ML20058Q017
| ML20058Q017 | |
| 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 9312280036 | |
| Download: ML20058Q017 (6) | |
Text
MEMORANDUM FOR:
Robert F. Burnetto Director Division of Fuel Cycle Safety a
and Safeguards J3. 0S E FROM:
Theodore S. Sherr, Chief Regulatory and International Safeguards Branch, FCSS
SUBJECT:
Standard Review Plan Acceptance Criteria Meeting, November 1, 1993 - Summary On Monday, November 1,1993, at NRC headquarters, the staff held the first of a 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).
Eleven representatives of industry were present, in addition to NRC staff and contractor representatives. is the list of attendees. Topics addressed were draft acceptance criteria for the fire protection and emergency preparedness chapters of the SRP, which were mailed in advance to participants who had registered with our coordinator, Joan Higdon.
After introductory remarks by me and the SRP Project Manager, Jerry Swift, Mr. Amar Datta gave a brief review of the fire protection chapter of the SRP, and of other recent guidance on fire protection issued by the Office of Nuclear Material Safety and Safeguards. This was followed by comments by the industry representatives, with Mr. Marvin Fertel taking the lead.
is a synopsis of comments on the draft SRP acceptance criteria on fire protection. Attendees were reminded that written comments would be accepted at any time. Mr. Fertel said that they would be sending written comments, and that they might send comments on the Branch Technical Position also.
Early in the day, the representatives of industry had said that they thought their comments on the two topics would not take nearly the time allotted, and proposed that the afternoon session on emergency preparedness be moved up to follow the fire protection session, after a short break.
This was done, Mr.
Swift introducing the emergency preparedness chapter. is a synopsis of the comments received on the draft acceptance criteria on emergency preparedness.
The meeting adjourned at 12:15 p.m.
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Enclosures:
As stated.
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DISTRIBUTION:
tH Central File, PI-37/"PUBLIC"~
CEmeigh, FCLB MTokar, FCLB NMSS'r/f FCSS r/f Section r/f FRIB r/f JHigdon, FRIB GBidinger, FRIB RPierson, FCLB LTenEyck, FCSS
- SEE PREVIOUS CONCURRENCE
- OFC FRIB*
FRIB*
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FCLB*
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9312280036 931209 e
MEMORANDUM FOR:
Robert F; Burnett, Director z.-
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 1, 1993 - Summary On Monday, November 1,1993, at NRC headquarters, the staff held the first of '
a 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).
Eleven representatives of industry were present, in addition to NRC staff and contractor representatives. is the list of attendees. Topics addressed were draft acceptance criteria for the fire protection and emergency preparedness chapters of the SRP, which were mailed in advance to participants who had registered with our coordinator, Joan Higdon.
After introductory remarks by Ted Sherr, Chief of the Regulatory and International Safeguards Branch, and the SRP Project Manager, Jerry Swift, Mr. Amar Datta gave a brief review of the fire protection chapter of the SRP, and of other recent guidance on fire protection issued by the Office of Nuclear Material Safety and Safeguards. This was followed by comments by the industry representatives, with Mr. Harvin Fertel taking the lead.
is a synopsis of comments on the draft SRP acceptance criteria on fire protection. Attendees were reminded that written comments would be accepted at any time. Mr. Fertel said that they would be sending written comments, and that they might send comments on the Branch Technical Position also.
Early in the day, the representatives of industry had said that they thought their comments on the two topics would not take nearly the time allotted, and proposed that the afternoon session on emergency preparedness be moved up to follow the fire protection session, after a short break. This was done, Mr.
Swift introducing the emergency preparedness chapter. is a synopsis of the comments received on the draft acceptance criteria on emergency preparedness. The meeting adjourned at 12:15 p.m.
Theodore S. Sherr, Chief Regulatory and International Safeguards Branch, FCSS
Enclosures:
As stated.
