ML20148D469
| ML20148D469 | |
| Person / Time | |
|---|---|
| Issue date: | 05/16/1997 |
| From: | Ross D Committee To Review Generic Requirements |
| To: | Callan L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20007G650 | List: |
| References | |
| NUDOCS 9705300247 | |
| Download: ML20148D469 (3) | |
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UNITED 8TATES y
j NUCLEAR REGULATORY COMMISSION I g WASHINGTON, D.c. Sca46 4001 g'%...../
1 May 16, 1997 1-l MEMORANDUM TO:
L. Joseph Callan l
Executive Director for Operations FROM:
Denwood F. Ross, Jr.,
hairmak j
l Committee to Review Generiepyquire ents
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SUBJECT:
MINUTES OF THE CRGR MEETING NUMBER 304 i
l The Committee to Review Generic Requirements (CRGR) met on Tuesday, April 22,1997 l
from 9:00 a.m. to 12:00 noon. A list of attendees is provided in Attachment 1.
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At this meeting the CRGR reviewed the proposed generic letter titled, " Potential for Degradation of Emergency Core Cooling and Containment Spray Systems Following a l
Loss of-Coolant Accident Due to Construction Deficiencies and Foreign Materialinside the Containment." An earlier version of this generic letter tl led, " Potential for Degradation of i
Emergency Core Cooling System Recirculation Due to Construction Deficiencies and l
Foreign MCerialin the Containment Following a Loss of Coolant Accident," was reviewed j
l by the Committee on February 25,1997 at the CRGR Meeting No. 302; the minutes of that CRGR meeting were issued on April 4,1997. During that review, the CRGR commented that the 19 or so relevant NRC generic communications issued over the past dosen years have not been fully effective, as incidents involving debris and potential degradation of the emergency core cooling system (ECCS) continue to occur. Therefore, the Committee recommended that the NRC take a stronger stance on the subject, such as targeted inspections and escalated enforcement, it was agreed that the staff will rewrite l:
i the generic letter (1) with a greater emphasis that the licensees are required to ensure the j
operability of the structures and components in order to comply with the provisions of the ECCS Rule and the Maintenance Rule, as applicable: (2) combine this generic letter with another generic letter under preparation on the related subject of potential inadequacies in
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the licensees' protective coating programs, especially, the problems associated with the use of unqualified paints and coatings in the containment: (3) make it clear that NRC l
regards these lapses in the foreign material exclusion (FME) programs serious, and is i
willing to focus necessary inspection resources to verify licensee compliance with the j
existing regulations; and (4) that escalated enforcement actions will be taken when j
warranted. The staff agreed to resubmit the revised generic letter reflecting the CRGR recommendations.
Subsequently, the staff redraf ted the generic letter by expanding its scope to include the subject of another generic letter in progress dealing with the problems encountered with pA the use of unqualified paints and coatings in the containment, as recommended by the
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CRGR, and retained some 50.54(f) information request feature. The staff also requested a teroview by the CRGR as the contents, scope, and tone of the originally proposed generic i
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letter were significantlyfevised. The Committee agreed to review the redrafted the I
generic letter, which was accomplished on an expedited schedule.
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l The CRGR made several comments on the scope and the' technical contents of the revised l
draft generic letter, and also discussed the substance of the allegations. Specifically, the i
j Committee recommended that the differences in the FME and the coating issues (i.e., why
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the staff does not request information on FME, but does so on the coatings) should be
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clearly stated. Also, the message in the generic letter should remain focused on the main safety concerns, with separate discussions on the FME and the coatings. This should be followed by strong statements to the effect that NRC regards these lapses in the j
licensees' FME programs as serious, and is willing to focus necessary inspection resources to verify licentse compliance with the existing regulations, and to take escalated enforcement actions consistent with the NRC's enforcement policy, when warranted. The j
staff was also asked to include in an appendix of examples related to these enforcement 4
actions. Furthermore, the Committee recommended that discussion on ANSI standards t
and the Regulatory Guide should clearly point out that these are not requirements and that i
they are being included for information only.
