ML20058P966
| ML20058P966 | |
| Person / Time | |
|---|---|
| Issue date: | 12/09/1993 |
| From: | Sherr T NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Burnett R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9312280026 | |
| Download: ML20058P966 (9) | |
Text
.
- C091933.
MEMORANDUM FOR:
Robert F. Burnett, Director Division of Fuel Cycle Safety and Safeguards FROM:
Theodore S. Sherr, Chief Regulatory and International Safeguards Branch, FCSS
SUBJECT:
STANDARD REVIEW PLAN ACCEPTANCE CRITERIA MEETING, NOVEMBER 15, 1993 -
SUMMARY
On Monday, November 15, 1993, at NRC headquarters, the staff held the third of its series of public meetings with fuel cycle licensees to obtain information relevant to the development of acceptance criteria for the various areas of review within the Standard Review Plan for the Review of a License Application for a Uranium Fuel Processing and/or Fabrication Facility (SRP). Ten representatives of industry were present, in addition to NRC staff and contractor representatives. is the list of attendees.-
In the morning session, the topic addressed was the draft acceptance criteria for the Organization / Management Control and Oversight chapter of the SRP; in the afternoon, the Quality Assurance chapter. Drafts of.these chapters had been mailed in advance to participants who had registered with our coordinator, Joan Higdon.
Introductory remarks were made by Barry Mendelsohn, Section Leader of the -
Regulatory Development Section, Regulatory and International Safeguards Branch (FRIB), and by the SRP Project Manager, Jerry Swift.
For each topic, the chapter was introduced briefly by Willard Brown, the FRIB lead contact for these topics.
In the morning session, this was followed by comments by the industry representatives, with Mr. Felix J. Killar, Jr. taking the lead. is a synopsis of the comments on the draft SRP acceptance criteria for Organization / Management Control and Oversight.
Because the latter part of the session was primarily a discussion, the latter part of Enclosure 2 reports it as discussion.
The afternoon session, on quality assurance, involved considerable discussion between industry representatives and NRC staff, and this is summarized in Enclosure 3 as discussion.
9312280026 931209 Theodores S. Sherr, Chief PDR ACRS Regulatory and International GENERAL PDR Safeguard Branch AQ),1f 5 hYf)
Enclosures:
As stated p
gg k @,,$
DISTRIBUTION:
I NMSS r/f FCSS r/f FRIB r/f Section r/f y d $ At 4 (/
.)
JHigdon, FRIB GBidinger, FRIB RPierson, FCLB LQTenEyck, FCSS Central? Files, Pli37, "PUBLIC"-
FCLBj%h,NAME:
OFC:
FCLB 0FC:
MTokprr q M % )
CEmeT NAME:
20o176 DATE: 12/t/ /93 DATE:
12/1-/93 0FC NMSS:FRIB 6
NMSS:FRIB 6
FRIB._th 6
FRh 6
NAME M Iwift:ga
/[,BMendel sohn Wdkwn Mhb DATE 12/3 /93
[
12/} /93 12//[/93 12/9/93 g:\\1mtg1115.jsm C = COVER ~
E = COVER & ENCLOSURE
.N = NO CDPY
-(
ATTENDEES STANDARD REVIEW PLAN ACCEPTANCE CRITERIA MEETING November 15, 1993 Fuel Cycle Industry John Conant ABB Combustion Engineering Rik Droke Nuclear Fuel Services, Inc.
Wilbur L. Goodwin Westinghouse-Cola., S.C.
Felix M. Killar, Jr.