DISTRIBUTION:
Central File, PI-37/"PUBLIC" CEmeigh, FCLB MTokar, FCLB NMSS r/f FCSS r/f Section r/f FRIB r/f JHigdon, FRIB GBidinger, FRIB RPierson, FCLB LTenEyck, FCSS reis 6
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T ende hohn TCox ML tra-Tsherr NAME DATE 12/I/93 12/Q/93 12/7/93 12/ 9 /93 12h/93 12/ /93 g:\\lmtgl101.jsm C = COVER E = COVER & ENCLOSURE N = NO COPY
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-ATTENDEES STANDARD REVIEW PLAN ACCEPTANCE CRITERIA MEETING November 1, 1993 Fuel Cycle Industry John Conant ABB Combustion Engineering James B. Edgar Siemens Power Corp.
Harold E. Eskridge ABB Combustion Engineering Marvin S. Fertel U.S. CEA Jeffery B. Hooper Westinghouse CNFD Felix M. Killar, Jr.
U.S. CEA Peter LeRoy Louisiana Energy Services Andy Maxin Nuclear Fuel Services Leah Morrell B & W Fuel Co.
Edward Reitler Westinghouse CNFD David C. Ward Babcock & Wilcox NNFD David Ward B&W, NNFD Nuclear Reaulatory Commission Stephen P. Burris Region II Thomas Cox NMSS/FCSS/FCLB Amar Datta NMSS/FCSS/FRIB Gordon Gundersen RES Joan Higdon NMSS/FCSS/FRIB Mike Lamastra-NMSS/FCSS/FCLB Barry Mendelsohn NMSS/FCSS/FRIB Jerome Roth NMSS/FCSS/FCLB Theodore S. Sherr NMSS/FCSS/FRIB Jerry J. Swift HMSS/FCSS/FRIB Mary L. Thomas RES Michael Tokar NMSS/FCSS/FCLB Q1har.1 Jim Boyce MMUS, Piketon, OH Hal Cohen SAIC Jim Hammelman SAIC Tom Storey SAIC Ray Wright MMUS, Paducah, KY 9:\\1mtg1101.att
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w' COMMENTS ON THE DRAFT FIRE PROTECTION ACCEPTANCE CRITERIA 1.
The participants wished that they had more time for review of the draft Standard Review Plan-(SRP) chapters.
2.
The sections were too prescriptive and detailed, e.g..they. call for a i
formal Fire Safety Board, whereas the operators of a facility might wish.
to include the function with the Plant Safety Committee.-
t 3.
The acceptance criteria should focus on fire protection needs relevant to NRC's regulatory role, e.g. if a fire in a portion of a building
'i would have no effect on NRC licensed activities; fire protection there should not be a concern of NRC.
-i 4.
The need for fire protection requirements by the NRC should be-derived from the integrated safety analysis (ISA).
In this way, it would.be similar to the emergency preparedness chapter of the SRP, which begins r
with the possession limits, and then refers to an analysis of potential accidents to derive the emergency preparedness requirements. Thus, the-ISA should identify the fire hazards that are important to radiation safety.
The requirements should be based on the ISA, and not on-standardized fire protection requirements.
5.
The approach of the fire protection chapter seemed to call for stand-alone programs, e.g. a separate fire protection program.
It would be-better to have an integrated safety program than to have safety compartmentalized.
6.
Some of the material in the fire protection chapter appeared to be redundant with other chapters, e.g. part of emergency preparedness is to indoctrinate the local Fire Department concerning areas where fire fighting must consider the presence of radioactive' materials.
i L
(The NRC staff noted that at this stage of development of the SRP, overlap was more desirable than gaps, and that eventually, the SRP sections should shcw how they work together, and reference other applicable sections. However, it was thought that the 15A approach could not totally supplant the general application of principles, e.g. in fire-protection.).
7.-
The revised Part 70 should be as performance-based as possible, with the details left to documents like the SRP.
t 8.
