ML20133H874

Summary of ACRS Subcommittee on Regulatory Activities 850604 Meeting in Washington,Dc Re Proposed Reg Guides & Regulations.Viewgraphs Encl

ML20133H874
Person / Time
Issue date:	06/16/1985
From:	Advisory Committee on Reactor Safeguards
To:	Advisory Committee on Reactor Safeguards
References
RTR-REGGD-1.153, TASK-IC-127-5, TASK-IC-609-5, TASK-MS-021-5, TASK-MS-21-5, TASK-RE ACRS-2321, NUDOCS 8508090550
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" i l' 1'i DATE ISSUED: 6/16/85

SUMMARY

/MI!!UTES Qjg /pg ACRS SUBCOMMITTEE MEETING ON THE REGULATORY ACTIVITIES JUNE 4, 1985 WASHINGTON, D.C. l

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l INTRODUCTION The ACRS Subcomittee on the Regulatory Activities held a meeting on Tuesday, June 4, 1985 at 1717 H Street, N.W., Washington, D.C., to discuss certain proposed. Regulatory Guides and Regulations. The entire meeting was open to public attendance. Mr. Sam Duraiswamy was the cognizant ACRS Staff for the meeting. A tentative presentation schedule for the meeting is included in Attachment A. A list of documents submitted to the Subcommittee is included in Attachment B.

ATTENDEES ACRS: C. P. Siess (Subcommittee Chaiman), W. Kerr, C. Michelson, G. A. Reed, and C. J. Wylie S. Duraiswamy, Cognizant ACRS Staff Principal NRC Speakers: F. Gillespie, A. Hintze, G. Arndt, and J. Burns Public Speakers: Z. Reytblatt, Warren Wilson College M. Lenhart, Boston Edison EXECUTIVE SESSION Dr. Siess, the Subcomittee Chaiman, convened the meeting at 8:45 a.m.,

and stated that the purpose of the meeting was to discuss the following:

• Appropriateness of the NRC Staff's current practice of using Standard Review Plan (SRP) in lieu of Regulatory Guides.

• Proposed Regulatory Guide (Task No. IC 127-5), " Criteria for Programmable Digital Computer Systems Software in Safety-Related Systems of Nuclear Power Plants" (Post Coment).

8508090550 850616 DESIGNATED ORIGINAL 1 PDR Certified By_ MA

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!o Regulatory Activities Meeting June 4, 1985 Proposed Revisions to Appendix J of 10 CFR Part 50, " Leak Tests for Primary and Secondary Containments of Light-Water-Cooled Nuclear .

Power Plants" (Pre Coment).

Proposed Regulatory Guide (Task No. MS 021-5), "Containmnt System Leakage Testing" (Pre Coment).

Dr. Siess said that the Subcommittee had received no written coments from members of the public. It had received requests from Dr. Reytblatt (Warren Wilson College) and Ms. Lenhart (Boston Edison) for time to make oral statements on Appendix J and the associated Regulatory Guide.

USE OF THE SRP IN LIEU OF REGULATORY GUIDES - MR. GILLESPIE Mr. Gillespie discussed briefly the reasons for replacing some of the existing Regulatory Guides with the SRP. There are several Regulatory Guiles that contain deficient and obsolete information. Since the guidance in these Guides does not reflect the current state-of-the-art, they are not even used in the licensing process. Revisions to such guides have been long overdue. However, as a result of severe budget constraints, they do not have enough resources to update these Guides.

Since the SRP has been updated periodically, a decision was made within the Office of Nuclear Regulatory Research to withdraw those Guides that contain wrong and out-dated information and replace them with appropriate sections of the SRP.

1 Dr. Siess asked how many of the existing Division 1 Guides are expected I

to be withdrawn. Mr. Gillespie responded that there are about 151 Guides in Division 1. They plan to perform an in-depth review to detennine which of these Guides need to be recalled. He believes that i about 35 percent of these Guides may be withdrawn as a result of this in-depth review process.

