ML20058P982
| ML20058P982 | |
| 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 9312280029 | |
| Download: ML20058P982 (8) | |
Text
c MEMORANDUM FOR:
Robert F. Burnett, Director JECg,g1881 Division of Fuel Cycle Safety and Safeguards FROM:
Theodore S. Sherr, Chief Regulatory and International Safeguards Brancn, FCSS
SUBJECT:
STANDARD REVIEW PLAN ACCEPTANCE CRITERIA MEETING, NOVEMBER 16, 1993 -
SUMMARY
On Tuesday, November 16, 1993, at NRC headquarters, the staff held the fourth' and last 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).
Twelve representatives of industry were present, in addition to NRC staff and contractor representatives. is the 7!st of attendees.
For this meeting, the topic addressed was the draft acceptance criteria for the SRP chapter on nuclear criticality safety.
The current revision of this chapter 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. The chapter was introduced by George Bidinger, the FRIB lead contact for nuclear criticality safety. This was followed by comments by the industry representatives, with Mr. Felix J. Killar, Jr. taking the lead. is a synopsis of these comments.
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Theodore S. Sherr Regulatory and Internationa'.
Safeguards Branch, FCSS
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Enclosures:
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DISTRIBUTION:
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PDR " Advance Copy" TSSherr, FRIB LTenEyck, FCSS JHigdon, FRIB CEmeigh, FCLB JRoth, FCOB RPierson, FCLB Rfokar, FCLB 9312200029 931209 0FC:
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DATE 12/f/93 E
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I ATTENDEES STANDARD REVIEW PLAN ACCEPTANCE CRITERIA MEETING November 16, 1993 i
Fuel Cycle Industry John Conant ABB CE, Windsor,CT Rik Droke Nuclear fuel Services, Inc.
Wilbur L. Goodwin Westinghouse, Cola.,SC t
Larry Hassler B & W Fuel Co.
Brian 0. Kidd B & W NNFD 1
Felix M. Killar, Jr.
U.S. CEA Robert J. Klotz ABB CE, Windsor,CT Peter LeRoy Louisiana Energy Services Calvin D. Manning Siemens' Power Corporation Charles F. Sanders Westinghouse, Cola.,SC Raymond E. Vaughan Siemens Power Corporation Fred G. Welfare General Electric, Wilm.,NC Nuclear Reaulatory Commission i
Raj Auluck RES George Bidinger NMSS/FCSS/FRIB Willard B. Brown NMSS/FCSS/FRIB Gordon Gundersen RES Marc Klasky NMSS/FCSS/FCLB Ed McAlpine Region II Barry T. Mendelsohn NMSS/FCSS/FRIB Richard Milstein NMSS/FCSS/FCLB i
Jerome Roth NMSS/FCSS/FCOB Theodore S. Sherr NMSS/FCSS/FRIB Jerry J. Swift NMSS/FCSS/FRIB Mary L. Thomas RES I
Michael Tokar HMSS/FCSS/FCLB i
Qthers Mickey Beary SAIC James E. Hammelman SAIC Dave Lassiter Martin Marietta Utility Systems, Inc.
c:\\lmtgill6.att ENCLOSURE 1 u
y i
COMMENTS ON THE DRAFT ACCEPTANCE CRITERIA FOR J
NUCLEAR CRITICALITY SAFETY The following are comments from fuel cycle industry representatives ~(FCI)
[Mr. Killar leading) and responses from NRC staff (NRC).
(NRC:
5The comments labeled "NRC" staff were made by NRC staff and do not necessarily represent' the agency's authorized position on the issues under discussion.)
FCI:
I.
The St;ndard Review Plan (SRP) should reflect' only the requirements of 10 CFR Part 70.
ihe guidance should be put into Regulatory Guides.
This would help make clear to new reviewers what is required versus guidance.
2.
The writers of the SRP should stay away from reactor jargon. Also, some terminology needs to be defined, e.g', Conduct of Operations.
3.
The required qualifications for management go beyond the Part 70 requirements. The plant manager doesn't need an engineering degree to.
i be a manager, especially if the economics of the operation are critical.
l 4.
Chapter 6 is a good chapter in the draft SRP.
It shows a lot of.
thought.
5.
Section 6.2, in the second paragraph, refers to a commitment to upgrade I
the' nuclear criticality safety (NCS) program. There shouldn't be a requirement to upgrade an existing good program, just because we have come in for a license renewal. Also, there is a concern that Section 6.2.2 appears to call for submittal of operating procedures, as-builts, etc. which are not normally submitted.
NRC: The reference to as-built drawings, etc, in Section 6.2.3(d) means that i
they should be part of the Configuration Control program, not that they should be submitted for review. The commitment to upgrade referred to, means that we want to see expressed a management philosophy to work to enha' ice their NCS system.