U.S. CEA Robert J. Klotz ABB Combustion Engineering Peter LeRoy Louisiana Energy Services Charles F. Sanders Westinghouse CNFD-Charles H. Vaughan General Electric Raymond E. Vaughan Siemens Power Corp., ND David C. Ward B&W NNFD Nuclear Reaulatory Commission George Bidinger NMSS/FCSS/FRIB Willard B. Brown NMSS/FCSS/FRIB Stephen P. Burris NRC, NFS Site Chuck Emeigh NMSS/FCSS/FCLB Gordon Gundersen RES
~
Merri Horn NMSS/FCSS/FCLB Ed McAlpine NRC Region II Barry T. Mendelsohn HMSS/FCSS/FRIB Jerome Roth NMSS/FCSS/FCOB Jerry J. Swift NMSS/FCSS/FRIB Michael Tokar NMSS/FCSS/FCLB Others David Cleaves MITRE Corporation James E. Hammelman SAIC Dave Lassiter Martin Marietta Utility Systems, Inc.
c:\\lmtgill5.att ENCLOSURE 1
~
j v.
.i y
.?'
COMMENTS ON THE DRAFT ACCEPTANCE CRITERIA I
FOR-1 ORGANIZATION / MANAGEMENT CONTROL AND OVERSIGHT i
General Comments:
]
1.
The Standard Review Plan (SRP) chapters are too detailed...The. level of-detail goes beyond the content of Parts I and 2 of.the license.. That.
t level of detail is regulatory guide material.
It'is not clear where the 1
license conditions end, and the guidance begins.. We are very concerned that the acceptance criteria should be limited to what is in the license conditions, i.e., what is reouired for license renewal. or a license.
a l
2.
What is-the overall outline for safety? What we have here is separate sections addressing each topic separately. We need an'overall; safety i
philosophy, addressing how the various areas interact.
l 3.
The SRP chapters need to recognize the related sections, to reference them. Each of these SRP_ chapters calls for a team to do a function, without recognizing that these could be done in concert with, or combined with other. functions.
)
4.
Much of the_ terminology comes from the reactor side of.the NRC.
It 1
should recognize that fuel cycle facilities are different, and have risk j
levels much lower-than reactors. References to reactor safety concepts and use of reactor' safety terms should be eliminated.
5.
A number of new terms are used, e. g., Conditions of Operation, vital-5 areas, etc.
It is not. clear whst they mean. The SRP should give definitions for them.
I L
Specific Comments:
6.
This SRP chapter on Management Control and Oversight has~gone overboard.
Look back at Regulatory Guide 3.52.
It would be better to just-reference Reg. Guide 3.52.
j
-t 7.
This chapter gives the Safety Committee too much authority,'i.e., to
- approve changes.- Safety Committees do not have that much authority.
They recommend policy and are advisory only, a
8.
Section 2.3, Audits and Assessments, requires too high a:1evel'of.
j competence for the auditors.. It is not.necessary that the auditors have j
a level of competence equal to or greater than that of the management? of;
~i the section under review.
9.-
In Section 2.4, Design Changes, use of the requirements for 10 CFR 50.59 l
is inappropriate for fuel cycle facilities. The requirements;of 10 CFR-j 70.32 are ap differences.propriate.. [At this point, there was a discussion of the
]
ENCLOSURE 2 j
b j
(
F~
vt-
!T*'J
^v yg-
~~t uewP' M
10.
Section 2.5 is on human factors. We think that human factors have already been taken into consideration in fuel cycle facilities. We do not think that the situation calls for human factors to be a separate safety program at fuel cycle facilities.
11.
Section 2.6 is on Abnormal Events, which it expands too broadly, beyond what is required in 10 CFR 20.2202 and 20.2203. We do not need to determine a root cause for everything.
It is part of management-responsibilities to apply an appropriate, graded level of analysis to the spectrum of events that occur.
12.
The,ection on training is much too extensive. Training requirements are laid out in 10 CFR 19.12 and 70.23(a)(2). We do not need more.
13.
A separate SRP chapter is not needed on maintenance. The regulatory need for maintenance should be developed through the integrated. safety analysis (ISA). The ISA will point to maintenance necessary for systems and components important to safety.
14.
