ML20196B941
| ML20196B941 | |
| Person / Time | |
|---|---|
| Issue date: | 12/01/1988 |
| From: | Varga S Office of Nuclear Reactor Regulation |
| To: | Rossi C Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8812070100 | |
| Download: ML20196B941 (4) | |
Text
,-_____
'4 umTED STATES I
wr
,i NUCLEAR REGULATORY COMMIS810N wAsmwoTon, o. c. roses December 1, 1988 MEMORANDUM FOR:
Charles E. Rossi, Director Division of Operational Events Assessment Office of Nuclear Reactor Regulation FROM:
Steven A. Varga Director Division of Reactor Projects I/I!
Office of Nuclear Reactor Regulation
SUBJECT:
COMMENTS ON NUMARC/NSAC 10 CFR 50.59 GUIDANCE DOCUMENT In response to your request by memorandum dated November 17. 1988, we have completed our review of the sub.fect guidance document and offer the general coments addressed below.
We find the guidance provided in the final draft of NSAC-125, dated December 1988 to be seriously flawed and quite likely inconsistent with the provistor.s of 10 CFR 50.59.
It practically ignores the guidance provided in your letter of May 12,1988.
For example, NSAC-125 asserts that in detemining that a proposed change involves no unreviewed safety question with respect to the reduction of margins criterion, the analyses need onl acceptance criteria of the Standard Review Plan (SRP)y show that the are satisfied. This is inconsistent with the staff's long standing position that if a proposed change causes a change in a safety parameter, e.g., containment pressure, in the l
direction of the acceptance criterion in the SRP, then we are dealing with a reduction in margin and, therefore, an unreviewed safety question. Changes in j
the opposite direction do not involve an unreviewed safety question.
l Another example deals with whether there is an increase in consequences of i
accidents or malfunctions of equipment when determining whether a proposed l
change involves an unreviewed safety question. NSAC-125 asserts that proposed changes which cause a plant's design basis LOCA dose to increase from 200 Rem l
(thyroid) to 250 Rem (thyroid) would not involve an unreviewed safety question l
because the 10 CFR 100 guideline cf 300 Pem (thyroid) has not been violated.
This is clearly inconsistent with the staff's definition cf an increase in consequence of accidents.
NLeerous other examples of why we consider NSAC-125 to be seriously flawed are provided in the enclosed marked-up copy of NSAC-125.
i 1
In view of the serious flaws contained in the December 1988 draft of NSAC-125, we recomend that the document be returned to NUMARC without NRC endorsement on the basis that a substantial amount of rework is needed.
In the past, a substantial amount of staff resources has been expended in reviewing Itcensee proposed changes that involved unreviewed safety h
questions.
In most cases, the staff has found the proposed changes to be f 1, acceptable, though sometimes with scee modest adjustments in the licensee v
proposed changes, j ll' jc, y Jl q '),I: l es1;o7oico gg3;g!
/J pf03 PDR REVGP ERONurse FDC
\\
- *Mr. Charles Rossi
-2 As you know, the staff has a longer term objective of identifying initiatives which could reduce the demand for staff resources. As an option to returning the tiraft NSAC l?5 document as unacceptable, the staff could develop a reguletory framework under which pretty much the current draft of NSAC-125 cculd ha found acceptable.
For example we could offer the use of NSAC-125 to those licensees that agree to accept the findings of an independent INustry review group such as INP0 which would be certified by the NRC for conducting these types of reviews.
In effect, the approach would transfer much of this class of reviews and the associated resource requirements to the independent industr.v sponsored review group. Development of the regulatory framework to accomplish this transfer will require a fair amount of effort and may even require sted changes to 10 CFR 50.59. Obviously, this cannot be accomplished in the near term.
We shall be glad to discuss these conrnents as appropriate.
/h
/rr Steven A. V ga. Director Division of Reactor Pr?jects !/!!
Office of Nuclear Reactor Regulation
Enclosure:
As stated cc w/o enclosures:
J. Sniezek F. Miraglia D. Crutchfield
'Mr. Charles Rossi
.p.
As you know, the staff has a loncer term objective of identifying initiatives which could reduce the demand for staff re:ources.
As an option to returning the draft NSAC-125 document as unacceptable, the staff could develop a regulatory framework under which pretty riuch the current draft of NSAC-125 could be found acceptable.
For exar:ple we could offer the use of NSAC-125 to those licensees that agree to accept the findings of an independent industry review group such as INPO which would be certified by the NRC for conduc*ing these types of reviews, In effect, the approach would transfer ruch of this class of reviews and the associated resource requirements to the independent industry sponsored review aroup. Development of the regulatory framework to accomplish this transfer will requirr a fair amount of effort and may even require some changes to 10 CFR 50.69.
Obvi:usly, this cannot be accomplished in the near term.
We shall be glad to discuss these coments as appropriate.
/5/
Steven A. Varga. Director Division of Reactor Projects 1/II Office of Nuclear Peactor Regulation Er:losure:
As stated cc w/o enclosures:
J. Sniezek F. Miraglia D. Crutchfield DISTPIBUTION Doctet Mle NRC PDR/LPDR FDI-2 Reading SVaroa/BBoger t0'Brien KPutler OGC EJnrdan BGrires ACRS (10)
JSniezek
'raglia M
tchfield t
$51 MEMO)
- Freviously concurred PDI-2/D*
ADCI*
0 :
10 hEutler:tr BBoger Sia'ga 11/30/P8 11/30/08
${/88
'Mr. Charles Rossi.
As you know the staff has a longer term objective of identifying initiatives which could reduce the demand for staff resources.
As an option to returning the draft NSAC-125 document as unacceptable, the sta.ff could develop a regulatory framework under which pretty much the current draft of NSAC-125 could be found acceptable.
For example we could offer the use of NSAC-125 to those licensees that agree to accept the findings of an independent incastry review group such as INP0 which would be certified by the NRC for conducting these types of reviews.
In effect, the approach would transfer nuch of this class of reviews and the associated resource requirements to the independent industry spons ed review group.
Development of the regulatory framework tn accomplish this 6ransfer will require a fair amount of effort and may even require some changes to 10 CFR 50.59.
Obviously, this cannot be accomplished in the near term.
We shall be glad to disriss these comments as appropriate.
Steven A. Varga, Director Division of Reactor Projects I/II Office of Nuclear Reactor Regulation
Enclosure:
As stated cc w/o enclosures:
J. Sniezek F. Miraglia D. Crutchfield DISTRIBUTION Docket File NRC PDR/LPDR PDI-2 Reading SVarga/BBoger M0'Brien WButler 0GC EJordan BGrimes ACRS (10)
JSniezek FMiraglia DCrutchfield
[ROSSIMEMO)
PDI-2/D f k
D:DRPI/II flR er WEutler:t r SVarga ll / c/88
(/)/88
/ /88 3
L.
-