ML20149E113
| ML20149E113 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 07/14/1997 |
| From: | Ross D Committee To Review Generic Requirements |
| To: | Randolph G UNION ELECTRIC CO. |
| References | |
| NUDOCS 9707180106 | |
| Download: ML20149E113 (10) | |
Text
T July 14, 1997 Mr. Garry L. Randolph Vice President and Chief Nuclear Office g,. t[$
Union Electric Company i
P. O. Box 620 Fulton, Missouri 65251
Dear Mr. Randolph:
I would like to thank you for acceptirg our request that the Committee to Review Generic Requirements (CRGR) visit with the management and staff of the Callaway plant on July 23,1997. You should note that this visit is not an inspection; rather, it is an informal exchange of views on the role that backfit management plays in the regulatory process.
We would propose that our one day visit include meetings with plant management and an operating crew, and some time for follow-up remarks. Our intent in speaking to members of an operating crew (perhaps a crew is going through a trainiog session) is to obtain their views on the impact of generic communications on their performance of their licensed
}
duties.
) provides a preliminary agenda. Enclosure 2 provides a list of potential discussion questions relating to the evaluation and implementation of new generic requirements. The que.stions in Enclosure 2 are simply illustrative of subjects that are of interest to the CRGR, and do not constitute a request to you for a written reply. Let me know if you would like to add some items to this preliminary agenda. Enclosure 3 provides i
a summary of recent CRGR activities in reviewing new generic requirements. Enclosure 4
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provides a list of attendees. Enclosure 5 contains the CRGR Charter, Revision 6.
Please refer any questions to me at (301) 415-7472, or Dr. Raji Tripathi of the CRGR staff j
at (301) 415-7584.
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$ iNI' Signed by:
l Denwood F. Ross Dr. Denwood F. Ross, Jr., Chairman Committee to Review Generic Requirements l
Enclosures:
As stated Distribution:
Dross FMiraglia i
.cc/w enclosures:
MKnapp JMurphy j
Alan C. Passwater, Manager DDambly JDyer
/l Licensing and Fuels, Union Electric Company RTripathi RZimmerman Mark Reidmeyer, Union Electric Company DPassehl FBrush Samuel Collins, NRC KThompas JStone h/
1.g g Ellis Merschoff, NRC EJordan CRGR R/F CRGR S/F Fiie Center i
DISKlDOCUMENT NAME: S:\\CRGR\\CALLVISIT.797 PDR (NRC/CRGR)
To recoive a copy of this document, indicate in the box:
"C" = Copy w/o attachment, "E" - Copy w/ attachment, "N" = No copy OFC CRGR:AEOD C:CRGd RTripathih DFRosM g
g NAME DATE 7 p/97 h/h7 OFFICIAL RECORD COPY IR. II EI,R M, R, I,
'7o72*o2o' '7o7t*
11 PDR ADDCK 05000483 P
a PRELIMINARY AGENDA CRGR Visit to Callaway Plant July 23,1997
[ NOTE: ORDER OF EVENTS AND TIME ALLOCATIONS MAY CHANGE]
WEDNESDAY - July 23,1997 l
8:00 a.m. - 8:15 a.m.
Arrival at Callaway Plant Site & Badging Process 8:15 a.m. - 10:45 a.m.
Discussions with Union Electric Management General review of the backfit process and the role of CRGR; discussion of recent backfits (either generic or plant-specific) and their impact on the plant.
10:45 p.m. - 11:45 p.m.
Discussion with Operators Lunch Break 12:45 p.m. - 2:45 p.m.
Plant Tour 2:45 p.m. - 4:45 p.m.
Discussions with Union Electric Company Management (cont.)
4:45 p.m. - until Wrap-up ENCLOSURE 1
1 QUESTIONS FOR POSSIBLE DISCUSSION CRGR VISIT TO CALLAWAY PLANT July 23,1997 1.
Evaluation of Recently issued Generic Requirements a.
Have you had any difficulty in understanding documents (e.g., bulletins or generic letters) that transmit new or changed generic requirements / positions?
Has NRC applied the new requirements / positions appropriately in accordance with your understanding of them?
Cite examples of any specific difficulties.
b.
Generally, do you agree with the need for the new requirements / positions that have been transmitted over the past two years or so? Has implementation of the new requirements / positions improved safety (significantly, some, not at all) at your plant? Has any adversely affected safety in any instance in your judgment? Which have not improved safety or have not been technically justified?
c.
Did you feedback comments to NRC on any difficulties encountered?
In your view, are there appropriate mechanisms for such teedback?
I Would you have any reluctance to use such mechanisms?
d.
What has been your experiences with and what are your comments on the following:
Generic Letter (and Supplement) on thermo-lag fire barriers.
Supplements 1-6 to Generic Letter 89-10 regarding motor-operated valves.
