ML20136E058

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Summary of ACRS Subcommittee on Regulatory Activities 851008 Meeting in Washington,Dc to Discuss Proposed Reg Guide 1.23, Rev 1,Reg Guide 1.105,Rev 2 & Reg Guide, Criteria for Power Instrumentation & Control Portions of Safety Sys
ML20136E058
Person / Time
Issue date: 10/15/1985
From:
Advisory Committee on Reactor Safeguards
To:
Advisory Committee on Reactor Safeguards
References
RTR-REGGD-01.023, RTR-REGGD-01.105, RTR-REGGD-1.023, RTR-REGGD-1.105 ACRS-2361, NUDOCS 8601060399
Download: ML20136E058 (10)


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SUMMARY

/ MINUTES OF THE 1o/23 lgg ACRS SUBCOMMITTEE MEETING ON THE REGULATORY ACTIVITIES OCTOBER 8, 1985 WASHINGTON, D.C.

INTRODUCTION The ACRS Subcommittee on the Regulatory Activities held a meeting on Tuesday, October 8, 1985 at 1717 H Street, N.W., Washington, D.C., to discuss some proposed Regulatory Guides. The entire meeting was open to public attendance. Mr. Sam Duraiswamy was the cognizant ACRS Staff engineer 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 Chairman), M. W. Carbon, C. J. Wylie, D. W. Moeller (Part time for Regulatory Guide 1.23, Revision 1), and W. Kerr (Part time for Regulatory Guide IC 609-5)

R. Abbey (special invited consultant for Regulatory Guide 1.23, Revision 1)

S. Duraiswamy (Cognizant ACRS Staff engineer)

Principal NRC Speakers: B. Morris, A. Hintze, D. Sullivan, L. . Brown, L. Beratan, I. Spickler, and F. Rosa EXECUTIVE SESSION Dr. Siess, the Subcommittee Chairman, convened the meeting at 9:00 a.m.

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

Proposed Regulatory Guide 1.23, Revision 1, " Meteorological Mea-surement Program for Nuclear Power Plants" (Pre Comment).

Proposed Regulatory Guide 1.105, Revision 2, " Instrument Setpoints for Safety-Related Systems" (Post Comment).

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Regulatory Activities Minutes October 8, 1985

  • Proposed Regulatory Guide (Task No. IC 609-5), " Criteria for Power, f

Instrumentation, and Control Portions of Safety Systems" (Post Comment). -

i He said that the Subcomittee had received neither written comments nor requests for time to make oral statements from members of the public.

r PROPOSED REGULATORY GUIDE 1.23, REVISION 1, " METEOROLOGICAL MEASUREMENT PROGRAM FOR NUCLEAR POWER P'.. ANTS" - MRS. L. BROWN Mrs. Brown stated that Regulatory Guide 1.23, Revision I describes a meteorological measurement program acceptable to the NRC Staff for providing meteorological data needed to estimate potential radiation i

doses to the public resulting from routine or accidental releases of radioactive materials to the atmosphere, or to evaluate the potential dose to the public as a result of hypothetical acc1 dents in nuclear power plants. This Guide does not setforth new Staff positions, rather it consolidates the existing guidance on meteorological measurements contained in various NRC documents.

This Guide endorses, with an exception, the provisions of the industry Standard ANSI /AN.t-2.5-1984, " Standard for Determining Meteorological Information at Nuclear Power Sites."' Although ANSI /ASME NQA-1-1983,

" Quality Assurance Program Requirements for Nuclear Facilities" is referenced in the ANSI /ANS 2.5 Standard, it is not endorsed by this Guide for use with the quality assurance programs related to meteoro- l logical measurement programs for operating reactors. Instead, this Guide recommends the guidance in Regulatory Guide 1.33, " Quality Assurance Program Requirements (Operation)," for the quality assurance

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program and. record retention period related to meteorological measurement programs for operating reactors. I A previous version of this Guide was reviewed by the Regulatory Activ-ities Subcommittee during its meeting on November 11, 1981. During the l t

Regulatory Activities Minutes October 8, 1985 November 12-14, 1981 ACRS meeting, the full Comittee endorsed the Subcomittee's recomendation that the ACRS action on this Guide be deferred until the need for this Guide has been evaluated by the Comit-tee to Review Generic Requirements (CRGR).