0 Regulatory Activities Meeting June 4, 1985 Although the Subcomittee did not take a definitive position on this issue, it felt that the SRP was never intended to be anything but an ,

internal NRC document; now, trying to use it as a controlling document without the benefit of the public and ACRS review does not seem to be a good idea.

Dr. Siess said that the ACRS needs to discuss this issue with the Executive Director for Operations and get his perspective.

PROPOSED REGULATORY GUIDE (TASK NO. IC 127-5), " CRITERIA FOR PROGRAMM-ABLE DIGITAL COMPUTER SYSTEMS SOFTWARE IN SAFETY-RELATED SYSTEMS OF NUCLEAR POWER PLANTS" - MR. HINTZE This Guide describes a method acceptable to the NRC Staff for designing, verifying, and integrating software into the digital computer systems used in the operation of nuclear power plants. It endorses, without exceptions, the provisions of the industry Standard ANSI /IEEE-ANS-7.4.3.2-1982, " Applicable Criteria for Programable Digital Computer Systems in Safety Systems of Nuclear Power Plants."

This Guide was reviewed by the Regulatory Activities Subcomittee during a meeting held on December 8, 1981. It was issued for public coment in March 1983. The current version of this Guide reflects consideration of public coments.

Dr. Kerr commented that this Guide does not give adequate guidance for use in validating computer software. He suggested that the Staff develop further guidance.

1 Dr. Siess asked whether there would be additional industry Standards or Regulatory Guides in this area to provide more guidance. Mr. Sullivan responded that there are several other Standards (such as, Software Reliability Measurements, Software Quality Assurance Guide, Software Verification Plan) being developed by the Computer Society with input

Regulatory Activities Meeting June 4, 1985 from the IEEE Nuclear Power Engineering Comittee. The Staff has been monitoring the development of these Standards very closely to determine ,

which, if any, of these should be endorsed by new Regulatory Guides.

With regard to the statement in the last paragraph of the Discussion Section, which states: "It should also be noted that the Staff encourages the application of advanced technology, such as programable digital computers, in the operation of nuclear power plants, where such advanced technology serves to enhance safety," Dr. Siess comented that this statement describes the NRC Staff's policy on the use of digital computers and he does not believe that it is appropriate to express such a policy in this Guide. .

The Staff stated that the above statement was included in this Guide as recommended by the Comittee to Review Generic ^ Requirements (CRGR). .

After further discussion, the Subcomittee decided that the above statement seems to be related more to the use of digital computers than to the software itself. Therefore, it would be more appropriate to include such a statement in the Regulatory Guide dealing with the hardware portion of digital computers.

Mr. Michelson asked whether there are any Guides being developed to provide guidance on the hardware portion. Mr. Hintze stated that they have another Guide (Task No. IC 609-5, Criteria for Power, Instru-mentation, and Control Portions of Safety Systems) which provides guidance on the development of digital computer systems hardware and is expected to be sent to the ACRS for review in the near future.

Dr. Siess suggested that the Guide dealing with the hardware portion of the digital computers be referred to the Subcommittee on Electrical Systems for review.

Regulatory Activities Meeting June 4, 1985 The Subcomittee suggested some editorial changes, provided guidance for

' clarification in certain areas, and indicated that it would submit this .

Guide to the full Comittee during the June 6-8, 1985 meeting

, recommending concurrence in the regulatory position.

PROPOSED REVISIONS TO APPENDIX J OF 10 CFR PART 50, " LEAK RATE TESTS FOR PRIMARY AND SECONDARY CONTAINMENTS OF LIGHT-WATER-COOLED NUCLEAR POWER PLANTS" - MR. ARNDT Appendix J of 10 CFR Part 50 identifies general requirements and acceptance criteria for preoperational and subsequent periodic leak testing. The existing Appendix J requires that all Type A tests should be conducted in accordance with the ANSI N45.4-1972 Standard, " Leakage-Rate Testing of Containment Structures for Nuclear Reactors." This Standard had been revised to reflect the current state-of-the-art in the leak-testing technology and reissued as ANSI /ANS 56.8-1981, " Containment System Leakage Testing Requirements." As a result, Appendix J requirements now in effect refer to an outdated Standard. Consequently, the NRC Staff has decided to revise the existing Appendix J to make it compatible with the provisions of the revised industry Standard, to incorporate various internal / external coments received since 1973, and to simplify the text to a more " plain english" text. The proposed revision is being justified on the basis of being a licensing improvement rather than on a risk reduction / cost benefit basis.