Supplement 4 to Generic Letter 88-20 regarding individual plant examinations for external events (IPEEE).
Generic Letter 91-07 regarding reactor coolant pump seal failures and the potential impact on station blackout.
Information Notice 9317 regarding design to accommodate LOCA/ delayed LOOP.
ENCLOSURE 2
2 Generic Letter 92-01, Revision, Supplement 1, concerning reactor pressure vesselintegrity.
Bulletin 96-02 on movement of heavy loads.
Recently published for comments the proposed generic letter
" Potential for Degradation of Emergency Core Cooling System and Containment Spray Systems Following a Loss-of-Coolant Accident Due to Construction Deficiencies and Foreign Materialinside the Containment."
Recently issued generic letter titled " Degradation of Control Rod Drive Mechanisms and Other Vessel Head Penetrations" What is your experience? Is Callaway vulnerable?
Recently published for comments the proposed Supplement 1 to Bulletin 96-01, " Control Rod Insertion Problems."
Recently proposed generic letter titled " Assurance of Sufficient Net Positive Suction Head for Emergency Core Cooling and Containment Heat Removal Pumps."
50.64(f) Generic Letter on Design Basis Information.
Maintenance Rule.
Procurement and dedication of commercial grade items for safety applications.
2.
What has been the impact of the new requirements / positions that have been transmitted over the past two years or so; specifically:
a.
What is your tally of the actual cost of implementing new NRC requirements? (For example, what has been the actual costs of implementing specific new requirements / positions; and what has been the total cost of all backfits over a specific period?)
What is your view of the accuracy of NRC cost estimates?
b, Have any new NRC requirements / positions delayed or otherwise adversely affected intended improvements identified and undertaken solely on your initiative? Were any of your initiatives considered to b'e of higher priority than new NRC requirements / positions? Were any of higher safety importance?
3.
How is NRC's backfit control process working in your view, specifically:
a.
The CRGR review process for generic requirements?
3 b.
NRC process for plant-specific backfits?
4.
With regard to plant modifications / upgrades initiated by you (not resulting from new NRC generic requirements):
a.
What were the most important/ effective actions you have taken to improve performance (e.g., significant capitalimprovement items in the plant; significant increases in operating budget / personnel / training etc.)?
b.
Have new NRC generic requirements / positions helped or adversely impacted your ability to improve performance?
c.
Have NRC feedback documents (information notices, AEOD case studies, etc.) helped in a meaningful and specific way to improve plant performance?
5.
NRC has placed an emphasis on the use of specific assessments to identify and characterize potential sources of increased risk. These include PRA studies such as NUREG-1150, individual plant examinations, specific containment reviews and severe accident studies. What comments would you offer on the benefits, costs, efficiency, impacts, knowledge, insights and values that are associated with these assessments?
6.
Some of the comments received in the NRC's regulatory impact survey indicate that too many new requirements / positions are being issued (e.g., generic letters). Do you agree with this assessment? If so, are there far too many? Which new requirements / positions do you believe should have been withheld or postponed significantly?
7.
Do you believe that any new positions or requested actions contained in generic letters and bulletins you have received from NRC ought to have been processed as new rules instead? Which ones? Please explain.
8.
Do the generic issuances generally explain the safety problem being addressed so that you can understand the motive behind the issuance?
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i COMMITTEE TO REVIEW GENERIC REQUIREMENTS Generic requirements and positions proposed by the NRC staff for one or more classes of reactors are reviewed by the Committee to Review Generic Requirements (CRGR). The Committee is made up of senior NRC managers who review such proposals and advise the Executive Director for Operations (EDO) as to whether or not the requirement or position should be issued.
The current membership of the CRGR is as follows:
Denwood i ess, Jr. (Chairman), Director Office for /
F.' sis and Evaluation of Operational Data Frank J. Miraglia, Jr., Deputy Director Office of Nuclear Reactor Regulation hlalcolm R. Knapp, Deputy Director Office of Nuclear Material Safety and Safeguards Joseph A. Murphy, Director Division of Regulatory Applications Office o' Nuclear Regulatory Research Dennis C. Dambly, Deputy Assistant General Counsel for Materials, Anti-trust and Special Proceedings Office of the General Counsel James E. Dyer, Deputy Regional Administrator Region IV in making its evaluations of proposed requirements, the CRGR seeks assurance that a proposed requirement (1) is necessary for the pubiic health and safety, (2) is needed for compliance with existing requirements or written licensee commitments, or (3) will provide a substantial improvement in public safety or security and to have a cost impact on the public, industry and government which is consistent with and justified by the improvernent to be realized.