This Guide was not reviewed formally by the CRGR. Recently, CRGR l

decided that there is no need for it to review this Guide since it does not impose any new requirements.

Mr. Abbey suggested that the statement included in paragraph 1.3.3 of the Value/ Impact Statement Section which states that "Since the product f

document endorses an ANS Standard, the Nuclear Industry has co.isidered the recommendations and any related costs to be reasonable," be modified. "

-to read as "since the product document... and any related costs to be acceptable." The NRC Staff agreed to make the change suggested by Mr. Abbey.

Dr. Carbon asked whether the recomendations of the ANSI /ANS-2.5 Stan-dard have actually been considered and accepted by the utilities, rather than by instrument vendors. Mr. Spickler responded that there are no i instrument vendors on the Nuclear Standards Comittee of ANSI that reviews normally all the Standards associated with nuclear matters.

However, there are representatives of some utilities in the ANS-2.5 as well as ANS-2 Comittees who have reviewed-and accepted the recomenda-tions of the ANSI /ANS-2.5 Standard.

Dr. Carbon asked how much money an utility company has to spend to meet all of the provisions of this Guide. Mr. Spickler stated that to install a new meteorological system, it would cost about half a million dollars. For maintaining such system, it would cost about $5,000

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annually. He mentioned that most of the nuclear plants have some sort of meteorological system already in operation.

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. Regulatory Activities Minutes October 8, 1985 I

Dr. Carbon commented that although this Guide is not intended to impose any new requirements for operating nuclear power plants, it should be made sure that it will not impose unnecessary requirements on future plants. Mr. Spickler responded that it is not the intent.

The Subcommittee discussed briefly the written comments provided by Dr. Moeller in his memorandum to S. Duraiswamy, dated September 21, 1985. The NRC Staff has agreed with most of the editorial changes suggested by Dr. Moeller.

After further discussion, the Subcommittee suggested some editorial changes, provided guidance for clarification in certain parts of this Guide, and stated that it would submit this Guide to the full Connittee during the October 10-12, 1985 ACRS meeting recommending concurrence in the NRC Staff's proposal to issue this Guide for public comment.

PROPOSED REVISION 2 TO REGULATORY GUIDE 1.105, " INSTRUMENT SETPOINTS FOR NUCLEAR POWER PLANTS" - MR. A. HINTZE Mr. Hintze provided a preamble, stating that the proposed Regulatory Guide 1.105, Revision 2 describes a method acceptable to the NRC Staff for complying with the Commission's regulations for ensuring that instrument setpoints are initially within and remain within the techni-cal specification limits. This Guide endorses, without exceptions, the provisions of the Instrument Society of America (ISA) Standard - ISA-S67.04-1982, "Setpoints for Nuclear Safety-Related Instrumentation Used in Nuclear Power Plants."

A previous version of this Guide _that contained 10 regulatory positions was reviewed by the Regulatory Activities Subcommittee on November 16, 1983, and the ACRS full Connittee concurred in the positions of this Guide during its November 17-19, 1983 meeting. However, since CRGR felt that the 10 regulatory positions added to this Guide to provide clari-

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fication to the ISA Standard were not justified, another version of this

Regulatory Activities Minutes October 8, 198S Guide was prepared during April 1984 including the contents of the 10 regulatory positions in the Discussion Section of this Guide. Based on its review of this revised version, CRGR commented that the infonnation added to the Discussion Section was not justified and should be deleted from this Guide. Subsequently, the present version of this Guide was prepared incorporating the CRGR comments.

Dr. Siess stated that he was given to understand that some members of the NRC Staff felt that some of the information added to Discussion Section to provide clarification to the ISA Standard, but eventually deleted as a result of CRGR concern, should have been. retained in the Guide, and failure to provide such clarification may result in increased Staff efforts because the Staff may have to provide such clarification at a later stage on a case-by-case basis. He asked whether some of the NRC Staff still feel the same way. Mr. Rosa, NRR, responded that, in his opinion, some of the guidance included in the Discussion Section of this Guide should not have been deleted. He still believes that failure to include such guidance in this Guide may increase the Staff efforts.

One of the CRGR functions.is to improve the effectiveness and efficiency of the regulatory process, but he feels that in this case the CRGR seems to have overlooked that function.

Mr. Wylie commented that some of the information eliminated from the Discussion Section of this Guide would have been helpful to the industry to understand how-the NRC Staff is going to interpret certain provisions

, of the Standard.