A previous version (Draft 05) of the proposed revisions to Appendix J was reviewed by the Regulatory Activities Subcomittee during its June 12, 1984 meeting. During its June 14-16, 1984 meeting, the ACRS stated that it had no objection to issue the proposed revisions to Appendix J to public coment. Since June 1984, several changes have been made as a result of additional inter-office review. Consequently, the revised version has been resubmitted to the ACRS for another review prior to its issuance for public coment.

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. Regulatory Activities Meeting June 4, 1985 i

Dr. Arndt reviewed briefly the major differences between the existing and the proposed Appendix J (Attachment C, pages 1-5). ,

Dr. Arndt said that during the June 3, 1985 CRGR meeting, a question was raised as to whether the revision to Appendix J is appropriate at this time or it should be deferred for a short period of time and reconsidered in light of the research on severe accidents and source terms.

' Dr. Siess commented that he does not believe that a revision to Appendix J reflecting the results of the research on severe accidents and source terms could be done in less than two or three years. In his opinion, 4 the proposed revisions should be issued for public coment at this time.

He suggested that it would be helpful if the Staff solicited comments from the industry as to whether the currently proposed interim revision

to Appendix J would be beneficial. ,

Dr. Kerr asked on what basis the frequency for conducting Type A test was chosen. Dr. Arndt responded that he was not sure of the reason for selecting this frequency.

Dr. Kerr suggested that it would be helpful if the Staff tried to find out the rationale for the Type A test frequency so as to determine whether it is still appropriate. Dr. Arndt responded that a similar type of question was also raised by CRGR and he believes that it would be a good idea to look at this issue to determine whether there is a good rationale for the Type A test frequency.

Mr. Michelson commented that there are certain plants which use pneumatic (inflattable) seals in personnel accesses and the retention capability of these seals depend on the retention of the air pressure to these seals. If the air pressure is lost, the seal will loose its retention capability and there will be a large leakage. He asked why

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x Regulatory Activities Meeting June 4, 1985 this issue is not addressed in the proposed Appendix J. Mr. Burns responded that the Staff will take a look at this issue. ,

Mr. Wylie commented that in pages 6 of the comparative Draft (s), under .

Type B testing, the Staff seems to imply that electrical penetrations use flexible metal seal assemblies; to his knowledge, they do not use such assemblies.

With regard to the statement in page 10 of the Comparative Draft (s) which states that " continuous leakage monitoring systems must not be operated and pressurized during Type A tests," Mr. Wylie comented that it is not practical to apply this requirements to electrical penetrations because they are generally canned penetrations filled with gas.

The Staff responded that they will consider the coments provided by Mr.

Wylie.

The Subcommittee suggested some editorial changes, provided guidance for clarification in certain areas and indicated that it would submit the proposed revision to Appendix J to the full Comittee during the June 6-8, 1985 meeting with the recomendation that the ACRS concur in the Staff's proposal to issue this item for public coment.

PROPOSED REGULATORY GUIDE (TASK NO. MS 021-5), " CONTAINMENT SYSTEM LEAKAGE TESTING" (PRE COMMENT) - DR. ARNDT This Guide describes a method acceptable to the NRC Staff for complying with the NRC regulations associated with the containment leak rate testing. It endorses, with certain exceptions, the ANSI /ANS 56.8-1981 Standard, " Containment System Leakage Testing Requirements".

