ML20153B060

Summary of 980828 Meeting W/Nei in Rockville,Md Re NEI Revised Approach to risk-informed,performance-based Pilot Project.Attendance List & Handouts Encl

ML20153B060
Person / Time
Issue date:	09/17/1998
From:	Stewart Magruder NRC (Affiliation Not Assigned)
To:	Essig T NRC (Affiliation Not Assigned)
References
PROJECT-689 NUDOCS 9809220304
Download: ML20153B060 (32)

Text

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION 2

WASHINGTON, D.C. 206 + 0001

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September 17, 1998 MEMORANDUM TO:

Thomas H. Essig, Acting Chief Generic Issues and Environmental Projects Branch Division of Reactor Program Management Office of Nuclear Reactor Regulation FROM:

Stewart L. Magruder, Project Manager Jh%d % 1 Generic issues and Environmental Projects Branch l

Division of Reactor Program Management Office of Nuclear Reactor Regulation

SUMMARY

OF MEETING HELD ON AUGUST 28,1998, WITH NEl TO DISCUSS RISK-INFORMED, PERFORMANCE-BASED PILOT PROJECT On August 28,1998, the staff held a public meeting with the Nuclear Energy Institute (NEI) at NRC headquarters in Rockville, Maryland. The purpose of this meeting was to discuss NEl's rovised approach to a risk-informed, performance-based pilot project. Attachment 1 lists the meeting participants. Attachment 2 comprises the handouts presented by NEl during the meeting.

The NEl representative opened the meeting by stating that the objective of the pilot projec: is to incorporate risk and performance-based information into the regulatory requirements in an efficient and effective manner. He stated that NEl's goal in this risk focus on regulations is on the safe operation of existing plants. He also stated that they believe that the current regulations, with their emphasis on design basis events, could be improved by focusing on more likely accidents.

The NEl representative stated that the pilot plants for this project are Arkansas Nuclear One, South Texas, and San Onofre. He discussed the schedule for the project (included in the handouts) and emphasized the importance of a dedicated, multi disciplined team of NRC

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reviewers to meeting the schedule. He stated that the phased exemption approach was y

important to the pilot plants to facilitate timely implementation and allow them to begin to see benefits from their extensive probabilistic safety assessment ef' orts. He noted that another key element for success was rulemaking to allow the rest of the industry to adopt similar changes.

I),r03 In response to questions from the NRC staff, the NEl representative stated that the industry intends to measure the safety performance and cost benefit of the pilots and that the industry does not view the program as voluntary. He stated that the industry believes that the rulemaking should allow for an implementation phase-in period, similar to what was done with the maintenance rule, but that the new rules would supersede existing rules, not supplement them.

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dw T. Essig September 17, 1998 The group next discussed the " road map" for transforming current regulations to a risk-informed, performance-based regulation approach presented by NEl. A consensus was reached that more study was needed before a decision to commit NRC resources could be made. In addition, it was agreed that the process should include as much public involvement (e.g. workshops) as possible and that a commitment from the whole industry is essential.

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The NRC staff committed to look more closely at the proposed schedule and to discuss this project with senior management. NEl committed to (1) schedule a briefing on this subject with senior NRC managers, (2) make a formal submittal to the staff after the briefing, and (3) include additional details on the actual implementation effects of the proposal in the formal submittal.

The group agreed that additional meetings on this subject should be held.

Project No. 689 Attachments: As stated cc w/att: See next page i

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l T. Essig

-2 September 17, 1998 o

The group next discussed the " road map" for transforming current regulations to a risk-informed, performance-based regulation approach presented by NEl. A consensus was i

reached that more study was needed before a decision to commit NRC resources could be L

made. In addition, it was agreed that the process should include as much public involvement -

. (e.g. workshops) as possible and that a commitment from the whole industry is essential.

The NRC staff committed to look more closely at the proposed schedule and to discuss this j

project with senior management. NEl committed to (1) schedule a briefing on this subject with t

senior NRC managers, (2) make a formal submittal to the staff after the briefing, and (3) include additional details on the actual implementation effects of the proposal in the formal submittal.

I The group agreed that additional meetings on this subject should be held.