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( Dr. Siess asked why didn't the ISA Consnittee include additional informa--

f tion in the Standard to make it unambiguous, if the NRC Staff believes that the ISA Standard is ambiguous and certain infonnation needs to be included in the Guide to clarify the Standard. Mr. Morris responded that he believes that the technical content of the Standard is.

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Regulatory Activities Minutes October 8, 1985

, unambigucus. If it is ambiguous, the RES Staff would not have deleted all the information added in the Discussion Section.

Mr. Rosa stated that they plan to work with the ISA Standard Comittee to get a revision to the Standard so as to include some additional clarification.

The Subcommittee felt that although the information deleted from this Guide as a result of CRGR concern are not substantive in terms of public safety, some of the information should have been retained in the Dis-cussion Section of this Guide to provide additional guidance to the industry.

Mr. Hintze stated that this Guide has been under preparation for about five years. He believes that even those members of the Staff who are unhappy about the deletion of the additional information included in the l Discussion Section would agree that the issuance of this Guide for industry use should not be delayed further.

Indicating that the statement in the Implementation Section of this Guide, "However, the Staff does not intend to recommend the systematic application of every aspect of this guide to plants currently operat-ing," seems to imply that some aspects of this Guide will be applied to operating plants, Dr. Siess asked to what extent the provisions of this Guide will be backfitted in operating plants. The. Staff responded that the industry has already been following the provisions of the ISA Standard endorsed by this Guide. The Staff does not intend to apply all of the provitions of this Guide to operating plants. They merely indicate that the application of some of the provisions of this Guide could make those plants safer.

Dr. Siess commented that he is pleased to see a Regulatory Guide endorse, without exceptions, the provisions of an industry standard. He l

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Regulatory Activities Minutes October 8, 1985 l believes that this represents an improved cooperative effort between the NRC and the industry.

After further discussion, the Subcomittee stated that it would submit this Guide to the full Comittee during the October 10-12, 1985 ACRS meeting, recomending concurrence in the regulatory position of this Guide.

PROPOSED REGULATORY GUIDE (TASK NO. IC 609-5), " CRITERIA FOR POWER, INSTRUMENTATION, AND CONTROL PORTIONS OF SAFETY SYSTEMS" - MR. A. HINTZE Mr. Hintze reviewed this Guide stating that it describes a method acceptable to the NRC Staff for complying with the Comission's regu-lations with respect to the design, reliability, qualification, and testability of the power, instrumentation, and control portions of safety-related systems of nuclear power plants. It endorses, with certain exceptions, IEEE Standard 603-1980, " Criteria for Safety Systems for Nuclear Power Generating Stations." He said that IEEE 279-1971,

" Criteria for Protection Syst' ems for Nuclear Power Generating Stations,"

which is already incorporated into the Comission's regulations, includes criteria only for the nuclear power plant protection systems.

IEEE 603-1980 provides the same criteria as IEEE 279-1971 for protection systems, but is expanded in scope to provide additional guidance for protection system actuation functions and auxiliary systems.

Mr. Hintze said that a previous version of this Guide was sent to the ACRS for review during April 1982. Since it was the only item submit-ted, Dr. Siess, Chairman of the Regulatory Activities Subcomittee, felt that a Subcomittee meeting to discuss one item was not justified. It was decided that the NRC Staff. could issue this Guide for public coment and the ACRS review would be performed subsequent to the public coment period. This Guide was issued for public coment in December.1982. The present version of this Guide reflects consideration of public coments and the CRGR recommendations.

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. Regulatory Activities Minutes October 8, 1985 '

Dr. Kerr suggested that it would be helpful if the correlation between the Discussion Section and the Regulatory Position Section was made clear by referencing the corresponding regulatory position number in the Discussion Section. The Staff agreed to consider this suggestion.

With reference to Figure 1 in the Guide which is intended to replace Figure 7 of the IEEE 603 Standard, Dr. Kerr commented that the words in the bottou block of Figure I are ambiguous. After further discussion, Dr. Siess suggested that it would be helpful if the NRC Staff replaced the words in the bottom block of Figure 1 in the Guide with the words in the bottom block of Figure 7 of the IEEE 603 Standard. The NRC Staff agreed.

The Subcommittee suggested some editorial changes in the Value/ Impact Statement Section of this Guide, provided guidance for clarification in certain parts of this Guide, and stated that it would submit this Guide to the full-Committee during the October 10-12, 1985 ACRS meeting, recommending concurrence in the regulatory positions of this Guide.

