ML20197J425
| ML20197J425 | |
| Person / Time | |
|---|---|
| Issue date: | 12/29/1997 |
| From: | Bergman T NRC (Affiliation Not Assigned) |
| To: | NRC (Affiliation Not Assigned) |
| References | |
| PROJECT-689 NUDOCS 9801020180 | |
| Download: ML20197J425 (5) | |
Text
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d December 29, 1997 D.
MEMORANDUM TO: NEl Project File FROM:
Thomas A. Bergman, Senior Project Manager Original Signed By:
Generic issues and Environmental Projects Branch Division of Reactor Program Management Office of Nuclear Reactor Regulation
SUBJECT:
MEMORANDUM TO CHAIRMAN JACKSON FROM THE NUCLEAR ENERGY INSTITUTE CONCERNING PROPOSED REVISED LANGUAGE FOR 10 CFR 50.59 Attached is a memorandum from the Nuclear Energy institute to Chairman Shirley Jackson, NRC, concerning proposed revised language for 10 CFR 50.59. The memorandum was faxed to the Chairman on December 19,1997.
F roject No. 689
Attachment:
As stated
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December 29, 1997 MEMORANDUM TO: NEl Project File FROM:
Thomas A. Bergman, Senior Project Manager Generic issues and Environmental Projects Branch Division of Reactor Program Management Ohice of Nuclear Reactor Regulation
SUBJECT:
MEMORANDUM TO CHAIRMAN JACKSON FROM THE NUCLEAR ENERGY INSTITUTE CONCERNING PROPOSED REVISED LANGUAGE FOR 10 CFR 50.59 Attached is a memorandum from the Nuclect Energy Institute to Chairman Shirley Jackson, NRC, concerning proposed revised language for 10 CFR 50.59. The memorandum was faxed to the Chairman on December 19,1997.
Project No. 689 Attachrnent: As stated
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Dear Chaiman Jackson,
I believe the attacLed revised 10 Crit VJ.59 wording acco:nplisbee vur smutual ol/jectivos to casure 50.69 cvaluations are being performed to the right eenpe and perinits the consides ation of risk inei bts, 6
t Our hist xical review of the hec seing procesa convinces us that N plants were liceneed on the basis of an analym that concluded the plant mot th regulations and would respotd to postulated accidente in a manner that would not paan undue rirk to public Lealth and safety. Our su gested language for (a)(1) provides a 60.69 ocopo that would ensure that tho input assumptions anj parameters that went credited in tb accident analys.c, regardle.a of where they reside, are either yceerved or otherwise would be subject to ataff review and appivval Wo bdiove it is inappmpriate to hve the current licensing basis be the scope as j
there already exista other rogulatory required proceases for changing portions of the current licensing basis.We believe our sugg-eted approach fonnaos on the pertinent portions of th current licensing baris that should be captu; i undet 60.59 without hving to s.a the tera. That is,itja "C_LB invisible?
A ith respat to applying risk insights, wa believe the scope of the rt.gulation ((a)(1))
abould rem ain focused on the determmistic licensing basia, c'.leasi untilissuee regarding ths quality and empletanese of Pitas sat.sfies us that we are ready to y
make adjustments semas the indastry. Such adjustments may have to include rule
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changes to shift from the purely deterministic requirementa, where appropriate.
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"be detenninistic design basis r%uirements have werveo us well for providing defense-in. depth and clauld be preservod. E k iraights can halp focus our operational attention without cheging LM basic design of the planto. This metationalinclu can best be applied under (aM2) of the rule in considerQib tnrTritr51dirlo~r'derarmuuss if an unreviewed safety questica exists. Our propored language that allows negligible increases in probabihty pawidea operating flexibility for honriabaignificant changee fhat do not altar the accident analym resulta.
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We believe the attachd ruk language would provide stability and clarity in this crea nf the regulatmy proceen.