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l Project No. 689 i

Attachments: As stated i

cc w/att: See next page l

DISTRIBUTION

• See attached page Document Name:g:\\sim0828.98 1

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NAME SMagruder:sw FAkstulewicz DATE 9/16/98 9/16/98 9//i/9Y OFFICIAL OFFICE COPY l

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Distribution: Mtg. Summary w/ NEl Re Risk-informed Pilot Project Dated September 17, 1998 l

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Docket File PUBLIC PGEB R/F i

OGC ACRS SMagruder.

i MDrouin EMa11 SCollins/FMiraglia BSheron RZimmerman JRoe DMatthews

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TEssig FAkstulewicz

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SMagruder 1

MRubin RBarrett 3Holahan MCaruso JFlack, RES TKing, RES MDrouin, RES

' MFederline, RES TSu,RES JMonninger, OCM/SAJ JMitchell, EDO i

GTracy, EDO i

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List of Attendees i

Name Oraanization i

Steve Floyd NEl Rick Grantom South Texas Mark McBurnett South Texas Thomas Hook' San Onofre Joe Kowalewski Arkansas Nuclear One

' Bob Christie Performance Technology Millan Straka NUS r

Theresa Sutter SERCH/Bechtel Mark Rubin NRC/NRR Tom Essig NRC/NRR-Stu Magruder -

NRC/NRR John Flack NRC/RES Richard Barrett NRC/NRR Gary Holahan NRC/NRR Tom King NRC/RES ~

Mark Caruso NRC/NRR Mary Drouin NRC/RES i

Margaret Federline NRC/RES

- John Monninger NRC/OCM/SAJ

-l T.M. Su NRC/RES Jocelyn Mitchell NRC/EDO

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RISK-INFORMED, PERFORMANCE-BASED PILOT PROJECT ii l

i August 28,1998 i

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i PILOT PROJECT OBJECTIVE l

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= Incorporate risk and performance-based j

information into the regulatory requirements in an eficient and effective manner i

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.i MEETING OBJECTIVES i

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= Reach consensus on:

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. Proposed plan to achieve project objective

. Key elements for success l

. Project Target Schedule

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l PROPOSED PLAN l

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Eight tasks as per handout

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i KEY ELEMENTS FOR SUCCESS a

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= Recognize that risk insights can add to or reduce current requirements

= Establish dedicated NRC project team with approval authority

. Multi-discipline a

. PRA training

. Management oversight

= Establish accelerated review process i

KEY ELEMENTS FOR SUCCESS

= Phased exemption approach to facilitate h

timely implementation j

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= Rulemaking to allow rest of industry to j

adopt changes l

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PROJECT TARGET SCHEDULE i

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= As per handout j

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GENERAL DISCUSSION,L 'D CONSENSUS TO PROCEED i

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P PROGRAM PLAN OUTLINE FOR RISK-INFORMED. PERFORMANCE-BASED PILOT PROJECT I.

Risk Rank SSCs Under this task, the pilot plants will perform a risk significant ranking of SSCs.

The risk significance determination criteria described in the recently issued i

regulatory guides on graded QA and in service testing will be used to perform the ranking.

II.

Identify Needed Changes to the Regulations The risk and resource rankings completed to date have allowed the pilots to identify a draft set of 10 CFR Part 50 regulations that would need to be changed to make them risk informed, performance based. Under this task, the pilots will review the draft set of 10 CFR Part 50 regulations, review the other pertinent sections of 10 CFR and finalize a set of regulations that will be evaluated under the balance of the project. The changes will be categorized in one of three bins:

A. General changes to 10 CFR Part 50 that affect the scope of applicability of the regulations (e.g., definition of safety related, operational basis event)

B. Specific changes to balance of 10 CFR Part 50 C. Changes to other parts of 10 CFR.

III.

Prioritize Needed Changes to the Regulations Once the regulation that'need change are identified, the next step is to prioritize the changes in terms of cost / benefit and ease of change. The pilots will use the cost information gathered to date to assist in this effort.

IV.

Establish Dedicated NRC Project Team Under this task, the NRC will designate a multi-discipline review / approval team that will be dedicated to the timely completion of this project. The establishment of this team and the project scope should be included in the NRC's PRA Implementation Plan.

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V.

Identify Specific Word Changes to the Regulations

.Under this task, the pilots will work with the NRC dedicated team to reach j

agreement on the specific wording changes needed to make the regulations risk-informed, performance based. The order of work activity should be consistent with the priorities established under Task III.

VI.

Develop Exemptions / Advanced Notice of Proposed Rulemaking The most efficient and expedient way to complete the project is to grant an exemption from the current set of regulations identified under Task III and permit the pilots to adopt the recommended changes identified under Task V under the review of a multi-discipline NRC team. This approach is far preferable to identifying individual regulation changes and pursuing them under the current 10 CFR 60.12 exemption regulation or proposing a revised rule, neither of which is efficient or expedient. To be successful, the current NRC review process will need to be significantly streamlined.

The public and the industry could be appraised of the agency's intent to conduct the pilot through a blanket exemption through an Advanced Notice of Proposed Rulemaking (ANPR). In effect, the pilot projects will be the l

vehicle by which the decision to proceed with a proposed rule change encompassing the scope identified under Task V would be made.