The acceptance criteria should be written'in terms'of functions, rather-than labeled. programs or positions. At operating plants, we do things-by function. We don't want to have to do.a lot _ of writing just to have; a stand-alone document (for example for a " Fire Protection Program").
9.
A concern is not to have too many prescriptions in the acceptance criteria, that an inexperienced reviewer might.think are inviolable.
q l
i-10.
An objective of the Standard Review Plan is to have consistency in reviews, but this is the case of a Standard Review Plan with a new rule with existing plants.
Part of the SRP should require a visit to the i
plant.
The NRC reviewer shouldn't just review documents, but should also visit and get familiar with the facility.
i 11.
The benefits of the regulations should be weighed against the costs.
12.
In reaction to a statement tLat the SRP should cover the worst case, it was remarked by another fuel cycle industry participant that the acceptance criteria should not call up the worst case because it could be difficult for the reviewer to adapt the criteria to the realistic level.
13.
The OSHA Subpart 2 regulations on fire protection should be used as they are, rather than have the NRC create another entire set of requirements.
Requirements for training are incluofd in Subpart L.
14.
The ISA should include fire protection.
Fire protection features should be derived from the ISA. The review criteria should address such features.
15.
What makes our industry more hazardous than others, to justify more requirements (i.e., in Appendix A of the SRP Fire Protection chapter)?
16.
We should be reviewing sornething formulated differently.
The details should be in a Regulatory Guide.
Look at the fire protection SRP for reactors.
17.
More emphasis should be placed on requirements derived from the ISA.
The ISA should indicate what barriers are needed.
If a good ISA is performed that covers all safety concerns, the need for a separate fire hazard analysis has vanished.
I 18.
There should be an integral linkage between the ISA and fire safety-this SRP chapter needs to refer to the ISA. New reviewers should be led to understand the need to review the facility on an integrated basis.
We need to be careful not to drive unnecessary compartmentalization.
19.
The ISA will lead to management of configuration change, and integrated safety, including fire protection, will be reviewed at that time.
Therefore, there should be no need to review fire protection every two
- years (referring to page 3, subsection (d)(2), where it says biennially or at more frequent intervals). Refer to OSHA regulation 1910.119,
" Process safety management for highly hazardous materials," (which came from petroleum industry accidents).
It says every 5 years rather than every 2 years.
20.
We need to get into the head of each SRP author to use the ISA approach.
1 I
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COMMENTS ON THE DRAFT EMERGENCY PREPAREDNESS ACCEPTANCE CRITERIA 1.
The industry participants thought the emergency preparedness (EP) chapter was just about right, well done.
(This contrasted with the view i
of Jerry Swift, NRC, who indicated that it should be more self-contained rather than referring the reviewer to an assortment of guidance documents.)
2.
The EP chapter now bases its requirements on a specific accident.
It should refer to the Integrated Safety Analysis (ISA) for identification of dominant accidents.
3.
The reference to physical security and sabotage is out of place. These topics are covered in the Physical Security Plan.
(Reference to FR of March 15, 1993, page 13,699) 4.
With regard to section 9.2.2, there is no call for separate books.
5.
With regard to section 9.5.3, clarify what types of chemical hazards need to be addressed.
6.
For the Standard Format and Content Guide, the ISA chapter should lay out the results of the ISA, and relate other chapters to it.
7.
There is a concern that if the EP SRP chapter is enlarged with more detail, the result will be a lack of a 1:1 correspondence between the SRP and the regulatory guide and other references.
8.
Pulling acceptance criteria into the SRP chapter could make it too voluminious, and bring in extraneous material.
9.
Reg. Guide 3.67 has references to non radioactive hazardous materials that should come out.
)
10.
Reg. Guide 3.67 calls for annual independent audits of EP. This seems almost redundant when put on top of requirements for reviews, training, etc., plus NRC inspections. An NRC inspector thought that annual independent audits should be committed to.
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- Enclosure 3
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