Additionally, the staff should include a stronger statement about applicability of the Maintenance Rule, and finally, should make it clear that the lack of conformance with the requirements applicable to both debris and coatings are subject to enforcement actions.
l The staff redrafted the generic letter by organizing the " Purpose" section, focusing the j
message in the main text of the letter, and moving all the supporting materialin the Appendices.
i Subject to the satisfactory incorporation of these comments plus appropriate changes, as i
deemed appropriate to the boiler-plate material, the Committee endorsed the generic letter j
for issuance. A formal endorsement was sent to the staff by e-mail on May 5,1997.
l contains details.
i At the 304th meeting, the CRGR also reviewed the proposed supplement to Bulletin 96-01, " Control Rod Insertion Problems." The Committee made several comments regarding j
the scope and the technical content of the proposed supplement. There was specific discussion on the applicability of the requested actions in the proposed supplement only to 4
i the licensees of the Westinghouse-and B&W-designed PWRs, but not to the licensees of j
l CE-designed PWRs. Also, the design aspects of the rod insertion problems warranted i
discussion. The staff elaborated on the design differences between the NSSS vendors and j
thimble tube design variations, as applicable, in supporting the rationale for excluding the j
licensees of the CE-designed plants. The staff summarized the world wide experience and
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the results of the licensee responses to Bulletin 96-01, and the conclusions drawn, j
including the rationale for the prescriptive requirements in the proposed supplement.
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There was also a discussion on the applicability of the General Design Criteria (GDCs) (of j
Appendix A to 10 CFR 50) to operation. Specifically, in the proposed supplement, the text under the " Regulatory Requirements," which began with "The regulatory requirement for i
i operation..." explicitly referenced GDC 26 and GDC 29, raised questions, as there may be l
as many as 60 plants licensed during the pre GDC days. The Committee maintained that i
although over the years the intent of the design requirements articulated under the GDCs i
have been included in the current licensing basis of various facilities, GDCs are not s
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7 L. J. Callan i generically enforceable. However, the plant Technical Spec lfications and the requirements included in Appendix B of 10 CFR 50 are. Specifically, Criterion XI, " Test Control," of Appendix B,is a binding legal requirement. The wording used in the " Requested Actions" and those of the " Required Response" sections were discussed in detail.
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l The CRGR recognized that the requested actions are very specific and prescriptive, However, they do have definite merit as they relate to ensuring the operability of the reactor protection system and maintaining adequate shutdown margin. Thus, the CRGR agreed with the staff in invoking the compliance exception to the backfit rule. In addition, j
since the licensees were not afforded any flexibility of proposing other viable alternatives, the Committee recommended that,in lieu of testing at prescribed intervals, the alternative i
of a rigorous engineering analysis to demonstrate control rod insertion ability (which was already suggested in the text of the proposed supplement) be also included in the
" Requested Actions."
l Subject to incorporation of these comments, the Committee endorsed the bulletin supplement for issuance. A formal endorsement was sent to the staff by e-mail on May 1, 1997. Questions concerning these meeting minutes should be referred to Raji Tripathi (415-7584).
Attachments: As stated cc:
Commission (5)
SECY J. Lieberman, OE E. Halman, ADM H. Bell, OlG K. Cyr, OGC J. Larkins, ACRS Office Directors i
Regional Administrators, RI-RIV B. Sheron, NRR CRGR Members G. Holahan, NRR Distribution:
l sfile Center (w/attch)'
PDR (NRC/CRGR) (w/o attch)
CRGR SF CRGR CF STreby EJordan JMitchell CBerlinger RTripathi JMeadoff JLyons RLobel JDavis MChatterton RElliott MMarshall WBurton ASerkiz ASingh JShapaker JStrosnider DISK / DOCUMENT NAME: S:\\CRGR\\MTSNEW.304 To rsesive a copy of this document, indicate in the box: "C" = Copy w/o attachment, "E" = Copy w/ attachment, "N" = No copy D:AkD\\
OFC CRGR fj. j RTripathth DFRk NAME DATE 05//J/97 Oh7
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OFFICIAL HECORD COPY
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