ML20153H326
| ML20153H326 | |
| Person / Time | |
|---|---|
| Issue date: | 09/29/1998 |
| From: | Stewart Magruder NRC (Affiliation Not Assigned) |
| To: | Essig T NRC (Affiliation Not Assigned) |
| References | |
| NUDOCS 9810020009 | |
| Download: ML20153H326 (8) | |
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION 2
WASHINGTON, D.C. 20666-0001 49 +....
September 29, 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 ML Generic Issues and Environmental Projects Branch Division of Reactor Program Management Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF MEETING HELD ON SEPTEMBER 15,1998, WITH NEl TO DISCUSS RISK-INFORMED, PERFORMANCE-BASED PILOT PROJECT On September 15,1998, 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 continue discussions from a meeting on the same subject held on August 28,1998, and to provide a forum to discuss NEl's answers to 11 questions that had been faxed to them a few days before the September 15,1998, meeting. Attachment i lists the meeting participants. Attachment 2 is a copy of the 11 questions faxed to NEl before the meeting.
In response to question 1, the NEl representatives stated that their highest priority rule changes are a few " definition" changes that would affect many rules. Examples of these are changes to the definition of the terms " safety-related" and "important to safety" to make them consistent with 10 CFR 50.36(c)(2)(ii)(D).
In response to question 2, the NEl representatives stated that current rulemakings that are well
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along in the process should not be subsumed into this effort. They specifically mentioned efforts regarding the maintenance rule,10 CFR 50.55(a), inservice inspection, and 10 CFR
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50.59 that should be continued.
In response to question 3, the NEl representatives s,iated that even though two of the pilot plants are Combustion Engineering plants, all three utilities are very interested in continuing with the project.
In response to question 4, the NEl representatives stated that the risk metrics and the criteria of RG 1.174 will be used. They noted that the plants are using realistic importance measures and that cost-benefit analyses will also be considered.
In response to question 5, the NEl representatives stated that they intend to focus on core damage and large early release frequency and not health effect risks.
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T. Essig
-2 September 29, 1998 in response to question 6, the NEl representatives stated that they intend to meet all of the suggested objectives (i.e. improve safety, make regulations more effective and efficient, and clarify requirements.)
In response to question 7, the NEl representatives stated that their focus is not on changing the design bases of the plant or on physical changes to the plant. The stated that the pilots will help define what changes make sense in terms of risk and that they will perform a step by step evaluation of the design bases.
The NRC staff noted that instead of changing the general design criteria and major regulations in 10 CFR Part 50, maybe a process rule is a better approach for affecting design requirements. The staff proposed that a rule be developed that would set criteria for changing requirements on a plant-specific basis. The idea would be to focus on operations and not on design requirements.
In further discussion of question 7, the NEl representatives stated that they intend to make the loss of coolant accident break size more realistic and that other design basis accidents may also be revised. They also stated that analysis assumptions and methods will probably be revised.
In response to questions 8 and 9, the NEl representatives stated that they may suggest adding a risk-informed condition to the list contained in 10 CFR 50.12. They also discussed using a conditional exemption that would be contingent on a safety evaluation report.
In response to question 10, the NEl representatives stated that they intend to carefully monitor the pilots and use them pilots to determine which ideas work and which ones don't.
In response to question 11, the NEl representatives stated that plants would submit updates to their final safety analysis reports as required. They also stated that not all plants may be willing to adopt the propos'ed changes; particularly those five to seven years from the end of their license.
The NRC staff next handed out a proposed schedule for forwarding options on Part 50 rulemaking to the Commission. This is provided as Attachment 3. The staff noted that their objective is to have an options paper to the Commission by mid-November. The NEl representatives agreed with this objective and committed to meet with the staff as required to support the schedule.
Project No. 689 Attachments: As stated cc w/atts: See next page DISTRBUTION: See attached page Document Name:g:\\simi\\msum0915.98 *See Previous ncyrrence QCfGk' OFFICE PGEB BC:RES/PRAB NAME SMagrudN MCunningham*
htu7ewicz
/9fj/98 DATE 9/@/98 9/28/98 OFFICIAL OFFICE COPY
T. Essig 2
September 29, 1998 in response to question 6, the NEl representatives stated that they intend to meet all of the suggested objectives (i.e. improve safety, make regulations more effective and efficient, and clari'y requirements.)
In response to question 7, the NEl representatives stated that their focus is not on changing the design bases of the plant or on physical changes to the plant. The stated that the pilots will help define what changes make sense in terms of risk and that they will perform a step by step evaluation of the design bases.
The NRC staff noted that instead of changing the general design criteria and major regulations in 10 CFR Part 50, maybe a process rule is a better approach for affecting design requirements. The staff proposed that a rule be developed that would set criteria for changing requirements on a plant-specific basis. The idea would be to focus on operations and not on design requirements.
In further discussion of question 7, the NEl representatives stated that they intend to make the loss of coolant accident break size more realistic and that other design basis accidents may also be revised. They also stated that analysis assumptions and methods will probably be revised.
In response to questions 8 and 9, the NEl representatives stated that they may suggest adding a risk-informed condition to the list contained in 10 CFR 50.12. They also discussed using a conditional exemption that would be contingent on a safety evaluation report.
in response to question 10, the NEl representatives stated that they intend to carefully monitor the pilots and use them pilots to determine which ideas work and which ones don't.
In response to question 11, the NEl representatives stated that plants would submit updates to their final safety analysis reports as required. They also stated that not all plants may be willing to adopt the proposed changes; partice 9 those five to seven years from the end of their license.
