ML20136C041

Summary of 970207 Meeting W/Nei in Rockville,Md Re Concerns Concerning NRC Info Notice 92-18, Potential for Loss of Remote Shutdown Capability During Control Room Fire. List of Attendees Encl

ML20136C041
Person / Time
Issue date:	03/07/1997
From:	Malloy M NRC (Affiliation Not Assigned)
To:	Matthews D NRC (Affiliation Not Assigned)
References
PROJECT-689 IEIN-92-018, IEIN-92-18, NUDOCS 9703110248
Download: ML20136C041 (16)

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4 UNITED STATES j

j NUCLEAR REGULATORY COMMISSION 4"

WASHINGTON, D.C. 20555-0001

, g g,o March 7, 1997 MEMORANDUM TO: David B. Matthews, Chief Generic issues and Environmental Projects Branch Division of Reactor Program Management Office of Nuclear Reactor Regulation FROM:

Melinda Malloy, Project Manager Generic issues and Environmental Projects Branch Division of Reactor Program Management Office of Nuclear Reactor Regulation

SUMMARY

OF FEBRUARY 7,1997, MEETING WITH THE NUCLEAR ENERGY INSTITUTE (NEI) ON INFORMATION NOTICE 92-18 On February 7,1997, representatives of the U.S. Nuclear Regulatory Commission (NRC) met with representatives of the Nuclear Energy Institute (NEI) and several nuclear utilities at the NRC's offices in Rockville, Maryland. The list of meeting attendees is provided in.

The purpose of the meeting was to discuss NEl's concerns related to NRC Information Notice (IN) 92-18, " Potential for Loss of Remote Shutdown Capability During a Control Room Fire." These concerns were articulated in a January 14,1997, letter from Ralph Beedle to Frank Miraglia (NRC) (see Accession No. 9701220184 for this letter).

Fred Emerson of NEl was the primary presenter. The slides he used during his presentation are included as Attachment 2 to this meeting summary. He explained that NEl is concerned about policy and technicalissues that arose with the issuance of IN 92-18 and that their concerns are intensifying as a result of IN 92-18 followup by NRC inspectors.

Mr. Emerson stated that during recent NRC followup inspections, the inspectors have interpreted the insights and suggestions in the IN as 10 CFR Part 50, Appendix R requirements that must be complied with by licensees, and that enforcement actions (EAs) citing the IN have been initiated. (Page 3 of NEl's presentation slides (Attachment 2) lists the specific technicalissues raised by IN 92-18 and the NRC followup inspections that are of concern to NEl. Pages 4 and 5 of the slides state NEl's questions on hot shorts and

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spurious actuations, respectively.) in the case of the Salem plant, there is a related startup issue. Used in such a manner, NEl believes that IN 92-18 inappropriately promulgates changes to interpretations of Appendix R and other staff guidance on fire

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• protection, such as Generic Letter (GL) 86-10 and GL 85-01. It is NEl's position that these changes in interpretation represent de facto backfits, and that an IN is not an appropriate vehicle for promulgating new or different regulatory interpretations.

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-2 March 7, 1997 Dave Nelson of NRC's enforcement staff clanfied that as a point of policy, it would be incorrect for the NRC to cite an IN as the basis for a violation. Gary Holahan of NRR's j

Division of Systems Safety and Analysis stated that it would not be inappropriato, however, for EAs to reference the IN. When requested by the NRC staff representatives to provide specific information on how EAs might be citing or referencing IN 92-18, none of the NEl or utility representatives in attendance at the meeting could provide any details.

I Mr. Holahan and Patrick Madden of NRR's Plant Systems Branch stated that the information in IN 92-18 is consistent with NRC regulatory requirements. Because of this difference of opinion between the NRC staff and NEl, Ralph Beedle asked if NRC would reexamine the guidance provided in IN 92-18 and suspend enforcement actions related to

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the information in the IN until the issue of whether the guidance is specifically covered by the regulatory requirements has been thoroughly considered. Mr. Emerson emphasized that the industry wants to do the right thing if there are technical issues not previously considered, but it is opposed to NRC not using an appropriate vehicle to impose new requirements if the existing ones are not sufficiently clear.

4 Mr. Holahan thanked NEl for having utility representation at the meeting. He indicated that the NRC staff is preparing a formal response to Mr. Beedle's January 14,1997, letter, but could not commit to a specific completion date.

