ML20065D906
| ML20065D906 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 03/24/1994 |
| From: | Hutchinson C ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GNRO-94-00047, GNRO-94-47, NUDOCS 9404070262 | |
| Download: ML20065D906 (4) | |
Text
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. March 24,1994 amm.
m amo comw sa,on U.S. Nuclear Regulatory Commission
- Mail Station P1-137 Washington, D.C. 20555 Attention:
Document Control Desk r
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Subject:
Grand Gulf Nuclear Station Unit 1 Docket No. 50-416 License No. NPF-29 10 Year ASME Code Meeting GNRO-94/00047 Gentlemen:
We are requesting your attendance at a meeting to discuss our cost beneficial licensing action (CBLA) request which proposes an alternative to the 10CFR50.55a requirements to adopt the latest approved ASME code edition every 10 year period.-
As you know,'we met with the technical staff on December 6,'1993 to review our -
10/21/93 submittal and supplemented our' proposal'with a further submittal on 12/9/93.
Although _we left the meeting on December 6 with the agreement that the staff would -
quickly docket any additional questions, we have since been informed that the review
, staff has no further questions. Therefore, we believe the technical staff has a good :
understanding of'our proposal. Unfortunately, NRC management was unable to attend the December meeting.
Our.CBLA request raises fundamental policy questions which go beyond the proposed --
attemative to 10CFR50.55a. We believe the resolution of these questions may shape g
' the future nature, value and scope of the CBLA program. Because we feel that the; CBLA program is approaching a crossroads, we believe it importan_t that NRC.
management and technical staff have a common understanding of the key elements of -
n our proposal and that Entergy Operations have the opportunity to discuss our view of the broader issues.
- Based on feedback during and subsequent to the December 6 meeting, it appears that l the review staff concerns focus in two main areas: 1) the use of PRA as a basis for
. making safety decisions, and 2) the likelihood that many of the ASME code changes E will not meet a substantial safety benefit test.: These concerns could be raised forf
.n many of our CBLA requests'and involve substantial policy issues which we believe -
NRC rnanagement has already a' dressed oris in the process of addressing, We:
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r discuss our views, in brief, below.
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Use of PRA At Entergy Operations and in some areas of the NRC, probabilistic risk assessment coupled with engineering judgment has become a standard toolin resolving a wide range of safety issues, it is particularly usefulin providing a measure of the relative importance of a system, component, issue or proposed change.
Much of our effort in the area of regulatory burden reduction employs PRA as a critical component. For instance, as a pilot in the pending graded QA effort, both the ANO and Grand Gulf plants will_ be using the Maintenance Rule risk ranking of systems along with -
further PRA refinements to fundamentally re-grade the Q-list rankings of plant components.
For our attemative to 10CFR50.55a, we propose to use PRA as one element to determine if a particular ASME code change constitutes a substantial safety benefit.-
.As we presented on December 6, this decision criterion will be more conservative than those derived from the criteria published in NUREG/BR-0058 Rev 2, Regulatory Analysis Guidelines of the NRC. Specifically, we will determine that a substantial safety benefit exists based on a change in core damage frequency of greater than 10-6 and/or a change in containment release probability oi greater than 104 During our December 6 meeting, the staff raised a number of' good issues which have prompted some changes in and clarifications of our original submittal.- We did not make clear our intention to employ criteria in addition to PRA to determine substantial safety benefit. We intend to use an expert panel process not unlike that used to identify the structures,' systems and components important to Maintenance Rule implementation. This panel will be responsible.for reviewing the probabilistic screening results and ensuring that appropriate deterministic and engineering discipline criteria are considered in the final determination of safety benefit for a given ASME code change. In addition, the proposed program. revisions will be reviewed by each plant's on-site review committee. Similarly, if a value/ impact analysis is nece_ssary, we intend '
to base our criteria on those contained in NRC Manual Chapter 0514, paragraph 043 (Regulatory Analysis).
Dearee of implementation of ASME Code Chanaes
- We agree with the staff that approval of our altemative to 10CFR50.55a will likely result in many individual ASME code changes not being implemented because they do not constitute a substantial safety benefit. In fact, it is because these types of incremental changes often result in little safety benefit, but at a significant cost, that we initiated our request.
The fundamental purpose of Entergy Operations' burden reduction initiatives is to
' increase fiexibility in our allocation of resources. When limited resources must be -
assigned to functions of lesser safety significance, overall safety suffers. While we expect to achieve cost savings through the CBLA program, more importantly, we ni J
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- GNRO-94K)004 7 Page 3 of 5 7
expect to free up resources which can be re-invested in more safety significant activities.
We believe that safety improvement through burden reduction is the basic' premise -
behind the CBLA program.' Our proposed alternative to 50.55a is a good example of this principle in action.
Meetina Request it is our belief that these basic issues, if not adequately aired, will adversely affect the course of the CBLA program.
Consequently, we request a near term meeting with Messrs. Russell, Thadani, Reyes, Virgilio, Sheron, Roe, Zimmerman and the technical review management and staff to -
explore these issues.
We appreciate your consideration of this request and look forward to your response.
Yours truly, CRH/MJM/ba cc:
Mr. R. H. Bembard Mr.H. W. Keiser Mr. R. B. McGehee Mr. N. S. Reynolds
+
Mr. H. L. Thomas Mr. Stewart D. Ebneter Regional Administrator U.S. Nuclear Regulatory Commission Region 11 101 Marietta St., N.W., Suite 2900 Atlanta, Georgia 30323 y
Mr. William T. Russell Director, NRR.
U.S. Nuclear Regulatory Commission Washington, D.C. 20555 y
Mr. Ashok C. Thadani Associate Director, NRR U S. Nuclear Regulatory Commission Wa.shington, D.C. 20555 2_
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. M:rch 24,1994'
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'GNRO-94/00047 Page 4.of 5
.1 cc:
. Mr. Luis A. Reyes Acting Assocatie Director,'NRR U.S. Nuclear Regulatory Commission Washington, D.C. 20555'
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Mr. Martin J. Virgilio Director, Systems Safety & Analysis -
U.S. Nuclear Regulatory Commission Washington, D.C; 20555.
Mr. Brian W. Sheron Director, Engineering
. U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Jack Roe Director, Reactor Projects
' U.S. Nuclear Regulatory Comrnission Washington, D.C. 20555 Mr. Roy P Zimmerman U.S. Nuclear Regulatory Commission Washington, D.C. 20555 '
Mr. P. W. 'O'Connor, Project Manager (w/2)
Office'of Nuc' ear Reactor Regulation a
U.S. Nuclear Regulatory Commission Mail Stop 13H3 Washington, D.C. 20555 I-t
,