'. Regulatory Activities Meeting June 4, 1985 Dr. Arndt stated that thre are 21 regulatory positions in this Guide including two that were included as a result of previous public coments ,

on the containment leak testing criteria; most of them are exceptions to the ANSI /ANS 56.8-1981 Standard. c'e said that the Standard is being revised and he expects that the revised Standard will incorporate a major portion of the material in the proposed Guide.

After further discussion, the Subcomittee suggested some editorial changes, provided guidance for clarification in certain areas, and indicated that it would submit this Guide to the full Comittee during the June 6-8, 1985 ACRS meeting recommending that the ACRS concur in the Staff's proposal to issue this Guide for public coment.

ORAL STATEMENTS BY DR. REYTBLATT Some of the comments provided by Dr. Reytblatt on the proposed Appendix J and the associated Guide are given below:

• Appendix J

- He believes that the proposed revisions to Appendix J are long overdue and should be issued for public coment as soon as possible.

-ParagraphV.A(page13,AppendixJ.DraftE4)relatingtoTypeA, B, and C Test Details should be revised to require that the leak test methods, procedures, etc., must be selected from the methodologies duly endorsed by the NRC.

• Proposed Regulatory Guide, MS 021-5

- He strongly objects to the issuance of this Guide for public cwment at this time, because it infringes on proprietary documents.

Regulatory Activitics Meeting June 4, 1985

- This Guide does not provide guidance for determining weight coefficients. -

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- The technical adequacy of all the regulatory positions in this Guide should be discussed in detail at a forum (not at an ACRS forum) prior to issuing this Guide for public comment.

ORAL STATEMENTS BY MS. LENHART Ms. Lenhart from the Boston Edison Company sought clarification from the NRC Staff regarding certain provisions of the proposed Appendix J.

Dr. Siess thanked all participants and adjourned the meeting at 3:15pm.

NOTE: Additional meeting details can be obtained from a transcript of this meeting available in the NRC Public Document Room, 1717 H Street, N.W., Washington, D.C., or can be purchased from Ann Riley & Associates Ltd., 1625 I Street, N.W., Suite 921, Washington, DC 20006,(202)293-3950.

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5/29/85 TENTATIVE PRESENTATION SCHEDULE ACRS SUBCOMMITTEE MEETING ON THE REGULATORY ACTIVITIES JUNE 4, 1985

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ACRS

Contact:

Sam Duraiswamy 634-3267 I. Executive Session C. P. Siess 8:45 am - 9:00 am II. Use of Standard Review Plan in Lieu of Regulatory Guides F. Gillespie 9:00 am - 9:30 am i III. Proposed Regulatory l

Guide (Task No. IC 127-5),

" Criteria for Programable Digital' Computer Systems

' Software in Safety-Related l Systems of Nuclear Power Plants" (Post Comment) A. Hintze 9:30 am - 10:30 am

• • • Break *** 10:30 am - 10:45 am i IV. Proposed Revisions to

! Appendix J to 10 CFR Part 50, " Leak Tests for Primary and Secondary Containments of Light-Water-Cooled Nuclear Power Plants" (Pre Coment) G. Arndt 10:45 am - 12:30 pm

! *** Lunch *** 12:30 pm - 1:30 pm V. Proposed Regulatory Guide l (Task No. MS 021-5),

" Containment System Leak-age Testing" (Pre Coment) G. Arndt 1:30 pm - 3:00 pm VI. Public Coments (if any) 3:00 pm - 3:30 pm VII. Subcomittee Remarks 3:30 pm - 3:45 pm Adjourn 3:45 pm A TTAc H u& dr R

- LIST OF DOCUMENTS SUBMITTED TO THE REGULATORY ACTIVITIES SUBCOMMITTEE JUNE 4,1985

1. Memorandum f ron R. Fraley to ACRS Members, "NRC Staff Use of the Standard j Review Plan in Lieu of Regulatory Guides," dated March 19, 1985.

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2. Memorandum f rom E. Igne to P. Shewmon, " Withdrawal of Regulatory Guides 1.46 and 1.48," dated April 4,1985.