A SRP section en procedures is not needed in such detail. The fuel cycle licensees have been writing procedures for decades.
Safety relies on the training and experience of the operators.
Procedures are a backup.
15.
We do not see a need for a SRP section on recordkeeping.
[The above comments were from Mr. Killar, who, at this point, asked if others had comments.]
16.
Many of these acceptance criteria imply the use of committees and teams.
Safety is best integrated into routine operations.
It is difficult to 4
make it happen with occasional efforts by teams or committees. We'need j
to have it mainstream.
17.
We do not mean to downplay human factors, but it needs to be ingrained in the safety operations, in the normal safety program.
18.
Regarding procedures, the majority of routine jobs get done because the operator is trained in his job. The operator is not constantly referring to procedures.
Procedures are just how you document the normal way to do the job.
Procedures are most useful for non-standard activities.
19.
On recordkeeping, if I have to retrain every two years,.it is unnecessary to keep records for five years.
It is also unnecessary to trend records for five years; only one or two years is important.
i Keeping so many records so long is not useful. Nuclear power plants do not change drastically; their design is static.
Fuel cycle facilities change, with new fuel designs and new programs; fuel cycle facilities are more dynamic.
20.
The SRP requirements should be scaled to the risk. NUREG-1140 describes the threat in worst-case terms, but even that shows that there is not much risk.
Therefore, you should look at how much you need to spend to
~,-
deal with this low risk.
Fuel cycle facilities do not have complex, interrelated systems; they do not have high temperatures and pressures, and they do not have high radiation areas. The entire plant is accessible to operators at individual work stations, and when the electricity. is. shut off, the plant is rendered safe. They are classified as a " Light Industrial Facility." Our market is highly competitive; we are not making a lot of money to throw at programs, to hire new skills, and set up new organizational groups._ These requirements should be looked at in cost-effectiveness terms, what it does for safety.
21.
Section 2.3.7 references the Westinghouse " Conduct of Operations Field Handbook." This is something that is not commonly available.
22.
We are getting a mixed message. NUREG-1140 gives the correct picture:
emergency preparedness is generally not called for. The risk is minimal except in extreme, non-plausible situations. The SRP chapters give a different picture: they call for many programs, many books on the shelf.
This is reactor stuff The risk basis for all these requirements for i
fuel cycle facilities has not been demonstrated.
23.
Our concern is that the SRP will be taken by junior reviewers as 100 percent firm requirements.
24.
Some of the SRP chapters elevate certain topics to a much higher level than can be justified. More integration is needed, rather than compartmentalization.
25.
We have to find a way to get through some regulatory reform, where the safety requirements are commensurate with the risk.
5 26.
As we get into the ISAs, we should be able to define those controls necessary for safety, for criticality, for radiation protection, etc.
But in our facilities, we have many controls; on one line, we might have 150, but of these, only 25 are safety. Most controls are for process control, for quality.
The ISA process will identify where we should spend our efforts.
After the above presentation of comments, there was a discussion between fuel
- 1 cycle industry representatives (FCI) and staff (NRC:
SThe comments labeled "NRC" staff were made by NRC staff and do not necessarily represent the i
agency's authorized position on the issues under discussion),. roughly as 4
follows:
1 NRC: NUREG-ll40 addresses offsite consequences; the NRC is also concerned with worker safety. The ISA should drive the safety process. The ISA l
should tell you where you need to put your safety effort.
FCI: The SRP should not call for this unique skill, human ftetors, to be a t
safety program.
NRC: The history of incidents shows experience with human factors is needed.
FCI: We bring in a human factors expert, but we do not need a free-standing.
j
o f
Ej.
I l
program. We have an open management philosophy; we get feedback from operators, suggestions. Operators get moved around, and thus if one is silent, we can get feedback'from'others.
NRC: This chart [a chart sketched by Willard Brown]-shows how some-of these i
should fit into management oversight.