FCI: The concern is what a new reviewer, or an inspector, will make out of it.
6.
We don't see a need for all the limits in Section 6.2.3(b), failure limits, safety limits, and operating limits.
7.
In the paragraph at the top of page 6-3 is a statement that "no other activity will.be authorized." This is too restrictive; there are a lot-of activities that take place that are internal to plant operations that; are not so significant that the NRC needs to review and approve them.
ENCLOSURE 2
NRC:
It was not intended in that way. The issue here'is management control, management authorization of activities in the plant.
8.
In the-last paragraph of Section 6.3.1, it states that.the staff will use existina data bases. They all tend to have some errors. - Perhaps we have re-analyzed anj have come up with a new set.
9.
Section 6.4.1(e) needs correction to say-"to assure NCS," not to avoid it.
Section 6.4.1(f) should specify criticality monitoring alarm systems; we have many types of monitoring alarm systems' in our plants.
10.
Section 6.4.3.1 should be integrated into Chapter 2.
The requirements for the qualifications for the plant manager position are unnecessarily '
demanding.
Less than half of our managers could meet this. We have a good plant manager who couldn't meet this. These requirements are a
unnecessary; the manager must do the job or be replaced.
NRC:
Someone who controls the activities of the plant should have a knowledge.
base such that he can understand the impact of his decisions on the plant. These are our concept of generic requirements for the position, but we make exceptions when they are justified.
FCI: This issue is one of equivalency.
It becomes an issue when we~can't t
name a person to a position, when we can't fill a position because we have to wait for NRC approval. Don't get the NRC into the hiring _
process. We should aim for something like a 70.32 process; " don't diminish the effectiveness." The licensee makes the determination of equivalency, and later notifies the NRC.
NRC:
It is in the regulations.
The Commission must determine that the applicant is qualified by training and experience.
FCI: We are asking for an interpretation.
If it specifies the minimum f
requirements or equivalent, explain " equivalent" better.
NRC: These criteria are not requirements. I and my staff view these criteria as guidance.
Other NRC: This SRP will make them effectively requirements.
Other NRC: These are " criteria" for plant manager.
Perhaps you can show that these criteria are being covered in another way.
11.
Regarding categories of NCS people, we call them engineers, rather than analysts, and we don't need three levels. We don't want to differentiate so much.
s 12.
We don't need so many titled managers. The Safety Manager doesn't need j
so many credentials. Also, we don't need so many named organizations.
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13.
.On page 6-7, under "d.", the plant manager's signature approval is not needed. The plant manager has taken ownership of the safety system.
Eliminate the reference to " signature" there.
14.
In Section 6.4.3.2.2, page 6-11, the requirements for training are_too detailed, too specific. A designer can work with specifications; he doesn't need to be NCS trained.
15.
In Section 6.4.3.2.3,'not all members of the NCS audit team need to be NCS trained. One team, not plural.
Is an audit' team a new requirement?:
l NRC: Many audits have been made by individuals. We are trying to get the benefits of the various abilities of operations and safety people L
auditing together.
3 l
16.
In Section 6.4.3.2.4, change " Human factors must be consulted" to "must 1
be considered."
17.
The frequency of audits should be left up to the management.
If we have an organi7ation which is a good performer, we back off on the frequency, and put our effort elsewhere.
18.
Section 6.4.3.2.4 states that " Controls----are to be incorporated in the operating procedures." You should distinguish between safety procedures i
and operating procedures. The concern is how much we have to put into detailed operating procedures, what to do versus. explanation.
NRC: Active controls and administrative controls should be in there.
19.
We are concerned that Section 6.4.3.3.2 contains three~' types of limits,-
failure limits, safety. limits, and operating. limits. We believe that operating' limits and safety limits are enough.
)
i NRC: You need to know what '.he failure limit is. Don't test the safety
]
limit.
1 FCI: What is the operating limit used for?
i NRC: The operating limit is spelled out in procedures.
The safety limit.is in the license.
FCI: Our concern is that this._is required in the license, not just in.
procedures. Our group feels strongly that the operating limit should not be required in the license.
We feel that the safety limit is sufficient, and we should be able to keep the operating limit out of the j
license. The operating limit should be in operating procedures, not in the license. When we set safety limits, we incorporate allowances for uncertainties. The delta ks are on the safety limits.
q NRC: We want a commitment that the operating limit will be developed and reflected in procedures for _use in the process.
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NRC: One of the things _that is missing from the SRP'is the differentiation between what_ goes into the requirements of the license, and what goes into the demonstration section. The safety limit and its safety margin should be'in the license, and a commitment.to set operating limits and to incorporate them in controls.
l FCI: We'll adjust the safety limit to account for heterogeneity. Therefore, we don't need operating limits.