Dr. Siess thanked all participants and adjourned the meeting at 1:40pm.

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 ACE-Federal Reporters, 444 North Capitol Street, N.W.,

Suite 402, Washington, D.C. 20001, (202) 347-3700.

9/30/85

-TENTATIVE PRESENTATION SCHEDULE -

ACRS SUBCOMMITTEE MEETING ON THE REGULATORY ACTIVITIES OCTOBER 8, 1985 ROOM 1046, 1717 H STREET WASHINGTON, DC NOTE: TOTAL PRESENTATION TIME INCLUDES:

  • '%# 50% for actual presentation
  1. %'50% for Subcommittee ACRS

Contact:

Sam Duraiswamy (634-3267) Questions and Answers TOTAL PRESENTATION ACTUAL ITEM SPEAKER TIME TIME I. Executive Session --

15 Min. 9:00 - 9:15am II. Regulatory Guide 1.23, Revision 1, " Meteorological Measurement Program for Nuclear Powers Plants" (Pre Comment) Leta Brown 90 Min. 9:15 - 10:45am

      • BREAK *** 15 Min. 10:45 - 11:00am III. Regulatory Guide 1.105, Revision 2, " Instrument Setpoints for Safety-Related B. Morris /

Systems"(PostComment) Al Hintze 90 Min. 11:00 - 12:30pm

      • LUNCH ***

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60 Min. 12:30 - 1:30pm IV. Regulatory Guide IC 609-5,

" Criteria for Power, Instrumentation, and Control Portions of Safety Systems" (PostComment) Al Hintze 90 Min. 1:30 - 3:00pm V. Subcommitee Remarks 30 Min. 3:00 . 3:30pm

      • ADJOURN *** 3:30pm l

ATTACHMENT A L

LIST OF DOCUMENTS SUBCOMMITTEED TO THE REGULATORY ACTIVITIES SUBCOMMITTEE OCTOBER 8, 1985

1. Proposed Regulatory Guide 1.23, Revision 1, " Meteorological Mea-surement Program for Nuclear Power Plants," dated July 26, 1985.
2. Proposed Regulatory Guide 1.105, Revision 2, " Instrument Setpoints for Safety-Related Systems," dated July 12, 1985.
3. Proposed Regulatory Guide, IC 609-5, " Criteria for Power, In-strumentation, and Control Portions of Safety Systems," dated June 13, 1985.
4. Letter from R. F. Fraley to W. J. Dircks on Regulatory Guide 1.23, Revision 1, dated November 17, 1981.
5. Memorandum from C. P. Siess to ACRS Members providing written Subcommittee report on Regulatory Guide 1.23, Revision 1, dated November 12, 1981.
6. Minutes of the October 14, 1981 Regulatory Activities Subcommittee meeting related to the Regulatory Guide 1.23, Revision 1.

i 7. Minutes of the November 11, 1981 Regulatory Activities Subcommittee-meeting related to the Regulatory Guide 1.23, Revision 1.

8. Memo from S. Duraiswamy to T. Murley, CRGR, transmitting written comments by M. Bender on Regulatory Guide 1.23, Revision 1. ,
9. Minutes of the November 16, 1983 Regulatory Activities Subccmmittee meeting related to Regulatory Guide 1.105, Revision 2.
10. Memorandum from D. Ross to CRGR members related to Regulatory Guide 1.105, Revision 2, dated January 30, 1985.
11. Memorandum from R. B. Minogue to 11. R. Denton related to Regulatory

, Guide 1.105, Revision 2, dated May 6, 1985.

12. Memorandum from H. R. Denton to R. B. Minogue related to Regulatory Guide 1.105, Revision 2, dated June 27, 1985.
13. Memorandum from A. Hintze to S. Duraiswamy transmitting the ISA procedures, dated May 1984.
14. Memorandum from A. Hintze to W. Morrison related to Regulatory Guide 1.105, Revision 2, dated April 25, 1984.
15. Minutes of the CRGR meeting Number 76 related to the discussicn of Regulatory Guide IC 609-5, dated July 15, 1985.
16. Memo from S. Duraiswamy to Regulatory Activities Subcommittee members related to the Regulatory Guide IC 609-5, dated April 23, 1982.

ATTACINENT B

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