VII. Implement Exemptions The actual changes to plant programs, procedures and hardware will be implemented under this task. A dedicated NRC review team with the authority to make decisions regarding how to implement the revised I

regulations is critical to completing the project in a reasonable time frame.

In effect, the pilot plants and the dedicated NRC team will be reaching agreement on how to implement the revised regulations. The pilot plants will be rewriting the pertinent sections of the Final Safety Analysis Report (FSAR) or preparing safety analyses to describe how the plant will comply with the revised regulations. In turn, the NRC will be rewriting the pertinent sections of the Standard Review Plan. The NRC team will prepare a Safety Evaluation Report that documents the basis for concluding that the i

plant complies with the revised regulation, and provides formal notification i

to the pilot plant that implementation is approved.

4 Because of the large number of proposed changes, the proposed changes to the regulations will be divided among the pilot plants for implementation.

i This will ease the resource burden on both the pilot plants and the NRC L

team.

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l Where practical and appropriate to do so, performance measures will be established to determine if there is any unintended impact on risk significant SSCs performance.

VIII. Prepare Petition for Rulemaking and Associated Regulatory Guides i

The results of the pilot applications will be used to prepare a petition for rulemaking to change the regulations for the balance of the industry.

Insights, lessons-learned and actual performance results will be used as the i

basis for the regulatory analysis justifying the rule changes.

The experience gained in implementing the pilot implementation and the agreements reached between the pilots and the NRC team should permit i

timely preparation of regulatory guides / and or industry implementation guidance for consideration under the proposed rule process.

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r' TARGET DATES FOR RIS.K-INFORMED. PERFORMANCE-BASED PILOT PROJECT Task I-Risk Ranking i

South Texas Project 9/30/98 San Onofre 10/31/98 Arkansas Nuclear One 4/1/99 i

i Task II-Identify Changes to Regulations Bin A 9/30/98 Bin B 10/30/98 Bin C 10/30/98 i

Task III-Prioritize Changes to Regulations Bin A Complete Bin B 11/30/98 Bin C 1/31/99 Task IV - Establish NRC Proiect Team Establish team and update PltA Implementation Plan 9/30/98 Task V-Identify Specific Word Changes to Rerulations Bin A 10/31/98 Bin B 12/31/98 Bin C 3/31/99 Task VI-Develoo Exemptions /ANPR Bin A 11/30/98 Bin B 1/31/99 to 6/30/99 4

Bin C 4/30/99 to 9/30/99 ANPR 12/31/98-l Task VII -Implement Exemptions Bin A 1/99 to 6/99 Bin B 4/99 to 9/99 Bin C 6/99 to 12/99

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Task VIII-Petition for Rulemaking Bin A January 2000 Bin B September 2000 Bin C December 2000

DRAFT

" ROAD MAP" FOR TRANSFORMING CURRENT REGULATIONS TO A RISK-INFORMED, PERFORMANCE-BASED REGULATION APPROACH RECOMMENDED FIX 10 CFR SUBJEcr PROBLEMATIC IANGUAGE REGULATION Add a new item 50.12 (2) (vii) that 50.12 Specific 10 CFR 50.12(2), special circumstances, exemptions does not include provisions for considering would allow exemptions for requirements, shown on the basis of risk and operating experience.

risk insights and operating experience, to be oflow safety value.

50.36 Technical 10 CFR 50.36(b) requires that tech specs Revise 10 CFR 50.36 (b) to allow specifications be derived from the safety analyses tech specs to be based on risk contained in the FSAR. FSAR safety insights and operating experience.

analyses are deterministic.

50.44 Combustible gas 10 CFR 50.44(a)(3)(ii) requires all reactors Revise 50.44 to require hydrogen control that rely on purge systems to control recombiners only if hydrogen concentration based on the hydrogen install hydrogen recombiners, irrespective of the containment volume percentage of oxidized cladding and the likelihood for having an explosive exceeds 50% of the explosive limit.

concentration of hydrogen.

DenBe LUunm.m _ ortInmys 50.46 ECCS 10 CFR 50.46 (a) (1) (i) pipe briak $UdNpentrudbaised d(

10 CFR 50.4G(c) defines a LOCA as a risk irisighth sifd hieratiligi' M + 3 break in pipes in the RCS pressure sxperienc61)QiddMN:

boundary up to and including a break 44g*ip M [%W>+

l equivalent in size to the double-ended

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rupture of the largest pipe in the RCS.