FCI: As a reviewer, you asked for operating limits; it was in the Safety Demonstration Section, and never was in Part I.
We don't see why=we should justify operating limits once we have established and justified the Safety Limit.
20.
Section 6.4.3.3.3 contains too much detail for an experienced reviewer, but not enough for a raw reviewer.
It is suggested that this detail be separated as guidance or auxiliary explanatory material.
Page 6-18, under Geometry, has an unfinished sentence.
FCI: What do you mean by individual user validation (on page 6-19)?
NRC: We mean validation of the individual's ability to calculate, to correctly model subcritical reactors, to show that he can properly use the code himself.
FCI: That is part of the training, not part of the validation.
21.
The first line of page 6-19 calls for training of all potential firefighters.
It is not possible to assure that all firefighters in' town can be reached and trained.
You can't compel the plant to train them; you can only compel the plant to offer to train them.
22.
Regarding the Implementation section on page 6-21, what facilities will r
this SRP apply to? Part 40 licensees as well as Part 707 23.
The last paragraph on page 6-12 specifies that inspections be conducted weekly.
Conditions are not always the same. When the operation is shut down, the interval could be lengthened.
NRC: There is a missing area, Measurement Methods. Measurement must be treated under mass and other controls.
NRC: This should come out in the ISA process: types of error (and mistakes).
24.
Regarding the organizational structure: we have a Safety Committee that looks at safety as a whole, not as a separate Nuclear Safety Committee.
We don't want to have a special organizational unit. We are not going j!
to have many separate specialists. Each person has more than one area.
This is consistent with a safety culture. The requirements on
[
management positions are not flexible enough.
NRC: Nevertheless, a manager that mgst make decisions on technical matters should have a background that gives him an understanding of the issues._
FCI: Don't ask me to tell the plant manager that he isn't qualified.
FCI: There aren't many nuclear facilities: we don't have many people with experience to draw upon for staff.
25.
The set of limits, Failure Limit, Safety Limit, Operating Limit, gives us as a group the most trouble, especially not tying it to the double contingency principle.
26.
Regarding Section 6.4.3.3.3, page 6-16, and the largest value for k-effective, our present license has many requirements for k-effective.
What is meant by "the critical mass of an array"?
NRC: This is for the process vessels on the floor. There are a lot of different ways of exceeding the failure limit. You have to look at the most reactive mode for the unit.
FCI:
You should retain that part about sensitivity studies.
27.
In spite of those words that these are not requirements, the SRP acceptance criteria will carry more weight with reviewers. We want to emphasize the need to separate the unnecessary detail out, to make clear what is to be submitted to d a reviewer.
FCI:
In NID, they use the SRP as a checklist.
If you don't match it, you must show equivalency by Mount Olympus proportions.
FCI:
The SRP in.just a shade under the Standard Format and Content Guide; if something is not there, you must document the hell out of why it is not there.
NRC:
I agree that pragmatically, the SRP becomes the standard.
28.
What do I have to put in the mail to you? This is becoming very murky.
A lot of things are not defined as to where they go in the application.
There is concern about what goes in Part I versus what goes in Part II; Part I can't be changed without a license amendment.
NRC: There is some confusion in the staff on what will be in the parts of the application, but this will be worked out.
FCI: You should be careful not to put extra requirements here on licensees that will be carried over into the new Part 70.
29.
The description of responsibilities for the Nuclear Safety Committee is.
better than that for the Plant Safety Committee in Chapter 2.
This is a suggested change to Chapter 2, rather than Chapter 6.
30.
We are concerned that with the SRP evolving during the renewal process, one licensee might be required to do something by an SRP chapter that gets rewritten and applied differently to the next licensee. We see a change in implementing philosophy that we want implemented equitably across the board.
e o
',9 NRC: We will meet with the licensees and discuss the use of. this SRP for the~-
current renewal, and give more details on the commitments to be in:
Part I.. We plan to treat them uniformly, to convey the same points to each licensee.
FCI:
For the next workshops, avoid Mondays and Fridays.
NRC: When can we expect written comments?
FCI:
In December-- by the end of December.
FCI: Will there be another SRP workshop?
NRC: We hope to have a partial draft around April first. There is the possibility for another indiistry review and comment. Are written comments better, or a meeting?
FCI: Meetings are appropriate for resolving discrepancies in viewpoints.
PS from FCI:
There was never any mention of a Backfit Rule. You need to incorporate something that calls for cost-benefit analysis of requirements, to limit new requirements.
G\\lMTGll16.EN2
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