The NRC staff next handed out a proposed schedule for forwarding options on Part 50 rulemaking to the Commission. This is provided as Attachment 3. The staff noted that their objective is to have an options paper to the Commission by mid-November. The NEl representatives agreed with this objective and committed to meet with the staff as required to support the schedule.
Project No. 689 Attachments: As stated cc w/atts: See next page L
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Distribution: Mtg. Summary w/ NEl Re Risk-informed Pilot Project Dated September 29, 1998 Hard Coov Docket File
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PGEB R/F OGC ACRS SMagruder TKing M
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SCollins/FMiraglia BSheron RZimmerman JRoe DMatthews TEssig FAkstulewicz SMagruder MRubin RBarrett GHolahan MCaruso EMcKenna JFlack, RES TK!ng, RES MCenningham, RES JMitchell, EDO GTracy. EDO JSorense.1, ACRS NDudley, ACRS MMarkley, ACRS l
I t
i s
e NEl/NRC RISK-INFORMED PART 50 9/15/98 List of Attendees Name Oraanization Steve Floyd NEl Tony Pietrangelo NEl Biff Bradley NEl
. Lynne Neal NEl Rick Grantom South Texas Mark McBurnett South Texas Steve Rosen South Texas Glen Schinzel South Texas Steve Thomas South Texas Bob Christie Performance Technology Jerry Dozier NUS Theresa Sutter SERCH/Bechtel Jenny Weil McGraw-Hill Mark Rubin NRC/NRR Eileen McKenna NRC/NRR Stu Magruder NRC/NRR Richard Barrett NRC/NRR Gary Holahan NRC/NRR Mark Caruso NRC/NRR Tom King NRC/RES Mark Cunningham NRC/RES Jack Sorensen NRC/ACRS Noel Dudley NRC/ACRS Jocelyn Mitchell NRC/EDO 9
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QUESTIONS ON NEl WHOLE PLANT STUDY PROPOSAL 1.
What are the highest priority rule changes desired? Can a few selected areas be the focus of the study?
4 2.
Relationship of NEl proposal to other NEl petitions for rulemaking and ongoing staff work to improve Part 50. Should they be subsumed in the whole plant study?
50.59 50.54a - NEl Petition on OA rule others?
3.
Do we need 3 pilots, or is 2 sufficient?
4.
How will risk-information be used in the study? What are the metrics and criteria? How are o;her facters (such as described in R.G.1.174) considered in an integrated fashion?
5.
When the NEl definition of " safety-related" refers to "significant to public health and safety," does this mean health effects (i.e. PRA Level 3) onl/ or would it address core damage and large release?
6.
What are the objectives of any proposed rule changes:
improved safety?
remove unnecessary burden?
provide more flexibility to licensee (i.e., performance-oriented rules)?
7.
Need to better understand intent of rule changes:
how much of a change to the design basis, or only changing operational characteristics and pedigree of SSCs?
will LOCA be eliminated or just revised?
will other DBAs be revised fo-nperational analysis purposes?
will analysis assumptions / methods be modified?
will acceptance criteria be modified?
8.
hhat information will be developed and supplied to support exemption requests?
9.
What will be the basis for exemptions (i.o., 7 hat are the special circumstances)?
10.
What are the criteria that would have to be met to s' ow that permaneat rule changes h
are worth making?
11.
Upon completion of the generic rulemaking, would all plants have to submit a revised FSAR (including a PRA) for NRC approval?
Attachmnt 2
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Part 50 Rulemaking l
Proposed Schedule 09/18/98 Formulate objectives of risk informed regulations based on:
existing NRC policy on risk-informed, performance-based regulation NRC strategic plan concerns raised by representatives of the public and the nuclear industry.
09/23/98 Develop preliminary approaches (options) for achieving the objectives set forth.'
09/24/98 ACRS subcommittee meeting:
discuss objectives and approaches for rule changes; announce public meeting for further discussion of potential rule changes.
09/30/98 EDO signs out memorandum to Commission describing rutomaking plan and amending response to tasking memorandum.
10/01/98 Discuss potential rule changes with NRC PRA steering committee.
mid-Oct Conduct public meeting (s) to discuss potential rule changes.2.
11/1/98 Complete draft Commission paper on options for rulemaking:
objectives options for achieving objectives assessment of options regarding effectiveness and efficibncy 90 day public comment period.
11/15/98 EDO signs out Commission paper with options for rulemaking.
l 12/03/98 ACRS review 12/15/98 Staff requirements memorandum (SRM) received.
D R A Mc.m l
' Preferred approach is to mutually agree on plan and options for rulemaking.
8 Multiple meetings may be needed to reach agreement on definition of options.
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4 Nuclear Energy Institute Project No. 689 cc:
Mr. Ralph Beedle Ms. Lynnette Hendricks, Director Senior Vice President Plant Support and Chief Nuclear Officer Nuclear Energy Institute Nuclear Energy Institute Suite 400 Suite 400 1776 l Street, NW 1776 i Street, NW Washington, DC 20006-3708 Washington, DC 20006-3708 Mr. Alex Marion, Director Programs Nuclear Energy institute Suite 400 1776 l Street, NW Washington, DC 20006-3708 Mr. David Modeen, Director Engineering Nuclear Energy Institute Suite 400 1776 i 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 i
Mr. Jim Davis, Director Operations Nuclear Energy Institute Suite 400 1776 l Street, NW Washington, DC 20006-3708
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