10 CFR 50.47( c)(2) generally establishes Define exposure and ingestion 50.47 Emergency planning an exposure pathway EPZ of 10 miles and pathway EPZs in terms of a realistic source term, site demography and an ingestion pathway EPZ of 50 miles.

the safety goals.

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s DRAFT 10 CFR SUBJECT PROBLEMATIC LANGUAGE RECOMMENDED FIX REGULATION 50.49 Environmental 10 CFR 50.49(b)- Regulation applies to

Rhideli b if.

una g g qualification equipment that is important to safety as importAnt tolsafetyi.666Eistent'withj defined in 10 CFR 50.49 (b)(1) and (2).

strueturbr@em$componen}tb 's10 CF Definitions are based on deterministic, design basis events.

which opeEatins ex$erience ord's1.

i eq probabilistic risk assessment ha

~ hown to be sianhntjo pnblict s

health and safety.""

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50.54 Conditions of 10 CFR 50.54(a)(3) requires prior NRC Limit scope to those commitments Licenses approval to reduce commitments in the related to the performance of risk-l QA plan.

significant SSCs.

50.55a Codes and 10 CFR 50.55a (a)(1) requires SSCs to be Defud es,..y.

J Standards tested and inspected commensurate with with 10 CFR150.36;(c)(23(w)~(D)fA i ii importance of the safety functions to be

' structure; systeni of componsntlip > ;

performed.

which'opbrating expsilense ordjik #

i probabilistic'riskilssdssinehthSNI '

'shown to b6 kignidesht'to public$ 1 health had iiafet#M$49 ' MF8 50.55a Codes and 10 CFR 50.55a (f)(1) requires in-service Re-define safetf4 elated sinds WJ Standards testing for safety-related pumps and importantitd safety doiisisterft withi 2 i

valves.

structure, system or bompone(ntim1,0 i

t which operating expsfier~ ice or '

i probabilistic risk assessment has; shown to be significant to public health and safety."

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DRAFT 10 CFR SUBJECT PROBLEMATIC LANGUAGE RECOMMENDED FIX REGULATION 50.55a Codes and 10 CFR 50.55a (f)(4)(i) and (4)(ii) requires PE 4

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nf dkSt Standards code testing of pumps and valves required Msired foEL ~

for safety be conducted in accordance with fl,0 C_FR 5d3. 6

}ksepI32 we the latest edition of the ASME code.

structure,"

"ofdbanponesitMd?

Mbich operatinkjnqisilesisordy$is probabilistic Eisk asseseshesihed slioirn t6 M@nHliminitifpfabhii!

. health!sndiAnds3MMMsMM[i 4;

50.55a Codes and 10 CFR 50.55a(g)(1) and (2) requires Reglefins W.fslated$btleistittgG with4d CFRW.M(6)(2)(li)(D)igh@

"kl Standards inservice examination of safety-related

• hicli operas @i aslbleslee sMurelp ssitt$0iseh components in accordance with latest addenda of ASME code.

e2 probabilistic"rls essMisIt5diEN l

shown%lbi&Mient'th pubNed"'

health and safeth"'

""i 50.59 Changes, tests 10 CFR 50.59 (a)(1) focuses on changes as Revise 50.59 (a)(1) to change the and described in the safety analysis report.

scope consistent with 10 CFR 50.36 experiments (c)(2)(ii)(D) "A structure, system or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety."

50.59 Changes, tests 10 CFR 50.59 (a)(2) provides criteria for Define risk-informed thresholds for and determining if a change is an unreviewed determining if a change is an experiments safety question. The criteria is not risk-unreviewed safety question.

informed.

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DRAFT 10 CFR SUBJECT

! PROBLEMATIC LANGUAGE RECOMMENDED FIX REGULATION 50.59 Changes, tests 10 CFR 50.59 (c) references facility as Revise paragraph (c) consistent with I

and described in safety analysis report.

paragraph (a)(1).

experiments 50.65 Requirementa 10 CFR 50.65 (3)(b) defines the scope of Revise 50.65(3)(b) to change the i

for monitoring the maintenance rule. The scope is not scope consistent with 10 CFR 50.36 the effectiveness risk-informed.