'~
ji FCI: Quality assurance (QA) is for product, but the facility is built with off-the-shelf components.
NRC: QA is covered in the next session.- QA for the product is your interest.
Our_ interest'is'in QA for the safety program.
FCI: There is a QA program for the product because the product goes-into power reactors.
We do not need the same thing for the' fuel cycle facility itself.
NRC:
In a Commission meeting on Sequoyah Fuels, the Commissioners _ bore down l
on this topic, on how Sequoyah got into trouble.
FCI: Hegarding your SRP requirement that the Safety. Committee review procedure changes, it would be a tremendous burden if the Committee had r
to review each change. There are many small changes. The Committee does not get into the day-to-day details. Change review includes a member of the Safety Committee.
NRC: Every change of the 70.32 type needs a review of all safety aspects.
FCI: Committees cloud responsibility and accountability.
L NRC: What do you see are the differences between the 50.59 and-70.32(c) processes?-
t FCI: The difference is the amount of documentation and oversights in the reviews.
For a fuel cycle facility it takes about 5:pages versus about
_i 30 pages of analysis for a reactor.
10 CFR 50.59_is PRA driven.
PRAs are neither helpful nor desired in our industry.
FCI: Only if a change involves something new, a new process or a new safety question, should we bring it to NRC. Otherwise, it should only be subject to inspection.
NRC:
If you treat a plant change with the ISA. process, you find'out its.
-)
impact on safety due to.all aspects.
7 FCI: At Westinghouse, a minor change would only be an addendum to the ISA,-
1 but we wouldn't update the ISA unless we had a large change, or an j
accumulation of smaller changes.
If we had to go the _ISA with each of the insignificant changes that are made, we would lose an awful lot of-
- time, i
FCI: The 50.59 process is more descriptive and detailed than what we need for fuel cycle facilities, j
t I
l i
NRC: Most 50.59s are a few pages, some are volumes.
NRC: We should get enough detail so that we know what the changes are, and not have to wait for an inspector to find out, i
NRC: What is the difference? Ten CFR 50.59 raises the issue of an unreviewed safety question, and clearly calls out what areas need to be addressed
[ recital omitted] in establishing whether or not there is an unreviewed safety question. The requirements for records seem to be about the same. Thus the big difference is the requirement to determine whether there is an unreviewed safety question.
NRC: Our process will be ISA driven. There might be a greater need to update the safety analysis reports.
NRC:
How many changes would come into this?
FCI: We get many small changes. The small changes are handled through the configuration control process. The main thing is that we don't want any more requirements for non-cost-effective reporting.
FCI: The SRP places too many requirements on audits.
It asks that the auditor be qualified to be a senior analyst; there are not many available.
Its difficult to find them. An auditor doesn't need to be an expert in every area. An auditor can audit the nuclear criticality safety area without being an expert.
NRC: Sequoyah Fuels' main human factors problem was way beyond the control panel design (but that was part of it).
They refused to accept the fact that they needed somebody with a human factors perspective.
FCI: We don't need a human factors person on the staff full time, only when there are large changes.
c:Imtglll5.en2 ENCLOSURE 2
x i
1 DISCUSSION OF THE DRAFT ACCEPTANCE CRITERIA FOR-
}
QUALITY ASSURANCE Willard Brown and Mike Tokar introduced the session with the NRC/NMSS/FCSS view of quality assurance (QA):
(1) We are seeking a graded approach to QA.
1 A precedent was developed in the Division of Low-Level Waste Management and.
Decommissioning, NUREG-1293, April 1981. (2) This draft chapter on QA is more detailed than is reasonable.
The discussion then began between fuel cycle' industry representatives (FCI)
)
[Mr. Killar leading] and staff (NRC:
sThe comments labeled "NRC" were made by-NRC staff and do not necessarily represent the agency's authorized position on the issues'under discussion), roughly as follows:
i FCI: QA is changing.