4 Att;mment
No.59 Changes, teste and experimenta.
j (aX1) he holder of alicense authorizing operation of a production or usation facility may G) make changes in the fheuity :: &cedtd 1: S: -aty ::='yi eepeak GI) make changes in the procedu=:.2 ?xd:' E & rmt; =^Yh repor6, and (iii) conduct tests or p=>+ ::: 6::adEN Mdy-"y6 seportrwithout pdor Commission approval, unlesa h proposed change, test or experiment involves a change in 6 technics) cpacineations incorporated in the license or an unredewed safety quedan. A safetv evninntion shall be conducted
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under (a(2) fbr ebances in the facilitv.nroceduren_ nr for taats or nocriments that v
t affect the nerformanca ne condition of th__e svetems, structures or components as
- redited in the nerihnt annivses.
(2) A proposed chans:e, test, or experismant shall bs deemed to involve an unreviewed safety question (i)if there is rnore than a nerlirilde incrr ase in the probability of occurrence er i ner. of an aa:ident or malfunction of egotpment important to safety previously evaluated in b dty-Mclye!e reper$ accident analypt -- y b ' n^ ^:f; or(inif the conneaucun of an accident or malfunction of couinment imnorfant to safety previonalv naluated in the einf=4y c
en.dyei: ::pricecident an alvsac eYeeeds the estabhshed nerentance limit: or (iii) If I
a possibility for an accident of a different type er malfunction en !!"non' typ:
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with a different result than any evaluated previonuly in the cah --%
sepertaccident analyses Inaybe created; or (i.v.u)1f the margin of safety :: ?:%- ' i:
- ferovided by any (scimical specification la redaced.
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(bX1) The licensee shall maintain records etchan ca in the facility and of changes in procedures made pursuant to this section, to the extent that these changes constituts Aanges in the facility as4ecorEd 'a '& cdty =dyi ped er te de
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- answalu~es that affect the nnfomanco or
- l EDDdition of svetetns. etructurve and comrionents nn ;;;=h:,0 0.c d::9hd b &
safoty-en^1;& rep:r! credited in the accident analyses. The licetan shall alsc.
maintain records of teste and experiments carried nut pursuant to pangraph (a) of this section. These recorda must indude a written safety evaluation which provides the bases for the determination that b change, test, c. exporiment does not involve an unreviewed safety question.
(2) he licensee shaB submit, as srecified in 550.4, a report conhimna a brief G.scription of any changes, tests, and experim ente, including a summ ary of the v'
safety evaluation ofeach.'Ibe report may be submitted annually cr along with the PSAR updates as requ rod by 650.71(e), or at rach shorter intervals as may be
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specifiedin the lloenee.
(3) The rtcor s ofchanges in the fhellity shall be maintained until the date. of d
termination of the beanse, and recnrds of changes in proceduzca and recortis of tests and experiments shall be maintained for a period of five years.
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_ _ _ _ _ _ ' _ ~ _ _ _ ' _ _ _ ____ _ _ _, _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _., _ _ _ _ _ __ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. _. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ _ _ _ _ __ ____ __
t (c) b holder of a license authorizing operation of a production or utilization fadlity who desires (1) a change in tecludcal speci6 cations or (2) to make a change in the facility or the procedures.desenbe46 cr to conduct tests or experinuata ce be > 2-%t akt th.eerW-ce cr condition of svetems.^.hc &;/ rd;6 :Atmetures and components as cwdited in the accident =at vses. an a which involve an unreviewed safety question or a change in technical speciEcations, shall submit an application for --aA=nt ofhis license pursuant to $60.90.
(d)h provizians of this section apply to each nudear power reactarlieenece that has submilled the certification of partnanent cessation ofoperations required under
$50.82(a)(1)(i).
(e) h provisions of paragraphs (a) through (t.) of this section apply to each non-power remeur licenece whose license no longer actbo.-i:es operation of the reactor.
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