(c)(2)(ii)(D) "A structure, system or of maintenance component which operating at nucicar experience or probabilistic risk power plants assessment has shown to be significant to public health and safety."

i 50.72 Immediate 10 CFR 50.72 (b)(1)(ii), (iii) and (vi)

! Define. _~ _ _

.- _ -u g notification requires one-hour reporting of conditions CFit 80.Wf(e}Wd)(D)"A69

.with 10.dispeihitiF-ffisf3%

requirements that pose an actual threat to safety.

shinettar which opsratkA%'6h$!

probabilistIEtbke46esenlehih sh shown toWeigniffeiint tsSGbNe@N r

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health and safety."dM@dt 4MW 50.72 Immediate 10 CFR 50.72(b)(2)(i) requires four hour Defins sigdifienht comptodklee to9nb notification reporting of events that significantly

'ssfety considenstWifth 16_CFR 50%

requirements compromise plant safety (c)fD(ii)(D)Metracturelaystem bi6 conipodentwhich*dhieinding% 3D experience orptobabilistic ritk%[

assessmesiliiiishosirn td b&i [N i

significant $6MabNe heilth andI safety."

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10 CFR SUBJECT PROBLEMATIC LANGUAGE RECOMMENDED FIX l

REGULATION 50.72 Immediate 10 CFR 50.72 (b)(2)(iii) requires a four Dsftne safety---

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T notification hour report for any condition that could with 10 CFR'6D.3s (chs)'(iD(D)"A$

requirements have prevented the fulfillment of a safety structure,[systsm oYeom$bdent%W which operatiE[eid$ilsrMi ohy@

function.

probabilislic risk isdissdNil hasn@t

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shown to be slasl5fe t t8psblid(&

n health and safety."5N4slMi Define sigtiiscant-edrhpMinihe tor 50.73 Licensee event 10 CFR 50.73(a)(2)(ii) requires a written

' safety condistSdtstilh'10 UFR 50b report system report for events that significantly

( c)(2)(ii)(D);"Ast' Eitud,(shtend 'did-compromise plant safety r

componentshhhMrilingJikM,

'dxperiencefBE $50bsbilidtic) lab}NF assesementlidd sh6khis be!n @

significarit th pubiid beAlth[$Nd f((f safety."NGMdeenTY)ME ' ;W 50.73 Licensee event 10 CFR 50.73 (a)(2)(iii) and (x) requires a Define threst to safetyconsistenti report system written report of conditions that pose an with 10 CFR 56.38 (b)(2)(ii)(D)"kj actual threat to safety.

structure,'systs'didr^eombdnenthfs -

which opeistliik espefisnes or ff d '

probabilistic risk'NEEsirisbdt has%p

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shown to be sisnifi6snt t6 public i health and safety $#0E 'M l

50.73 Licensee event 10 CFR 50.73 (a)(2)(v) requires a written Define safety furiction consistent $

with 10 CFR 50.36,icomponenti #y *

(c)(2)(ii)(D)"A report system report for any condition that could have structure, syshni b prevented the fulfillment of a safety function.

which operriting eilpesience or; i

probabilistic risk assessment has' _

I shown to be significant to public health and safety."

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DRAFT

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10 CFR SUBJECT PROBLEMATIC LANGUAGE RECOMMENDED FIX REGULATION GDC1 Quality Requires that SSCs important to safety be Defids1-pouam,w yt Mp d standards and designed, fabricated, erected and tested to consistentMthiiO;CFR 60[$0iliths records quality standards commensurate with (c)(2)(ii)(U)'"# structure;isysteni or@

safety importance of functions to be component $h$cEMNtl6Mijn" gg '

performed.

experienc'e'bEpkbil$ilislIc risk 9Es-:

'aMasment his~sho#n fdbeh@fifh signifiennt to phbli$ bealth asd

' safety."MiPdntdM@dsjnh 9 5 M GDC2 Design bases fi,r Requires that SSCs important to safety be Define iniportantib mafetfiesr:ph protection designed to withstand the effects of consistent wib1D dFR'50.86Ni;Id$,

against natural natural phenomena.

(c)(2)(ii)(D)$"#strUhtinidj ptnANI phenomena component $li$ckJ6uatini experiencejdhSobhbil$sticr$n Atri

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sk[kphj assessaient h&s'shbWn 46 tieWWfu vignificarit:ts bdlis hedlih'addQW safety."' * $M SNd$hM'[ 2 UN s

GDC3 Fire protection Requires that SSCs important to rafety be Define importarit t6 safety @ na designed and located to minimizr; the c6risistent with30lCFit 50.36 Lefil probability and effect of fires and

'.(c)(2)(ii)(D)!'Eithiettare2sistein(dN s

explosions.

component whiEh $persting!yijP'l.

experienw br$robbliallhtic risk s

assessment hidshown td b'e -

f significant to public health and ' ;

safety."