If it is needed on a pump, it is needed on the function of the pump, not on the ore that went into making the steel that was used in making the pump. QA should be performance based, graded, and based on function..In this SRP chapter, the first paragraph on the 1
first page is reasonable. The rest of the chapter, with 18 criteria, is more' applicable to a power reactor.
NRC:
(1) QA responsibility should go to the top management, not just the i
production supervisor.
(2) The 18 criteria subjects for.QA are i
reasonably applicable, but the way in which you deal with _QA is i
important. We could use something similar to this' chapter, or start i
with a clean sheet of paper.
j 2.
Regarding the specifications for QA management, is. it satisfactory if the safety QA is kept separate from the. product QA? -[NRC staff: We would not want the Production Directors calling' the shots on safety QA.
- l
" Quality at the source" is product-oriented QA.]
l 5
NRC: How to apply a graded QA approach is a topic we would l'ike'to hear from you on.
In the SRP,'how the chapters fit together is the difficult part.
j 3.
If we have the SRP chapter on QA, why do we need the chapter on-Management Controls?
NRC:
(1) Refer to the Branch Technical Position' on Management and Control for
.]
assurance of safety, with feedback. The structure of the organization sets up a safe way of doing business, and a ' feedback mechanism that.lets-management know how it is doing.
(2) The chapter. topics of the draft-l SRP were chosen to make clear,what ought to be addressed in a way that j
we know where to:look for it.
(3) The draft SRP' suffers from the lack of an overall view, an introduction which tells how all the parts fit
.3 together, so that a person can see that it is comprehensive but not redundant.
o ENCLOSURE 3
.l 1
i 1
.i a
j
~
o 4.
This SRP chapter does not appear to be a graded approach.
It seems to insist on QA in all 18 elements. On page 2, it states "it is incumbent upon the applicant to provide justification either for elimination of any elements or minimal use of any elements." We do not want to have to address all 18 automatically.
NRC:
(1) If the QA program does not include all 18 criteria, the applicant should give the rationale why not.
(2) The SRP is guidance for reviewers to look for the various aspects of the program. A SRP is just a guidance document, on just one approach, but the licensee has the option to use another, with justification.
If one criterion is inapplicable, just say so.
(3) The burden of safety falls on the licensee; the reviewer should not have to rely on his personal experience to say that the QA for this facility is acceptable.
5.
If we have an organization that works, and does not need a QA box in its management diagram, is it acceptable without a QA box?
NRC: We need, in reviewing, to be able to find the QA in the organization.
6.
You have said in the past, that what you want is a high probability of not impacting the public. We can achieve that without such an elaborate QA program.
NRC:
(1) Your plants are not static. You get new products, new lines, new facilities which need to be addressed from the QA standpoint. With new structures, you may need to address QA in design.
(2) Your QA might be in your regulatory operations.
You must assure independent reviews by other people. There is the issue of independence, and the issue of independent audits.
7.
We have been operating our facility for 25 years. What do you perceive that we should be doing that we haven't? Do we need to just document the existing system, or do we need to beef it up?
NRC:
(1) We need an ISA based system, that calls up which controls are needed.
(2) Documentation is sparse; current licenses are not i
adequately detailed.
1 8.
On page 6, it indicates that we should submit the QA' program for the NRC f
to review for acceptance. What is necessary for acceptance?
NRC:
(1) We do not know what we want yet; at the bottom of page 6, see the l
sentence beginning with "However."
(2) This gets back to the parts of the SRP acceptance criteria.
For each of 18 areas, they are called out.
j for example, see section 3.4.3.1..." are acceptable if."
(3) You need i
to do some hard thinking of what you need to defend yourselves.
1 1
ENCLOSURE 3 l
~
1 t
e.
C 9.
We want to help draft reasonable requirements.
NRC: This document is wide open for improvement. We want you to help in this.
1 c:\\1mtg1115.en3 ENCLOSURE 3