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Attachments:

1. List of Attendees

2. NEl's Briefing Slides Project No. 689 cc w/atts: See next page j

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l March 7, 1997 D. Matthews,

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Dave Nelson of NRC's enforcement staff clarified that as a point of policy, it would be f

incorrect for the NRC to cite an IN at the basis for a violation. Gary Holahan of NRR's Division of Systems Safety and Analysis stated that it would not be inappropriate, however, for EAs to reference the IN. When requested by the NRC staff representatives

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to provide specific information on how EAs might be citing or referencing IN 92-18, none i

of the NEl or utility representatives in attendance at the meeting could provide any details.

Mr. Holahan and Patrick Madden of NRR's Plant Systems Branch stated that the information in IN 92-18 is consistent with NRC regulatory requirements. Because of this 3

difference of opinion between the NRC staff and NEl, Ralph Beedle asked if NRC would p

reexamine the guidance provided in IN 92-18 and suspend enforcement actions related to j

the information in the IN until the issue of whether the guidance is specifically covered by the regulatory requirements has been thoroughly considered. Mr. Emerson emphasized that the industry wants to do the right thing if there are technical issues not previously considered, but it is opposed to NRC not using an appropriate vehicle to impose new requirements if the existing ones are not sufficiently clear.

i Mr. Holahan thanked NEl for having utility representation at the meeting. He indicated that 4

the NRC staff is preparing a formal response to Mr. Beedle's January 14,1997, letter, but could rot commit to a specific completion date.

Attachments:

1. List of Attendees

2. NEl's Briefing Slides Project No. 689 cc w/atts: See next page i

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NRC-NEl MEETING ON INFORMATION NOTICE 92-18 February 7,1997 i

List of Attendees j

Name Oraanization Fred Barbieri GPU Nuclear, Inc.

Thomas Barnett Entergy Ralph Beedle Nuclear Energy institute MaryAnn Biamonte NRC/EDO Cave Brandes Duke Power Company William Burton NRC/DRPM/PECB Stan Chingo Comed Edward Connell NRC/NRR/DSSA/SPLB Fred Emersnn Nuclear Enerly Institute Jeff Ertman IES Utilities Nicholas Fiorsvante Florida Power Corp.

Bryan Ford Entergy Paul Frederickson NRC/ Region 11 Tom Gorman Pennsylvania Power & Light Co.

Gary Holahan NRC/NRR/DSSA George Hunger PECO Energy Co.

N. Prasad Kadambi NRC/RES/DRA Patrick Madden NRC/NRR/DSSA/SPLB Melinda Malloy NRR/DRPM/PGEB John Maracek D.squesne Light Co./BVPS William M. McDevitt Public Service Electric & Gas Co.

Dave Modeen Nuclear Energy institute David Nelson NRC/OE i

~ Jim O'Hanlon Virginia Power Phil Qualls NRC/ Region IV Ron Rispoli Entergy Ronald A. Rose Public Service Electric & Gas Co.

William L. Rossfeld Florida Power Corp.

l Denis Shumaker Public Service Electric & Gas Co.

Barry Sullivan NUS Information Services Theresa Sutter Bechtel Stephen Tingen NRR/EMEB l

Woody Walker Entergy I

j List of Attendees i Name Oraanization K. Steven West NRC/NRR/DSSA/SPLB Leon Whitney NRC/NRR/DSSA/SPLB Bill Williams Pennsylvania Power & Light Co.

1 Abbreviations BVPS Beaver Valley Power Station DRA Division of Regulatory Applications DRPM Division of Reactor Program Management l

DSSA Division of Systems Safety and Analysis EDO Office of the Executive Director for Operations EMEB Mechanical Engineering Branch NRC U.S. Nuclear Regulatory Commission NRR Office of Nuclear Reactor Regulation l

OE Office of Enforcement PGEB Generic issues and Environmental Projects Branch l

RES Office of Nuclear Regulatory Research SPLB Plant Systems Branch j

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FIRE PROTECTION ISSUES i

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NRC / Industry Meeting i

February 7,1997 1

White Flint l

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i DISCUSSION TOPIC l

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Industry concerns related to Information l