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DRAFT 10 CFR SUBJECT PROBLEMATIC LANGUAGE RECOMMENDED FIX REGULATION GDC4 Environmental Requires that SSCs important Esafety Define ifnigantichygg app:4 and dynamic be designed to be compatible with the consistent with 10 CFR 60.36hW s.

effects design effects associated with normal operation (c)(2)(ii)(D) filhiihtdre/ sjstAinTE bases and postulated accidents, including componentMhi6h opridngi A.~

U; LOCA.

experiened 65$rbbabilistic risk 4$

assessmenf,lias sho#d to 65 W4 i significani; ki giublid health hiidl @ '

safety."

6 % djyf $ 1 R jy;y SlMiij Define LOCAli.te$4!M5M@

rnisstilii619QM pipe breakiizd ApectruMbdssd onji riskinsighUfahd# rating? 04?

experienceREW db v d A -

GDC5 Sharing of SSCs Requires that SSCs important to safety Define importent te 6afety h;c m' consistent With'10, hts'iWTsystein$E.5 5 CFR 50.367..

not be shared among nuclear units unless (c)(2)(ii)(Dif1stru such sharing can be shown to not impair safety functions.

component 41Eich obdratingM ff '

experience or pinbabilistis risk ; W assessment has shoNn to be W D significant to public health alid.

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safety."

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,r DRAFT 10 CFR SUBJECT PROBLEMATIC LANGUAGE RECOMMENDED FIX REGULATION GDC 13 Instrumentation Requires that instrumentation be Define'adMo.w;sa-.y wo.wust and control provided to monitor variables during

kith 10 CFR 5036/6)(2)(il)(D)iAY '

normal operation, anticipated occurrences ststicture,?Natsist sr comWnent$

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and accident conditions to assure

.which opnatsikdhs'rlsnee orl IF{,

I robabilistid jlik assEshidbNt hakb?

adequate safety.

i shown to be;significa' t 16 publicM n

health and.' safety &; g&:'R cg@Y b

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.,h GDC 16 Containment Requires that containment design

' Define important t6safeth @3#l.

consist 4ntwitli'iOMFn5036ii b design conditions important to safety are not exceeded during postulated accident

.(c)(2)(ii)(DNKMrueld$systeMd, componeht which bifEntin$;i conditions.

M experienes 6r proba6ilistic risk assessment has shown to be? /

'significant td phblic heallh'and$iT safety."N; jd 1 ' J

'i a, M kgRNip.

G GDC 17 Electric power Requires that onsite and offsite electrical Define importarit to safety;

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systems systems be provided to permit functioning consistent withii0 CFR 5046ffe!-

of SSCs important to safety.

.(c)(2)(ii)(D)"A structitrs/iy' tem oO '

s osnponent which operatingi "

experience or psdbabillitic risM assessment has showh td 6el o :

significant to publid health anh '

safety."

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,c, DRAFT 10 CFR SUBJECT PROBLEMATIC LANGUAGE RECOMMENDED FIx REGULATION GDC 17 Electric power Requires that one circuit be available Change to be available within a time systems within a few seconds following a LOCA.

sufficient to maintain functions important to safety for likely pipe break spectrums.

GDC 18 Inspection and Requires that electric power systems De6ne: impede 11t hum.y mour M testing of important to safety be designed to permit hnportant featur68)oiisisterii th(

electric power periodic inspection and testing of 10 CFR 56.36;(c)(2)(ii)(D)fAMgjiiM i

~ tructure,;sysissili or coMpo$eiih iM:

systems important areas and features.

s which opekatiskespefiehes'6i%2ri.

~probabilistidilsk nessessASt hAdh p shown to be'Alinificant*t6 h0blic%U health'andisafetyalible pyM

+ g@f p%pMyrg.4%

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Define LOCAiriterta's of a likelf pipe break &lsiifshnetiiini based dN@

GDC 19 Control room Requires that control room be operable and habitable under LOCA conditions.

risk insights add obeFatins:i mW

'xpeHdnes.EITY!M @itMdi!IE e

Define impdttant to safety K @ib GDC 20 Protection Requires that the protection system be consistent nidivid:CFR 5d.l36 Tf3?p

• system desis;ned to sense accident conditions and "A ntdctifreisystenforX

.(c)(2)(ii)(D)OhIchlbheratingQh functions initinte operation of systems important to coml onent safety.

i experience or probabilistic risk - ;;

assessment has shbwn t6 bev+/

significant to public health ~ arid! ~ '

safety."

o

DRAFT i

10 CFR SUBJECT PROBLEMATIC LANGUAGE RECOMMENDED FIx REGULATION GDC 30 Quality of Requires that components part of the

.R@dhe to L--

_ _.s m.as d

reactor coolant reactor coolant pressure boundary be importance tdbafetpN$$ND pressure designed, fabricated, erected and tested to

~ 4 jijk

((Mkh ~f boundary the highest standards practical.