3. Memorandum f rom C. P. Siess to S. Duraiswamy, dated March 27, 1985, transmitting a memorandum from V. Stello to H. Denton related to Regulatory Guide 1.114, Revision 2.

! 4 Proposed Regulatory Guide (Task No. IC 127-5), " Criteria for Programmable Digital Computed Systems Software in Safety-Related Systems of Nuclear Power Plants."

5. Portion of the Minutes of the December 8,1981 Regulatory Activities Subcommittee meeting.

6. Proposed Revisons to Appendix J to in CFR Part 50 to9 ether with Associated Documents, j 7. Proposed Regulatory Guide (Task No. MS 021-5), " Containment System Leakage Testing."

8. Portion of the Minutes of the June 12, 1984 Regulatory Activities Meeti ng.

ATTACHMENT B

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TEST PFnUIREENTS l

EXISTING & PROPOSED RULE l

TYPE A TEST i

ENTIRE CONTAIN1ENT SYSTEM, IN POST-LOCA CONFIGURATION, PRESSURI EVERY 3 TO 4 YEARS. .

i B s C TESTS USUALLY PRECE9E TYPE A TEST.

TYPE B TEST CONTAlWENT PENETRATIONS PRESSURIZED EVERY TWO YEARS OR l.

l TYPE C TEST CONTAIR1ENT ISOLATION VALVES PRESSURIZED AT LEAST EVER an.

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MAJOR CHANGES

1. LEVEL OF DETAll

, LIMIT CONTENT TO GENERAL TEST CRITERIA: LEAVE DETAILS TO  :

REGULATORY GUIDE

2. EDITORIAL EXPANDED TABLE OF CONTENTS + DEFINITIONS: TEST REVISED TO C0fFORM

! TO " PLAIN ENGLISH" OBJECTIVES','

l j 3. INTERPRETATIONS

! CHANGES MADE TO RESOLVE PAST INTERPRETIVE QUESTIONS (E. G., DEFINITIONS 0F *CONTAIMENT ISOLATION VALVE" AE " TYPE A TEST FAILURES").

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MAJOR CHA EES (CONTINUED) l 4, rM ATER FIFYIBILITY f PROVISIONS ADDED THROUGHOUT AND IN GENERAL IN PARA. VII. A.

I l 5. TYPE A TFST PRFRRilRF

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REDUCED PRESSURE OPTION DELETED.

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6. TYPE A TFST FRFollFKY 4

i KEYED TO PREOP TEST DATE, RATHER THAN DATE OF CON 1ERCIAL OPERATION.

7. TYPE A TEST IMIRATION l

t i DELETED, SINCE IT IS A FUNCTION OF THE STATE OF TESTING TECHNOLOGY

! AND LEVEL OF CONFIDENCE IN IT. CONSENSUS TECHNICAL BASIS BEING DEVELOPED.

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' MAJOR CHANGFS (CONTINUED) l

8. TYPE A TFST "AS IS" fl ARIFICATION i

l "AS FOUND"/"AS LEFT" LEAKAGE DETERMINATION AND REPOR i

RE-EMPHASIZED, PER 1/11/82 EM0 MATTSON TO SNIEZEK.

9. TYPE A TFST AlInhlARIE 1FAKAGF RATE PRORATING i

A "AS FOUND" LEAKAGE LIMIT CHANGED A FROM 0.75L TO 1.0L '

"AS LEFT" LEAKAGE LIMIT KEPTAAT 0.75L '

10. nilANTIFICATION OF AlInhlARIE IFAK RATES B0 CHANGE IN APPENDIX J; STILL PROVINCE OF TECHNICAL SPECIFICATIONS.

APPENDIX J BASED ON CURRENT TECH SPEC VALUES.

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MAJOR CHANGES (CONTINUED)

11. REFOCUSING OF CORRECTIVE ACTIONS-WHEN SPECIFIC PROBLEM AREAS ARE IDENTIFIED, CORRECTIVE ACTI ARE REDIRECTED TO THEM RATHER THAN TO A TYPE A .

I As IS NOW DONE.

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