufacturing / quality assurance inadequacies have allowed the defects to progress to installed breakers and the status of welds in installed breakers is uncertain.
This situation is contrary to the conditions inherent in current requirements, as discussed above, and thus represen case of error or omission in implementing current requirements.
Westinghouse subsequently issued a technical bulletin to address the weld f ailures and the NRC has found that it adequately addresses concerns failures.
The NRC has determined that inspection and repair (as appropria tre needed to ensure that installed breakers are free from manufacturing d and, thti, will have the performance and reliability margins assumed-in the licensing M ees.
Since this inspection was not previously required, this request is considered a backfit.
Because established regulatory requirements exist but were not satisfied and no new interpretations or clarifications are invcived, this backfit is to bring facilities into compliance with existin recairements.
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i EXAMPLE EVALUATION - COMPLIANCE IE Compliance Bulletin No. 86-01: Minimum Flow Logic Problems that Could Disable RHR Pumps t
i Objectives of Backfit The objective of this action is to ensure that emergency core cooling systems in boiling water reactors are free of design errors that could rencer them vulnerable to single failures.
Reasons for Backfit As discussed in the bulletin, reported single failure vulnerabilities may exist i n the emergency core cooling systems for boiling water reactors.
Thus, review, evaluation and corrective action (as appropriate) are necessary to find and eliminate any such problems and to assure the redundancy assumed in the i
licensing bases.
Basis for invokino the Compliance Exception GDC 35 of 10 CFR Part 50, Appendix A, and 10 CFR 50.46(d) discuss single fa reouirements for emergency core cooling systems. These provisions have been made applicable to all power reactors (for example, in the application of 10 CFR 50.46(d) to all plants in 1974), and they represent a generic requirement approvec before October 21, 1985, i
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i As discussed in the bulletin, a design problem has been identified at some plants that could allow a single failure, if not recognized and corrected b operator action, to disable all LPCI (RHR) pumps following a loss-of coolant j
accident.
The conditten could exist at other plants.' This situation is l
contrary to the requirement discussed above, and thus represents a case of error or omission in implementing current requirements.
The NRC has detarmined that examination (and correction, as appropriate) be needed to ent.ure that plants are free of the identified problem.. $1nce this action was eot previously required, this request is considered a backfit Because established rcgul: tory requlrements exist but were not satisfied an new ir,terpretations or clarifications are involved, this backfit is to bring facilities into compliance with existing requirements.
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