4 1 M i e S & f3i f A GDC 35 Emergency core Requires a system to transfer heat from Define LOCA is tenniof k likely&<

t cooling the core following any loss of coolant pipe break s$sipfebthhn bassd odFM accident...

riskInsightN NIidl@NitQd{f@@j isp' dsnoeNfMO!:i$i$iMN$7N e

GDC 38 Containment Requires a system to rapidly reduce Define LOCAis tesina:dff ikel pipe break slN'W1bdied~yj E a heat removal containment pressure and temperature d~ f following any LOCA srisk Insightslillid $i6rstnibi$ayi experiericesMJSi$$5MTf9#Ii GDC 44 Cooling water Requires a system to transfer heat from

. Define importaht td safetya AtM -

SSCs important to safety to the ultimate sonsiste'ntMtN[iddMM.N$$ d (c)(2)'ii)(Dj.dkidr06Eli@hthidin?N Os heat sink.

(

componestyliibh experledes dr $$6@hbilist3d Nait MI r

assessmedk has shodnMhif $ ?

siirnificant E6TNblIblftehhlNhd Eafetp."

hh![,5)f Q k i y

e.2+-2. g pggg gggtg GDC46 Testing of Requires system to be designed such that Define LOCA id.tersis.6f a~ likely#.

cooling water testing at conditions as close as possible to pipe bfehk sizh speckEdtdEdssd ddN system the design conditions, including LOCA, risk insights Shd opelrdiinM

. l < /

can be performed.

experience!-WM S ; P V 2

GDC 50 Containment Requires containment and associated Defina LOCA is terms of a likely :

design basis systems to be capable of maintaining pipe break size spectrum based ori-containment integrity for any LOCAs risk insights and operating experience.

i 10 t

l

DRAFT 10 CFR SUBJECT PROBLEMATIC LANGUAGE RECOMMENDED FIx REGULATION GDC 54 Piping systems Requires piping systems that penetrate Define'imtWi!WiTfit,te;safb5Q q;L consistent withjl0; dure, system oECFR penetrating containment to have various capabilities (c)(2)(ii)(D)fA stru containment that reflect the importance to safety of isolating these niping systems.

componestkhichdiefatibg'p jfS <

experience or piobAbilistic riskui e assessment had sh84h to neh 6 significant to pnh14jiealth andv4 safety." t%w$M$,jtn?e, W

P um awwm GDC 55 Reactor coolant Requires that other requirements not Define adequate safetysconsistente

,with 10 CFR 50.36 (c)(2)(ii)(D)f ' i '

,Af pressure specifically identified in the GDC to structure, systini'dEsinl onen

~

i boundary minimize the probability or consequences penetrating of accidental rupture of these lines be whichoperatinibMri6nixi6s V containment provided as necessary to assure adequate probabilistic fisk assessnient has n safety.

shown to be sigtiifihitnt t0 p6bliO[I health and safety."g!) lp*.

• Bk: 4 W Q4 Y l

GDCG1 Fuel storage Requires that fuel storage and handling Define important t6)dfetyqq and handling systems be designed with a residual heat consistent witlil10 CFR 50.364 L

and removal capability having reliability and (c)(2)(ii)(D) "A strudure, systsm or'

'3 radioactivity testability that reflects the importance to component which dyerdtliign control safety of decay heat and residual heat experience or probabilistic risk ~

rc moval.

assessment has shdwn to be

~,

2 significant to public health ahd

[

3 safety."

I i

11

. ;~ 3 DRAFT 10 CFR SUBJECT PROBLEMATIC LANGUAGE RECOMMENDED FIx REGUIATION Appendix B -

Quality States that Appendix B applies to all Rs-defiHE

-y-..

g with 10 CFR 50.36 (c)(2)(ii)(D)!Kp(

Introduction assurance activities affecting safety-related SSCs.

structure, syhtsitt'o'r comp 6nestMG ljy which opefatidgexperiends @hMd%j probabilisticiisk' assessment i

shown to be ainl%nt t6phbildNil health and adfeth." fin"M$dddddh Appendix B -

Organization Requires that the authority and duties of Re-define safety-related ci6ssistedt5

. ith 10 Cs2 60.5s {c)($)(iij(D) *Atr shich operstinfexprisace Criterion I persons and organization performing w

strticturs,"nyiskdbbthpodsuts activities affecting the safety-related functions of SSCs be clearly ecablished i

and delineated in writing.

probabilistic risk asbeenmeist hadj @jg shows to befsignificniit tiiOitbliEj!!!ib l

health"and adfety."E. e MriM#s/

c Define,importance to safety,5; :