Since its inception in November 1981 through June 10,1996, the CRGR has held 288 meetings and taken up a total of 486 separate issues. Since May 1996 through June 1997, the CRGR has considered the following items-l Proposed final Regulatory Guide 1.153 and important-to-Safety issue RES Expedited Bulletin on Chemical, Galvanic and Other Reactions in Spent Fuel Storage and Transportation Casks NMSS ENCLOSURE 3 l
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2 50.54(f) Letter on Design Basis Information NRR Urgent Generic Letter on Assurance of Equipment operability and Containment Integrity During design basis Accident Conditions NRR Expedited Generic Letter on Loss of Reactor Coolant inventory and Associated potential for Loss of Emergency Mitigation Features While in a Shutdown Condition NRR i
Proposed Standard Review Plan, Chapter 7, " Instrumentation and Control,"
Update NRR Proposed SER on WCAP-144416-P (Credit for soluble boron issue)
NRR Briefing on Source Term Options (Commission Paper)
NRR o
Proposed Steam generator Ir.tegrity Rule NRR Briefing on risk-informed Regulatory Guides and associated Standard Review Plans Proposed general Regulatory Guide - risk-informed rt alations guidaner W':uments RES and NRR Proposed general SRP Briefing on Proposed Rule on Shutdown and Low-Power Operations and Spent Fuel Pools NRR Briefing by D. Muscara (RES) on ISI background concerns Review of Froposed Generic Letter on Effectiveness of Ultrasonic Testing Systems in ISI Programs NRR Review of Proposed Generic Letter on Stearn Generator Tube inspection techniques NRR Review of Proposed Generic Letter on Degradation of Steam Generator Internals NRR General Regulatory Guide (Excluding the Appendices) and SRP
.NRR Proposed Application-specific Regulatory G l des and SRPs - risk-informed regulations guidance documents RES and NRR RG and SRP inservice Testing RG and SRP on Technical Spec!hrations
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3 e
Urgent Generic Letter on Assurance of Sufficient NPSH for Emergency Core Cooling and Containment Heat Remova! Pumps NRR e
Generic Letter on Modification of the NRC Staff's Recommendations for the Post-Accident Sampling System NRR e
Generic letter on Degradation of Control Rod Drive Mechanism and Other Vessel Head Penetrations e
Generic letter on Degradation of Control Rod Drive Mechanism and Other Vessel Head Penetrations NRR e
CRGR review and endorsement the proposed Revision 2 to Regulatory Guide (RG) 1.160, which endorses Revision 2 to NUMARC 93-01, " Industry Guideline For Monitonng The Effectiveness Of Maintenance At Nuclear Power Plants" (April 1996 version), and provides certain clarifications (CRGR Material item No.153)
NRR CRGR review of the proposed generic letter " Potential for Degradation of e
Emergency Core Cooling System Recirculation due to Construction Deficiencies and Foreign Materialin the Containment Following a Loss-of-Coolant Accident."
(CRGR MaterialItern No.154)
NRR e
CRGR review of the revised general Regulatory Guide and Standard Review Plan for risk-informed regulation (CRGR ltem No.155)
NRR e
CRGR review of the revised application-specific (Inservice Testing, Technical Specifications, and Graded Quality Assurance) Regulatory Guides and the accompanying Standard Review Plans for risk-informed regulation.
NRR CRGR review of the revised proposed generic Ictter dealing with degradation of the e
emergency core cooling system and the containment spray system due to foreign materialinside containment and construction deficiencies (An earlier version of this generic letter was reviewed by the CRGR on February 25,1997 at the meeting No.
302).
NRR e
CRGR review and endorsement of Supplement 1 to Bulletin 96-01, " Control Rod Insertion Problems."
NRR CRGR briefing and review of the proposed rulemaking on shutdown and e
spent fuel pool operations NRR e
CRGR review of the revised SRP, Chapter 7, "!nstrumentation and Controls,"
Update NRR
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4 Proposed generic letter on problems with medium-voltage circuit e
' breakers NRR i
Standard Review Plan, Chapter 7, " Instrumentation and Controls,"
e Update NRR Safety Evaluation Report on EPRI Topic 4 report, " Guideline on Evaluation and Acceptance of Commercial Grade Digital Equipment for Nuclear Safety Applications," EPRI TR-106439 NRR Six Regulatory Guides for computer software in nuclear safety RES e
applications
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LIST OF ATTENDEES Denwood F. Ross, Jr. (Chairman), Director Office for Anolysis and Evaluation of Operational Data Frank J. Miraglia, Jr., Deputy Director Office of Nuclear Reactor Regulation Malcolm R. Knapp, Deputy Director Office of Nuclear Material Safety and Safeguards Joseph A. Murphy, Director Division of Regulatory Applications Office of Nuclear Regulatory Research Dennis C. Dambly, Deputy Assistant General Counsel for Materials, Anti-trust and Special Proceedings Office of the General Counsel 2
James E. Dyer, Deputy Regicnal Administrator Region IV Raji Tripathi, Senior Program Manager CRGR Staff Office for Analysis and Evaluation of Operational Data l
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I ENCLOSURE 4
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