Notice 92-18 l

- Policy issues

- Technical issues

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INDUSTRY POSITION i

i Changes to interpretation of regulatory l

requirements should be promulgated i

through appropriate regulatory processes, l

not through the inspection / enforcement process and Information Notices i

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l-INFORMATION NOTICE 92-18 SUGGESTIONS FOR CONSIDERATION i

i IN 92-18 l

- Postulated hot shorts which bypass MOV protection j

devices can cause damage to an MOV before operators isolate the MOV controls from the fire i

area l

- Conceptual modification presented to place l

protection between the postulated hot short and the motor Related inspections

- During interactions with NRC staff concerning 92-l 18, an additional issue has been raised concerning j

multiple versus single spurious actuations

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l-NRC GUIDANCE i

(HOT SHORTS) i s

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Inc ustry Question

- What circuit failure modes must be considered in identifying circuits associated by spurious i

actuation?"

i Generic Letter 86-10 response For consideration of spurious actuation, all possible functional failure states must be evaluated, that is, the component could be energized or de-energized by one or more of the above failure modes.

l Therefore, valves could fail open or closed; pumps could fail running or not running; electrical distribution breakers could fail open or closed."

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Generic Letter 85-01 response

...if the concern is spurious actuation of equipment, j

actual circuit failure modes could be byoassed by i

assuming all oossible failure states for the equipment (valves could fail either open or closed)."

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NRC GUIDANCE j

(SPURIOUS ACTUATIONS) 4 Industry question

- What plant transients should be considered in the design of the alternative of dedicated shutdown systems?"

i Generic Letter 86-10 response Per the criteria of Section Ill.L of 10CFR50 Appendix R, a loss of offsite power shall be i

assumed for a fire in any fire area concurrent with l

the following assumptions:

a. The safe shutdown capability should not be i

adversely affected by any Que spurious actuation or signal resulting from a fire in any plant area; and i

b. The safe shutdown capability should not be i

adversely affected by a fire in any plant area which results in the loss of all automatic functions (signal, logic) from the circuits located in the area in conjunction with one worst case spurious actuation or signal resulting from the fire; and..."

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i-INDUSTRY CONCERNS l

1.N. 92-18 APPLICATION i

Policy issues

- Insights and suggestions in IN 92-18 being l

interpreted as Appendix R compliance requirements Implicit definition as to what is required by applicable sections of 10 CFR 50 Appendix R l

Mods represent de facto backfit l

An IN is not an appropriate vehicle for promulgating regulatory interpretations j

- Enforcement actions taken against licensees not complying with IN 92-18 interpretations

- Regional staff suggestions to plants in refueling outages that circuit modifications appropriate before return to power

- Concerns described in IN 92-18 and associated issues not within licensing basis for many plants

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l INDUSTRY CONCERNS l

1.N. 92-18 APPLICATION l

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Technical issues

- Extensive analysis and NRC review already performed for plant compliance with Appendix R 1

- IN 92-18 issues should be pursued only after careful consideration of all relevant design requirements

- GL 89-10 objectives (increased torque to valve operators) and IN 92-18 objectives (possible damage from excessive torque during hot short conditions) both valid and should be balanced 1

- Treatment of multiple hot shorts from a single fire not required during Appendix R implementation (except for high / low pressure interfaces) 6

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j INDUSTRY RECOMMENDATIONS l

l Changes to interpretation of regulatory j

requirements should be promulgated j

through appropriate regulatory processes, j

not through the inspection / enforcement i

process and Information Notices i

j NRC should suspenc enforcement i

actions re ated to this issue until it has i

been thoroughly considered P

e NEl Project No. 689 cc:

Mr. Thomas Tipton, Vice President Operations and Engineering Nuclear Energy Institute Suite 400 1776 l Street, NW Washington, DC 20006-3708 Ms. Lynnette Hendricks, Director Emergency Preparedness and Waste Regulation Nuclear Energy Institute Suite 400 1776 i Street, NW Washington, DC 20006-3708 Mr. Ronald Simard, Director Advanced Reactors Programs Nuclear Energy Institute Suite 400 1776 l Street, NW Washington, DC 20006 3708 Mr. Nicholas J. Liparulo, Manager Nuclear Safety and Regulatory Activities Nuclear and Advanced Technology Division Westinghouse Electric Corporation P.O. Box 355 Pittsburgh, Pennsylvania 15230