Appendix B -

Quality Requires that the QA program provide consistent withi10 CFR 50.34@;gfl Criterion II Assurance controls over activities affecting the Program quality of SSCs to an extent consistent (c)(2)(ii)(D) *A AGuchdreTaystem edhe with their importance to safety.

componenthhich 06eratinMgpff$

experience or probabilishd riskM assessment haA'shown to beis!.C significant kpublid health add 2 Q safety." '

6

~ a: '.

i n

k 12 l

.C s

DRAFT

~

10 CFR SUBJECT PROBLEMATIC LANGUAGE RECOMMENDED FIx REGULATION Appendix B -

Design Control Requires that measures be established for ire-definefami-relawa-m mg3 Criterion III the selection and review for suitability of

.with 10 CFR'50.36] e)(2)(ii)(Dj "AJ i application of materials. Parts, stincture/ 5yhtdsoE e6mpo+1 nt5)E

• equipment, and processes that are which operalisg exp4rienedord $

. essential to the safety-related functions of probabilisde risk Essshsnient" Nad $ 3 the SSCs.

shown to be signifidant tu pitblicM 4 f

health and^safetyi"WSd@%, 'A Appendix B -

Corrective Requires that the cause of significant Define a significant codditiod e,!M Criterion Actions conditions adverse to quality be consistent withi10_CFR 50.36i4]F (c)(2)(ii)(D)"A2Nrisettde tpstenE.6rk n

'componentMhictioperst{ihsq3

[h XVI determined and corrective action to preclude repetition be identified and documented.

experience of hiobabilislic rihkW W assessment hai showd to beic E*

significant to jiiblic hEnish dnd 1 safety."

Appendix E Emergency Appendix E generally establishes an Define exposure and ingestion Planning and exposure pathway EPZ of 10 miles and an pathway EPZs in terms of a realistic Preparedness ingestion pathway EPZ of 50 miles.

source term, site demography and the safety goals.

Appendix K ECCS Appendix K (c)(1) requires LOCA analyses :Dsfine LdCAiRL-s or a nuelyd Evaluation to include instantaneous double ended pipe break sizu spehtrtim based ont Models guillotine and longitudinal breaks of the risk insights and operating -

largest diameter reactor coolant pipe.

experience.

13

2o DRAFT 10 CFR SUBJECT PROBLEMATIC LANGUAGE RECOMMENDED FIX REGULATION ivenseBh m $ddelhM6 % ^h' g Appendix R Fire protection This regulation makes extensive use of

- ewm ---- ;

iCFR50.36(s)}(2)(if)

$] system'orMhi$0nd& W sdfety-related the terms "important to safety" and

" safety-related" to define the scope of equipment to which this regulation opiratiAsbith6tidelidlinE kk risk assessaiedtilsiisinho$iub i applies.

WhitsbiiNT

'significanftdpubleHWalthEST Fj

• f w% " d l0 N,dl n% %_ : h~

n Defineimp6tt&nttidsafMbQQg i

Appendix S Earthquake This regulation applies to plants licensed corisis6ntiithii6:DFittio.[8694 }?

engineering after 1/10/97. It requires that SSCs criteria for important to safety be able to withstand (c)(2)(ii)(D)"fetindMathEs)ht$d i

nuclear power the effects of earthquakes without loss of compoeiithhich OherstInidQ O@Q plauts safety function.

stperissce'bf hrb6h6ilisiAE ink $$$:

ssnessinedt h'aisish6dn th biU60%

sigHificant t6 gisblic hsaithindi:NE,

safety." &

h]? =' % p + W 4c -

Rules that could be changed by changing the scope to which the rule applies by defining terms such as g

"important to safety, safety-related, significant to safety, ete" in 10 CFR 50.2 without having to change the wording of the affected regulation.

14

- C-1 o

Nuclear Energy institute Project No. 689 cc: Mr. Ralph Beedle Ms. Lynnette Hendricks, Director Senior Vice President Plant Support E

and Chief Muclear Officer Nuclear Energy Institute Nuclear Energy Institute-Suite 400 Suite 400 1776 i Street, NW 1776 l Street, NW Washington, DC 20006-3708 Washington, DC 20006-3708

' Mr. Alex Marion, Director Programs Nuclear Energy Institute i

Suite 400 1776 l Street, NW Washington, DC 20006-3708 Mr. David Modeen, Director Engineering Nuclear Energy Institute Suite 400

- 1776 l Street, NW Washington, DC 20006-3708 Mr. Anthony Pietrangelo, Director Licensing 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 Mr. Jim Davis, Director i

Operations

. Nuclear Energy Institute Suite 400 1776 l Street, NW Washington, DC 20006-3708 2

2 1

S i

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